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AAU Joins ACE in Submitting Comments on USCIS Fee Rule

Yesterday, AAU joined ACE and over 20 other higher education associations in submitting a comment letter on the proposed Department of Homeland Security rule adjusting fees for various immigration services and benefits provided by U.S. Citizenship and Immigration Services. The agency is funded primarily by fees and has not increased prices for its services since 2016.

As the letter noted, USCIS is proposing an “almost 40 percent overall increase” in fees for programs important to higher education. The letter expressed concern that the fee increases were too severe and, combined with current slow adjudication times, would deter international talent. The letter urged USCIS to ensure that any fee increases are accompanied by regular processing times. It also encouraged DHS to move away from USCIS’ continued reliance on fees and for the agency to “request a congressional appropriation that funds its humanitarian programs.”

The letter specifically expressed concern regarding the 59% fee increase for Form I-765, Application for Employment Authorization, which students on F-1 visas currently use to apply for Optional Practical Training. The letter urged USCIS to exempt students applying for OPT or STEM OPT from the proposed fee increase for Form I-765. The letter also expressed concern about increases in fees related to the H-1B visa program, including a proposed $600 fee that employers seeking H-1B workers would have to pay to fund an asylum program. The letter asked USCIS to share the cost for supporting asylum seekers with other nonimmigrant classifications or to exempt institutions of higher education altogether. Finally, the letter asked USCIS to retain its current premium processing timeline at 15 calendar days as opposed to the proposed 15 business days.

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