Prohibit Regulatory Actions on USCIS
Forms
USCIS should amend its regulations
to stop automatically incorporating all form instruction changes
into its regulations, bypassing notice and public comment
procedures.
USCIS requires employers and applicants
for immigration benefits to use forms that it creates to collect
information.
1 Along with these forms, USCIS
publishes detailed instructions that explain to applicants how they
must fill out the form and the types of information or evidence
that must be provided. USCIS s regulations currently assert
that all form instruction changes are incorporated into the
regulations themselves.
2 The clause allows the agency to
evade a slew of federal statutes and presidential directives