Agency Information Collection Activities; Reinstatement, With Change, of a Previously Approved Collection for Which Approval Has Expired: Alien Change of Address

An immigration attorney and owner of a boutique law firm opposes the proposed changes to the AR-11 form, arguing that the new requirements collect extraneous personal information and impose an unreasonable administrative burden. The commenter contends that the form exceeds its legal authority, lacks practical utility, and should remain in its current, simpler format.

Legal Services NYC opposes the proposed changes to Form AR-11, arguing that the new requirements for reporting public benefits will create a "chilling effect" that prevents mixed-status families from accessing essential services like housing and nutrition. The organization also contends that the proposal violates the Paperwork Reduction Act, exceeds USCIS's statutory authority, and jeopardizes the confidentiality of crime victims.

The Legal Aid Society (New York) opposes the proposed changes to Form AR-11, arguing that the collection of employment, education, and benefits-use information is unlawful, lacks a rational nexus to the form's purpose, and violates privacy protocols. They contend that these changes impose significant burdens on low-income immigrants and will create a chilling effect on the use of essential public benefits.

Greater Hartford Legal Aid, a non-profit law firm, opposes the proposed changes to Form AR-11 because they add unnecessary and over-inclusive questions regarding employment and means-tested benefits. They argue that this information is already collected elsewhere, creates confusion for recipients of specific services, and could have a chilling effect on parents seeking educational opportunities for their children.

The Immigrant Law Center of Minnesota, a nonprofit legal services organization, opposes the proposed revisions to the Alien Change of Address information collection. They argue that USCIS lacks the statutory authority to require information on public benefits, employment, and schooling, and that the expansion will deter compliance and discourage eligible individuals from seeking essential benefits.

The National Health Law Program (NHeLP) opposes the proposed changes to Form AR-11, arguing that it transforms a simple address change form into a public charge assessment tool. They contend that the proposal will create a "chilling effect," deterring immigrant families and U.S. citizen children from accessing vital healthcare and public benefits due to fear of immigration consequences.

FGA Action submits a comment in support of the proposed revision to Form AR-11, arguing that USCIS has the clear statutory authority to collect information on employment, schooling, and public benefits. The organization argues that the revision does not create new legal obligations but rather facilitates the enforcement of existing laws and is properly conducted under the Paperwork Reduction Act rather than the APA.

The commenter argues that the proposed expansion of Form AR-11 into a broad benefits-reporting mechanism lacks sufficient statutory authority. They contend that current laws only require address reporting and targeted investigations, rather than mandatory recurring disclosures from millions of filers.