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Multi-Association Comments to USCIS on the Changes to E-Verify through the Paperwork Reduction Act form change process
Friday, August 7, 2015 - 4:45pm
Re: OMB Control Number 1615–0092
Docket ID USCIS–2007–0023
Changes to E-Verify through the Paperwork Reduction Act form change process
80 Federal Register 32408 (June 8, 2015)
On behalf of the undersigned association member of the Council of Defense and Space Industry Associations (CODSIA), we are writing in opposition to the proposed expansion of the Information Collection Request published on June 8, 2015. The U.S. Citizenship and Immigration Services (USCIS) proposal acknowledges (1) expanding the use of E-Verify to include so-called “reverification” of expiring temporary worker documents and (2) revising the mandatory Memorandum of Understanding (MOU) and related processes for E-Verify use to create a formal review process when Final Non-Confirmations (FNCs) are issued. This proposed expansion of E-Verify conflicts with the governing E-Verify statute and the Federal Acquisition Regulation (FAR). Unrelated to the possible desirability of the underlying policies U.S. Citizenship and Immigration Services is promoting, there is no legal authority to expand E-Verify through a Paperwork Reduction Act process beyond the statutory terms, and in a manner that is inconsistent with the Federal Acquisition Regulation, without first seeking substantive revisions to those foundation authorities.