Procedures for Credible Fear Screening and Consideration of Asylum, Withholding of Removal, and CAT Protection Claims by Asylum Officers, 18078-18226 [2022-06148]
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18078
Federal Register / Vol. 87, No. 60 / Tuesday, March 29, 2022 / Rules and Regulations
8 CFR Parts 208, 212, and 235
[CIS No. 2692–21; DHS Docket No. USCIS–
2021–0012]
RIN 1615–AC67
DEPARTMENT OF JUSTICE
Executive Office for Immigration
Review
8 CFR Parts 1003, 1208, 1235, and 1240
[A.G. Order No. 5369–2022]
RIN 1125–AB20
Procedures for Credible Fear
Screening and Consideration of
Asylum, Withholding of Removal, and
CAT Protection Claims by Asylum
Officers
Executive Office for
Immigration Review, Department of
Justice; U.S. Citizenship and
Immigration Services, Department of
Homeland Security.
ACTION: Interim final rule with request
for comments.
AGENCY:
On August 20, 2021, the
Department of Homeland Security
(‘‘DHS’’) and the Department of Justice
(‘‘DOJ’’) (collectively ‘‘the
Departments’’) published a notice of
proposed rulemaking (‘‘NPRM’’ or
‘‘proposed rule’’) that proposed
amending regulations governing the
procedures for determining certain
protection claims and available parole
procedures for individuals subject to
expedited removal and found to have a
credible fear of persecution or torture.
After a careful review of the comments
received, the Departments are now
issuing an interim final rule (‘‘rule’’ or
‘‘IFR’’) that responds to comments
received in response to the NPRM and
adopts the proposed rule with changes.
Most significantly, the IFR provides that
DHS’s United States Citizenship and
Immigration Services (‘‘USCIS’’) will
refer noncitizens whose applications are
not granted to DOJ’s Executive Office for
Immigration Review (‘‘EOIR’’) for
streamlined removal proceedings. The
IFR also establishes timelines for the
consideration of applications for asylum
and related protection by USCIS and, as
needed, EOIR. This IFR responds to
comments received in response to the
NPRM and adopts the NPRM with
changes as described in this rule. The
Departments solicit further public
comment on the IFR’s revisions, which
will be considered and addressed in a
future rule.
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SUMMARY:
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Effective Date: This interim final
rule is effective May 31, 2022.
Submission of public comments:
Comments must be submitted on or
before May 31, 2022. The electronic
Federal Docket Management System
will accept comments prior to midnight
eastern time at the end of that day.
ADDRESSES: You may submit comments
on the entirety of this interim final rule
package, identified by DHS Docket No.
USCIS–2021–0012, through the Federal
eRulemaking Portal: https://
www.regulations.gov. Follow the
website instructions for submitting
comments.
Comments submitted in a manner
other than the one listed above,
including emails or letters sent to the
Departments’ officials, will not be
considered comments on the interim
final rule and may not receive a
response from the Departments. Please
note that the Departments cannot accept
any comments that are hand-delivered
or couriered. In addition, the
Departments cannot accept comments
contained on any form of digital media
storage devices, such as CDs/DVDs and
USB drives. The Departments also are
not accepting mailed comments at this
time. If you cannot submit your
comment by using https://
www.regulations.gov, please contact
Samantha Deshommes, Chief,
Regulatory Coordination Division,
Office of Policy and Strategy, U.S.
Citizenship and Immigration Services,
Department of Homeland Security, by
telephone at (240) 721–3000 (not a tollfree call) for alternate instructions.
FOR FURTHER INFORMATION CONTACT:
For USCIS: Rena´ Cutlip-Mason, Chief,
Division of Humanitarian Affairs, Office
of Policy and Strategy, U.S. Citizenship
and Immigration Services, Department
of Homeland Security, 5900 Capital
Gateway Drive, Camp Springs, MD
20588–0009; telephone (240) 721–3000
(not a toll-free call).
For EOIR: Lauren Alder Reid,
Assistant Director, Office of Policy,
Executive Office for Immigration
Review, Department of Justice, 5107
Leesburg Pike, Falls Church, VA 22041;
telephone (703) 305–0289 (not a toll-free
call).
