In preparation for a long-delayed transition to online processing of immigration applications, the Homeland Security Department has released new rules for describing forms and filing procedures in official policies.
The 43-page federal notice published on Monday instructs U.S. Citizenship and Immigration Services, a unit of DHS, to stop typing on documents the traditional numbers and titles for various benefit claims, such as "Application for Naturalization, form N-400." Instead, to accommodate the new computerized system known as Transformation, USCIS policies and rules will carry more generic phrases, such as "the form designated by USCIS."
The linguistic changes will be necessary once Transformation becomes functional. The program currently is about a decade behind schedule. The new rules take effect shortly after Thanksgiving, on November 28. Agency officials have said the first digitized form, one for visitors requesting extensions to stay in the country, should be ready by the end of the year.
"Mandating in regulations specific form numbers reduces USCIS's ability to modify its business processes to reflect filing procedures in an electronic environment," states the notice, which was signed by Homeland Security Secretary Janet Napolitano.
But USCIS's website still will show form numbers for reference purposes.
The goal of the $2.4 billion Transformation program, according to the guidelines, is to improve customer service by offering applicants online accounts for submitting and tracking their cases. Agency employees also should be able to work faster because they will be collaborating on documents electronically, rather than physically transferring folders between offices. USCIS receives about 6 million forms annually.
All this digitization should tighten security by enabling staff to cross-check information from multiple applications so they can better detect identity fraud, DHS officials said.
One example cited in the notice: If a person's marital status or employment history in one file differs from the information listed in another pending file, the discrepancy could signal a documentation scam.
Simultaneously, the system "facilitates authorized sharing of information with partner components of DHS—in a secure environment that better protects against unauthorized disclosures," the guidelines state.
But recent federal investigations depict an agency with a poor track record in protecting electronic data from internal tampering. Justice Department officials this spring announced that a former USCIS contractor received a five-and-a-half-year prison sentence for doctoring records to help illegal immigrants obtain passports. A January 2008 inspector general probe found that employees and supervisors at an application-processing center in Texas abused network access privileges, obtained unauthorized login information, and then allegedly sabotaged audit logs to cover up their illicit activities.
An audit by the DHS inspector general earlier this year revealed USCIS may become more vulnerable to internal hacking due to Transformation's design. In the January report, Frank Deffer, assistant IG for information technology audits, noted that in "reading the Transformation requirements documentation, it is not clear that insiders are considered in the security requirements for prevention and detection of fraud or national security in USCIS systems."
Under Monday's rules, the term "Service," which had been synonymous with USCIS, will now refer, more generally, to DHS immigration services at various agencies, including USCIS, Customs and Border Protection, and Immigration and Customs Enforcement. The definition of Service in forthcoming rules "is amended to provide flexibility," the guidelines state.
USCIS also will scrap all mentions of job titles in regulations—including director, commissioner, and adjudicator—and replace them with the word "USCIS."
The notice explains, "Both position titles and delegated authority to perform specific duties assigned to USCIS employees are subject to change, potentially rendering regulatory references inaccurate or delaying implementation of planned operational changes."
Going forward, rules will not specify requirements, locations, or procedures for processing, but instead will convey handling instructions in more ambiguous ways because such provisions are subject to change under Transformation, officials added.
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