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AAU, Associations Submit Joint Comment Letter in Response to NPRM on DACA

AAU joined ACE and 44 other higher education associations in responding to the Department of Homeland Security’s notice of proposed rulemaking on the Deferred Action for Childhood Arrivals program. The joint letter highlighted the importance of the DACA program to the higher education community and acknowledged the significant contributions DACA recipients have made to our universities and to the country. “They teach in our schools and have served on the front lines of the pandemic as researchers, doctors, nurses, and other healthcare workers. They consider the United States to be their only home, and despite the immigration, financial, and other challenges they face, DACA recipients have made incredible contributions to our country, its economy, and security,” the letter noted.

The letter acknowledged the NPRM as an important step to “further enshrine” DACA and offered comments in the spirit of strengthening the program and providing additional certainty for Dreamers. The DACA program has not undergone any formal rulemaking since it was first established in 2012.

Among other things, the letter urged DHS to expand the threshold criteria for DACA eligibility; keep work authorization and deferred action together instead of making the request for employment authorization optional; explicitly state that the program will accept new applications once the rule is finalized; and confirm the policy allowing for advance parole for DACA recipients. The letter also applauded the proposed rule for including provisions stating that DACA recipients should not be a priority for removal and limiting DACA information from being used for enforcement purposes.

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