SUPPLEMENTARY INFORMATION:
DATES:
DEPARTMENT OF HOMELAND
SECURITY
Table of Contents
I. Public Participation
II. Executive Summary
A. Background
B. Legal Authority
C. Changes in the IFR
1. Revisions to the Proposed DHS
Regulations
2. Revisions to the Proposed DOJ
Regulations
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D. Provisions of the IFR
1. Credible Fear Screening Process
2. Applications for Asylum
3. Proceedings for Further Consideration of
the Application for Asylum by USCIS
Through Asylum Merits Interview for
Noncitizens With Credible Fear
4. Streamlined Section 240 Removal
Proceedings Before the Immigration
Judge
5. Parole
E. Summary of Costs and Benefits
F. Effective Date
III. Discussion of the IFR
A. Credible Fear Screening Process
B. Applications for Asylum
C. Proceedings for Further Consideration of
the Application for Asylum by USCIS
Through Asylum Merits Interview for
Noncitizens With Credible Fear
D. Streamlined Section 240 Removal
Proceedings Before the Immigration
Judge
1. Schedule of Proceedings
a. Pre-Hearing Procedures
b. Merits Hearing(s)
2. Evidentiary Standard
3. Timeline for Proceedings
4. Continuances and Filing Extensions
5. Consideration of Statutory Withholding
of Removal and CAT Protection
6. Exceptions to Streamlined Procedures
E. Other Amendments Related to Credible
Fear
F. Parole
G. Putative Reliance Interests
IV. Response to Public Comments on the
Proposed Rule
A. Summary of Public Comments
B. General Feedback on the Proposed Rule
1. General Support for the Proposed Rule
a. Immigration Policy Benefits
b. Positive Impacts on Applicants, Their
Support Systems, and the Economy
2. General Opposition to the Proposed Rule
a. Immigration Policy Concerns
b. Negative Impacts on Applicants and
Their Support Systems
c. Negative Impacts on U.S. Citizens and
the Economy
d. Other General Opposition to the
Proposed Rule
C. Basis for the Proposed Rule
1. DOJ and DHS Statutory/Legal Authority
2. Need for the Proposed Rule/DOJ and
DHS Rationale
3. Prior Immigration Rulemakings
D. Proposed Changes
1. Applicability
2. Parole
a. General Comments on Parole
b. Change in Circumstances Under Which
Parole May Be Considered
c. Availability of Employment
Authorization for Those in Expedited
Removal Who Have Been Paroled From
Custody
d. Other Comments on Proposed Approach
to Parole
3. Credible Fear Screening Process
a. General Comments on Credible Fear
Screening Process
b. ‘‘Significant Possibility’’ Standard for
Protection Claims
c. Due Process in Credible Fear Screening
d. Removal of Mandatory Bars From
Consideration
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e. Other Comments on the Proposed
Credible Fear Screening Process
4. Applications for Asylum
a. Written Record of the Credible Fear
Determination Created by USCIS,
Together With the Service of the
Credible Fear Determination, Treated as
an Application for Asylum
b. Date Positive Credible Fear
Determination Served as Date of Filing
and Receipt
c. Inclusion of Applicant’s Spouse and
Children
d. Due Process in Asylum Applications
e. Other Comments on Proposed Provisions
on Applications for Asylum
5. Adjudication of Applications for Asylum
for Noncitizens With Credible Fear
a. DHS Interpretation of Statute in Creating
a New Adjudication Process
b. Review of Asylum Claim by an Asylum
Officer, Rather Than by an Immigration
Judge, in Section 240 Removal
Proceedings
c. Requirements for USCIS Asylum Merits
Adjudication
d. Failure To Appear
e. Process for USCIS To Deny an
Application for Asylum or Other
Protection and Issue a Removal Order
f. Other Comments on Proposed
Adjudication of Applications for Asylum
6. Application Review Proceedings Before
an Immigration Judge
a. Creation of New Limited Proceedings in
Lieu of Section 240 Removal Proceedings
and Limitation on Relief to Asylum,
Statutory Withholding of Removal, and
Convention Against Torture Review
Only
b. De Novo Review of Full Asylum Hearing
Record and Consideration of Additional
Testimony and Evidence
c. Immigration Judge’s Discretion To
Vacate Asylum Officer’s Removal Order
d. Immigration Judge’s Authority To
Review All Asylum Officer Decisions
e. Appeal of Immigration Judge’s Decision
to the Board of Immigration Appeals
f. Other Comments on Proposed
Application Review Proceedings before
Immigration Judges
E. Other Issues Related to the Proposed
Rulemaking
1. Public and Stakeholder Input
2. Severability
3. Discretion and Phased Implementation
a. Discretion
b. Phased Implementation
4. Comments on Immigration Court
Inefficiencies and Bottlenecks
