Comment Submitted by Anonymous

The newly proposed expansion of AR-11 change of address form by the agency violates the paperwork reduction act in many ways by having low practical utility and not minimizing the burden. Low practical utility: AR-11 change of address form is only used when a non citizen has an address change event. The questions regarding employment and public benefits are irrelevant to this address change event. Also, there is no direct dependency between change of address and the receipt of public benefits. Thus using the form AR-11 as a vehicle to collect information on these irrelevant and independent events will be an incomplete and weak attempt for the agency's given intended purpose as it will miss most of the people that are actually relevant in getting these information, eventually wasting resources of both the agency and the public. Also under public benefits section, the form says that the information provided by the person will be verified with the other agencies through data sharing agreements. If these information are already available under data sharing agreements, there is no practical utility of asking these same information again in this form, creating unnecessary duplications and wasting resources. Additional burden: This proposed expansion of the form AR-11 won't reduce but will create extra burden for the people who only comes to report an address change event. The form mentions the estimated burden time as 30 minutes, which is highly inacurate and seems to have been determined arbitrarily without a proper time study or a scenario analysis. For an example, suppose a person who is currently not taking any public benefit, but had taken some, long time ago, lawfully without being a public charge case. Since this happened long time ago and since the questions asked on public benefits are very broad, asking to provide details of every public benefit the user has ever received, without narrowing down to a certain time period (ex: within the last 12 months etc.) the person may run into challenges as they currently may not have all the details to accurately provide these information such as what benefits they took, who issued it, whether it was state or federally funded, how much or how long they took, if there is a reference/record number etc. Moreover, due to federal/state data retention and disposal policies/regulations, most of these old data may be already destroyed/disposed, as in some states the data retention period is limited to 3 years for these types of data. Thus to reliably obtain or verify/confirm anything beyond this time would be impractical for the person thus creating a significant burden/challenge which is much higher the mentioned estimated 30 minutes. This will also have the same issue for the agency as well when reviewing and verifying these information. Also, due to the new certification/signature clause under penalty and purgery, to certify the information are complete,true and correct, the person will have additional burden and pressure and will end up getting stuck in a limbo in this kind of a scenario as there is no possible way for the person to get the true, correct, complete information. Given all these information, it is respectfully recommended, not to adopt this new inefficient and ineffective form with low practical utility and higher burden for everyone, and utilize agency's resources in much better way.