USCIS Has Added 500 Pages to Its Immigration Forms Since 2003 – Cato Institute
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U.S. Citizenship and Immigration Services (USCIS) is facing an unprecedented backlog of immigration cases. Nearly 9 million applications across a variety of categories were pending in 2022, an entire year’s worth of submissions. One reason that it is taking the agency more resources to process applications is that it has dramatically lengthened the forms that it requires.
From 2003—when the agency began—until 2022, the total length of the USCIS immigration forms grew from 193 pages to 701 pages—an increase of 508 pages (Figure 1). The average form length grew from about 3 pages to about 10 pages—a 217‐percent increase. From 2003 to 2008, the agency added 81 pages (14 per year). From 2008 to 2016, it added 213 pages (24 per year). From 2016 to 2022, it added 214 pages (31 per year). All page counts exclude the length of the form directions, but the form directions have also exploded in length. To allow easier comparisons across years, they also generally exclude supplemental forms, meaning that the true form page count would be even higher.
Table 1 shows the data on which Figure 1 is based. Of the 71 forms considered, the agency has increased the length of nearly every form. Only one form that was in use throughout the entire period of 2003 to 2022 did not increase (the rather unusual form I‑687, Application for Status as a Temporary Resident). In other words, 99 percent of USCIS’s forms either grew longer or were created since 2003. Even the forms that were created during this time have grown. Overall, 93 percent of forms have grown longer since their creation.
The Form I‑212 (Application for Permission to Reapply for Admission into the United States After Deportation or Removal) has increased the most in percentage terms: 1,000 percent from 1 page to 11 pages. The Form I‑130 petition for alien spouse (now with I‑130A) has increased 800 percent from 2 pages to 18 pages. In absolute terms, the form that saw the biggest growth was the I‑129 form, petition for a nonimmigrant worker, which added 26 pages. The agency also added 16 pages to the form I‑485, adjustment of status to legal permanent residence.
The longer forms take longer for the agency to process because it must manually enter and review every question response—no matter how trivial. In August 2021, the Government Accountability Office reported:
According to staff we interviewed from four of eight USCIS field locations, longer forms increased the amount of time it takes for staff to adjudicate applications and petitions, and resulted in longer interviews, since adjudicators were to collect and confirm additional information.… USCIS added questions to the Application to Register Permanent Residence (Form I‑485) regarding the applicant’s parents, marital history, and past application history. With respect to the Petition for Alien Relative (Form I‑130), USCIS added questions related to the petitioner’s background, biographical information, parents, current or former spouses, and the petitioner’s addresses and employment history for the previous 5 years.
USCIS also added questions to the I‑485 form that request a potentially enormous quantity of information. For instance, one question states:
Have you EVER been arrested, cited, charged, or detained for any reason by any law enforcement official (including but not limited to any U.S. immigration official or any official of the U.S. armed forces or U.S. Coast Guard)?
The form does not define the word “detained” which could potentially encompass any border crossing in the entire world, any traffic stop in the world, etc. Documenting this type of information is an extreme imposition on any applicant, but there is also no doubt that the agency is being flooded with massive quantities of useless documentation because of this single question.
It is worth emphasizing that no significant immigration reform has become law during the last two decades. The agency is unilaterally imposing dramatic increases in the bureaucratic obstacles to immigration benefits without input from Congress. But the hundreds of new pages of information is also making the agency less efficient at its job, delaying applications and causing backlogs to grow to unimaginable lengths (Figure A).
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