F. Statutory and Regulatory Requirements
1. Impacts and Benefits (E.O. 12866 and
E.O. 13563)
a. Methodology
b. Population
c. Costs or Transfers
i. Impacts on the Credible Fear Asylum
Population and Support Networks
ii. Impacts on U.S. Workers, Companies,
Economy
iii. Impacts on Federal Government
iv. Other Comments on Costs or Transfers
d. Other Comments on Impacts and
Benefits of the Proposed Rulemaking
2. Paperwork Reduction Act
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3. Other Comments on Statutory and
Regulatory Requirements
G. Comments Outside of the Scope of This
Rulemaking
V. Statutory and Regulatory Requirements
A. Administrative Procedure Act
B. Executive Order 12866 (Regulatory
Planning and Review) and Executive
Order 13563 (Improving Regulation and
Regulatory Review)
1. Summary of the Rule and Its Potential
Impacts
2. Background and Purpose of the Rule
3. Population
4. Impacts of the Rule
a. Impacts to the Credible Fear Asylum
Population
b. Impacts to USCIS
i. Total Quantified Estimated Costs of
Regulatory Changes
ii. Intra-Federal Government Sector
Impacts
c. Familiarization Costs, Benefits, and
Transfers of Possible Early Labor Market
Entry
C. Regulatory Flexibility Act
D. Unfunded Mandates Reform Act of 1995
E. Congressional Review Act
F. Executive Order 13132 (Federalism)
G. Executive Order 12988 (Civil Justice
Reform)
H. Family Assessment
I. Executive Order 13175 (Consultation and
Coordination With Indian Tribal
Governments)
J. National Environmental Policy Act
K. Paperwork Reduction Act
I. Public Participation
The Departments invite all interested
parties to participate in this rulemaking
by submitting written data, views,
comments, and arguments on all aspects
of this interim final rule by the deadline
stated above. The Departments also
invite comments that relate to the
economic, environmental, or federalism
effects that might result from this
interim final rule. Comments must be
submitted in English, or an English
translation must be provided.
Comments that will provide the most
assistance to the Departments in
implementing these changes will
reference a specific portion of the
interim final rule, explain the reason for
any recommended change, and include
data, information, or authority that
support such recommended change.
Comments submitted in a manner other
than those listed above, including
emails or letters sent to the
Departments’ officials, will not be
considered comments on the interim
final rule and may not receive a
response from the Departments.
Instructions: If you submit a
comment, you must include the agency
name and the DHS Docket No. USCIS–
2021–0012 for this rulemaking. All
submissions will be posted, without
change, to the Federal eRulemaking
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Portal at https://www.regulations.gov,
and will include any personal
information you provide. Therefore,
submitting this information makes it
public. You may wish to consider
limiting the amount of personal
information that you provide in any
voluntary public comment submission
you make to the Departments. The
Departments may withhold information
provided in comments from public
viewing that they determine may impact
the privacy of an individual or that is
offensive. For additional information,
please read the Privacy and Security
Notice available at https://
www.regulations.gov.
Docket: For access to the docket and
to read background documents or
comments received, go to https://
www.regulations.gov, referencing DHS
Docket No. USCIS–2021–0012. You may
also sign up for email alerts on the
online docket to be notified when
comments are posted or a final rule is
published.
II. Executive Summary
A. Background
On August 20, 2021, the Departments
published an NPRM in the Federal
Register proposing to amend the
regulations governing the process for
further consideration of asylum and
related protection claims raised by
individuals subject to expedited
removal and found to have a credible
fear of persecution or torture. See
Procedures for Credible Fear Screening
and Consideration of Asylum,
Withholding of Removal, and CAT
Protection Claims by Asylum Officers,
86 FR 46906 (Aug. 20, 2021).
The preamble discussion in the
NPRM, including the detailed
presentation of the need for reforming
the system for processing asylum and
related protection claims at the
Southwest border, is generally adopted
by reference in this IFR, except to the
extent specifically noted in this IFR, or
in the context of proposed regulatory
text that is not contained in this IFR.
