Comment Submitted by Roots Reborn
AnonymousOpposeAdvocacy
Summary: Roots Reborn, an advocacy organization, opposes the proposed rule because it codifies fee increases that will cause financial strain on immigrant families and children. They argue that the fees are disproportionate to income and create a "Catch-22" for asylum seekers, recommending that the government prioritize clearing the court backlog instead of seeking new funding through fees.
Roots Reborn strongly opposes the proposed rule for USCIS Immigration Fees and Related Procedures under the H.R.1 Reconciliation Bill. This proposed rule will amend the USCIS regulations to codify fee increases for immigrant applications, including asylum.
While DHS claims that they have “no data that indicate that this IFR will have any impacts on disposable income or the poverty of certain families and children, including U.S. citizen children” and that “this rule would not have any impact on the autonomy or integrity of the family as an institution[,]” our organization firmly disagrees. When immigrants are not earning a living wage and are hit with increased immigration fees, children will be directly affected by the financial strain. This cascade of stressors hinders the family unit by decreasing individuals’ quality of life. Parental adversity and socioeconomic stressors directly increase children' s risk factors and adverse experiences, which can have a lasting effect on child development and adulthood. We have seen this in our own community, and with the continuous increase of USCIS filing fees. Because of these increases, families frequently struggle to meet their basic needs, including food and shelter.
This proposal would also create serious consequences for anyone unable to pay the annual asylum fees. The rule states that “. . . failure to pay within 30 days of notice results in rejection of the pending asylum application and the denial of any associated application for employment authorization.” This proposal is asking immigrants to pay for numerous fees that are nowhere near proportionate to immigrants’ income, or else they lose their employment authorization and pending asylum. This proposed rule is nothing but a Catch-22 – asylum applicants cannot receive work authorization unless they pay the required fees, but they are not permitted to work and earn income without the work permit.
Moreover, according to the American Immigration Council, “[t]he backlog in immigration courts continues to reach all-time highs, with over 3.7 million open removal cases as of January 31, 2025. At the end of FY 2024, 1,478,623 defensive asylum applications were pending in immigration courts.” Despite any efforts that immigrants make to ensure they are following the process and rules required of them, the system is structured in ways that set them up for failure.
To ensure that the U.S. immigration system remains transparent, just, and fair, our organization recommends that a greater priority be directed at reviewing the backlog of asylum applications rather than seeking this funding. This proposed rule will only exacerbate the existing strain that immigrants and immigrant families experience. As a result, Roots Reborn strongly opposes the proposed rule for USCIS Immigration Fees and Related Procedures under the H.R.1 Reconciliation Bill.