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

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.

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.

The American College of Obstetricians & Gynecologists (ACOG) opposes the proposed changes to Form AR-11 that require immigrants to report means-tested public benefits. They argue that this data collection will create barriers to healthcare, disproportionately affect women and families, and discourage individuals from utilizing essential programs like Medicaid and SNAP.

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.

An individual is opposing the reinstatement and expansion of Form AR-11, arguing that requiring non-citizens to disclose receipt of means-tested public benefits is punitive and creates a mechanism for deportation. The commenter contends that the proposal is unnecessary for administrative efficiency and will have a chilling effect on immigrants seeking essential services like healthcare and education.