To reform and improve the process,
the NPRM proposed revisions to 8 CFR
parts 208, 235, 1003, 1208, and 1235.
Those proposed revisions fell into five
main categories. First, individuals
subject to expedited removal and found
to have a credible fear of persecution or
torture would have their claims for
asylum, withholding of removal under
section 241(b)(3) of the Immigration and
Nationality Act (‘‘INA’’ or ‘‘the Act’’)
(‘‘statutory withholding of removal’’), or
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Convention Against Torture (‘‘CAT’’) 1
protection initially adjudicated by
USCIS following a nonadversarial
interview before an asylum officer.
Second, individuals granted protection
by USCIS would be entitled to asylum,
statutory withholding of removal, or
protection under the CAT, as
appropriate, without further
adjudication. Third, individuals not
granted protection would be ordered
removed by the asylum officer but
would have the ability to seek prompt,
de novo review with an immigration
judge (‘‘IJ’’) in EOIR through a newly
established procedure, with appeal
available to the Board of Immigration
Appeals (‘‘BIA’’) and the Federal courts.
Fourth, individuals placed in expedited
removal proceedings would be eligible
for consideration for parole from
custody in accordance with section
212(d)(5) of the Act, if DHS determined,
in the exercise of its discretion and on
a case-by-case basis, that parole is
warranted because, inter alia, detention
is unavailable or impracticable
(including situations in which
continued detention would unduly
impact the health or safety of
individuals with special
vulnerabilities). Finally, the NPRM
proposed to restore the expedited
removal framework and credible fear
screening processes that were in place
before various regulatory changes made
from late 2018 through late 2020.
Specifically, the longstanding
‘‘significant possibility’’ screening
standard would apply once more to all
such protection claims arising from
expedited removal proceedings initiated
pursuant to section 235(b)(1) of the Act,
and the mandatory bars to asylum and
withholding of removal (with limited
exception) would not apply at this
initial screening stage.
The comment period for the NPRM
opened on August 20, 2021, and closed
on October 19, 2021, with 5,235 public
comments received. The Departments
summarize and respond to the public
comments below in Section IV of this
preamble.
B. Legal Authority
The Departments are publishing this
IFR pursuant to their respective and
joint authorities concerning asylum,
statutory withholding of removal, and
protection under the CAT. Section 235
of the INA provides that if an asylum
officer determines that a noncitizen
subject to expedited removal has a
1 Convention Against Torture and Other Cruel,
Inhuman or Degrading Treatment or Punishment,
Dec. 10, 1984, S. Treaty Doc. No. 100–20, 1465
U.N.T.S. 85 (entered into force for United States
Nov. 20, 1994).
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credible fear of persecution, the
noncitizen shall receive ‘‘further
consideration of the application for
asylum.’’ INA 235(b)(1)(B)(ii), 8 U.S.C.
1225(b)(1)(B)(ii). This IFR addresses
how that further consideration,
including of the noncitizen’s related
claims to statutory withholding of
removal and CAT protection, will occur.
Section 208 of the INA authorizes the
‘‘Secretary of Homeland Security or the
Attorney General’’ to ‘‘grant asylum’’ to
a noncitizen—including a noncitizen
subject to expedited removal under
section 235(b) of the INA—‘‘who has
applied for asylum in accordance with
the requirements and procedures
established by the Secretary of
Homeland Security or the Attorney
General under this section.’’ INA
208(b)(1)(A), 8 U.S.C. 1158(b)(1)(A); see
INA 208(a)(1), 8 U.S.C. 1158(a)(1)
(referencing asylum applications by
noncitizens subject to expedited
removal under section 235(b) of the
INA, 8 U.S.C. 1225(b)); see also INA
208(d)(1), (d)(5)(B), 8 U.S.C. 1158(d)(1),
(d)(5)(B) (further authorizing rulemaking
concerning asylum applications).
These provisions of the INA reflect
that the Homeland Security Act of 2002
(‘‘HSA’’), Public Law 107–296, 116 Stat.
2135, as amended, created DHS and
transferred to it many functions related
to the execution of Federal immigration
law. See, e.g., HSA 101, 441, 451(b),
471, 1511(d)(2), 6 U.S.C. 111, 251,
271(b), 551(d)(2). By operation of the
HSA, certain references to the ‘‘Attorney
General’’ in the INA are understood to
refer to the Secretary. HSA 1517, 6
U.S.C. 557. As amended by the HSA, the
INA thus ‘‘charge[s]’’ the Secretary
‘‘with the administration and
enforcement of this chapter and all
other laws relating to the immigration
and naturalization of aliens,’’ INA
103(a)(1), 8 U.S.C. 1103(a)(1), and grants
the Secretary the power to ‘‘establish
such regulations; . . . issue such
instructions; and perform such other
acts as he deems necessary for carrying
out his authority’’ under the
immigration laws, INA 103(a)(3), 8
U.S.C. 1103(a)(3). The Secretary’s
authority thus includes the authority to
publish regulations governing the
apprehension, inspection and
admission, detention and removal,
withholding of removal, and release of
noncitizens 2 encountered in the interior
of the United States or at or between the
U.S. ports of entry. See INA 235, 236,
241, 8 U.S.C. 1225, 1226, 1231. Certain
2 This rule uses the term ‘‘noncitizen’’ as
equivalent to the statutory term ‘‘alien.’’ See INA
101(a)(3), 8 U.S.C. 1101(a)(3); Barton v. Barr, 140 S.
Ct. 1442, 1446 n.2 (2020).
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of the Secretary’s authorities have been
delegated within DHS to the Director of
USCIS.3 USCIS asylum officers conduct
credible fear interviews, make credible
fear determinations, and determine
whether a noncitizen’s affirmative
asylum application should be granted.
See 8 CFR 208.2(a), 208.9(a), 208.30.
In addition, under the HSA, the
Attorney General retains authority to
‘‘establish such regulations . . ., issue
such instructions, review such
administrative determinations in
immigration proceedings, delegate such
authority, and perform such other acts
as the Attorney General determines to
be necessary for carrying out’’ his
authorities under the INA. HSA 1102,
INA 103(g)(2), 8 U.S.C. 1103(g)(2). The
Attorney General also retains authority
over certain individual immigration
adjudications, including removal
proceedings pursuant to section 240 of
the INA, 8 U.S.C. 1229a (‘‘section 240
removal proceedings,’’ ‘‘section 240
proceedings,’’ or ‘‘240 proceedings’’),
and certain adjudications related to
asylum applications, conducted by IJs
within DOJ’s EOIR. See HSA 1101(a), 6
U.S.C. 521(a); INA 103(g), 8 U.S.C.
1103(g). With limited exceptions, IJs
within EOIR adjudicate asylum and
withholding of removal applications
filed by noncitizens during the
pendency of section 240 removal
proceedings, and IJs also adjudicate
asylum applications referred by USCIS
to the immigration court. 8 CFR
1208.2(b), 1240.1(a); see INA 101(b)(4),
240(a)(1), 8 U.S.C. 1101(b)(4),
1229a(a)(1); INA 241(b)(3), 8 U.S.C.
1231(b)(3).
The United States is a party to the
1967 United Nations Protocol Relating
to the Status of Refugees, January 31,
1967, 19 U.S.T. 6223, 606 U.N.T.S. 268
(‘‘Refugee Protocol’’), which
incorporates Articles 2 through 34 of the
1951 Convention Relating to the Status
of Refugees, July 28, 1951, 19 U.S.T.
6259, 189 U.N.T.S. 150 (‘‘Refugee
Convention’’). Article 33 of the Refugee
Convention contains a qualified nonrefoulement obligation to refrain from
expelling or returning ‘‘a refugee in any
manner whatsoever to the frontiers of
territories where his life or freedom
would be threatened on account of his
race, religion, nationality, membership
of a particular social group or political
opinion.’’ 19 U.S.T. at 6276. The United
States implements its obligations under
Article 33 of the Refugee Convention
(via the Refugee Protocol) through the
statutory withholding of removal
3 See DHS, Delegation to the Bureau of
Citizenship and Immigration Services, No. 0150.1
(June 5, 2003); see also 8 CFR 2.1, 208.2(a), 208.30.
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provision in section 241(b)(3) of the
INA, 8 U.S.C. 1231(b)(3), which
provides that a noncitizen may not be
removed to a country where his or her
life or freedom would be threatened on
account of one of the protected grounds
listed in Article 33 of the Refugee
Convention.
The Foreign Affairs Reform and
Restructuring Act of 1998 (‘‘FARRA’’)
provides the Departments with the
authority to ‘‘prescribe regulations to
implement the obligations of the United
States under Article 3 of the [CAT],
subject to any reservations,
understandings, declarations, and
provisos contained in the United States
Senate resolution of ratification of the
Convention.’’ Public Law 105–277, div.
G, sec. 2242(b), 112 Stat. 2681. In
addition, FARRA includes the following
policy statement: ‘‘It shall be the policy
of the United States not to expel,
extradite, or otherwise effect the
involuntary return of any person to a
country in which there are substantial
grounds for believing the person would
be in danger of being subjected to
torture . . . . ’’ Id., sec. 2242(a). DHS
and DOJ have promulgated various
regulations implementing U.S.
obligations under Article 3 of the CAT,
consistent with FARRA. See, e.g., 8 CFR
208.16(c) through (f), 208.17, and
208.18; Regulations Concerning the
Convention Against Torture, 64 FR 8478
(Feb. 19, 1999), as corrected by 64 FR
13881 (Mar. 23, 1999).
Section 212 of the INA vests in the
Secretary the discretionary authority to
grant parole to applicants for admission
on a case-by-case basis for urgent
humanitarian reasons or significant
public benefit. INA 212(d)(5)(A), 8
U.S.C. 1182(d)(5)(A). Section 103 of the
INA authorizes the Secretary to
establish rules and regulations
governing parole. INA 103(a)(1), (3), 8
U.S.C. 1103(a)(1), (3).
C. Changes in the IFR
After carefully reviewing the public
comments received in response to the
NPRM, this IFR makes 23 changes to the
regulatory provisions proposed in the
NPRM, many of which were
recommended or prompted by
commenters. The regulatory changes
pertain to both the DHS and DOJ
regulations. As also described below,
procedurally, the Departments could
issue a final rule. However, the
Departments are publishing this IFR
rather than proceeding to a final rule in
order to provide the public with an
additional opportunity to comment.
Although not legally required, the
additional opportunity to comment on
the IFR’s changes to the NPRM is
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desirable given the new procedures and
scheduling deadlines applicable to the
IFR’s streamlined EOIR process, the
limited time between issuance of this
IFR and when the first cases will be
calendared for hearings, and the
changes made to facilitate a shift from
the proceedings proposed in the NPRM
to the IFR’s streamlined 240
proceedings. The Departments therefore
solicit further public comment on the
IFR’s revisions, which will be
considered and addressed in a final
rule.
1. Revisions to the Proposed DHS
Regulations
First, in new 8 CFR 208.30(g)(1)(i),
this rule provides that USCIS may, in its
discretion, reconsider a negative
credible fear finding with which an IJ
has concurred, provided such
reconsideration is requested by the
applicant or initiated by USCIS no more
than 7 days after the concurrence by the
IJ, or prior to the noncitizen’s removal,
whichever date comes first. USCIS,
however, will not accept more than one
such request for reconsideration of a
negative credible fear finding.
Second, this rule adds a new 8 CFR
208.4(b)(2) to clarify that noncitizens
whose asylum applications are retained
by USCIS for further consideration
following a positive credible fear
determination may subsequently amend
or correct the biographic or credible fear
information in the Form I–870, Record
of Determination/Credible Fear
Worksheet, or supplement the
information collected during the process
that concluded with a positive credible
fear determination, provided the
information is submitted directly to the
asylum office no later than 7 days prior
to the scheduled asylum interview, or
for documents submitted by mail,
postmarked no later than 10 days prior
to the interview. This rule further
provides that, upon the asylum officer
finding good cause in an exercise of
USCIS discretion, the asylum officer
may consider amendments or
supplements submitted after the 7- or
10-day submission deadline or may
grant the applicant an extension of time
during which the applicant may submit
additional evidence, subject to the
limitation on extensions described in
new 8 CFR 208.9(e)(2) and provided in
new 8 CFR 208.4(b)(2). In new 8 CFR
208.9(e)(2), this rule further provides
that, in the absence of exigent
circumstances, an asylum officer shall
not grant any extensions for submission
of additional evidence that would
prevent a decision from being issued to
the applicant within 60 days of service
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of the positive credible fear
determination.
Third, this rule provides in new 8
CFR 208.2(a)(1)(ii), 208.30(f), 1208.2,
and 1208.30(g) that USCIS may further
consider the asylum application of a
noncitizen found to have a credible fear
of persecution or torture through a
nonadversarial merits interview
conducted by an asylum officer when
such application is retained by USCIS or
referred to USCIS by an IJ after an IJ has
vacated a negative credible fear
determination. Such nonadversarial
merits interviews are known as
‘‘Asylum Merits interviews’’ and are
governed by the procedures in 8 CFR
208.9.
Fourth, this rule provides in new 8
CFR 208.9(b) that, in the case of a
noncitizen whose case is retained by
USCIS for an Asylum Merits interview,
an asylum officer will also elicit all
relevant and useful information bearing
on the applicant’s eligibility for
statutory withholding of removal and
CAT protection. This rule provides that
if the asylum application is not granted,
the asylum officer will determine
whether the noncitizen is eligible for
statutory withholding of removal in
accordance with 8 CFR 208.16(b) or
CAT protection pursuant to 8 CFR
208.16(c). See 8 CFR 208.16(a), (c). Even
if the asylum officer determines that the
applicant has established eligibility for
statutory withholding of removal or
protection under the CAT, the asylum
officer shall proceed with referring the
asylum application to the IJ for a
hearing pursuant to 8 CFR 208.14(c)(1).
See 8 CFR 208.16(a). If the asylum
application includes a dependent (that
is, a spouse or child who is in the
United States and is included on the
principal applicant’s application as a
dependent, cf. 8 CFR 208.30(a),
208.14(f)) who has not filed a separate
application and the principal applicant
is determined to not to be eligible for
asylum, the asylum officer will elicit
sufficient information to determine
whether there is a significant possibility
that the dependent has experienced or
fears harm that would be an
independent basis for protection prior to
referring the family to the IJ for a
hearing. See 8 CFR 208.9(b). If the
asylum officer determines that there is
a significant possibility that the
dependent has experienced or fears
harm that would be an independent
basis for asylum, statutory withholding
of removal, or protection under the
CAT, the asylum officer shall inform the
dependent of that determination. See id.
USCIS also intends to inform
dependents that they may request their
own credible fear determination and
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may separately file an asylum
application if they choose to do so. If a
spouse or child who was included in
the principal’s request for asylum does
not separately file an asylum
application that is adjudicated by
USCIS, the principal’s asylum
application will be deemed by EOIR to
satisfy EOIR’s application filing
requirements for the spouse or child as
principal applicants. See 8 CFR
208.3(a)(2), 1208.3(a)(2).
Fifth, this rule provides in 8 CFR
208.9(a)(1) that USCIS shall not
schedule an Asylum Merits interview
for further consideration of an asylum
application following a positive credible
fear determination fewer than 21 days
after the noncitizen has been served a
record of the positive credible fear
determination. The asylum officer shall
conduct the interview within 45 days of
the date that the positive credible fear
determination is served on the
noncitizen, subject to the need to
reschedule an interview due to exigent
circumstances. See 8 CFR 208.9(a)(1).
Sixth, this rule includes language
from existing regulations, currently in
effect, in 8 CFR 208.9(d), that was
inadvertently not included in the
NPRM’s proposed regulatory text related
to USCIS’s discretion to limit the length
of a statement or comment and require
its submission in writing. See 8 CFR
208.9(d)(1).
Seventh, this rule removes language
proposed in the NPRM in 8 CFR
208.9(f)(2) related to having the Asylum
Merits record include verbatim audio or
video recordings, and provides that the
interview will be recorded and a
verbatim transcript of the interview
shall be included in the record. See 8
CFR 208.9(f)(2).
Eighth, this rule clarifies in 8 CFR
208.9(g)(2) that if a USCIS interpreter is
unavailable, USCIS will attribute any
resulting delay to USCIS for the
purposes of employment authorization
pursuant to 8 CFR 208.7. The rule
continues to provide that, for asylum
applications retained by USCIS for
further consideration, if the applicant is
unable to proceed effectively in English,
the asylum officer shall arrange for the
assistance of an interpreter in
conducting the Asylum Merits
interview. See 8 CFR 208.9(g)(2).
Ninth, although the NPRM proposed
to amend 8 CFR 208.10(a) to provide
that, for noncitizens whose cases are
retained by USCIS for further
consideration of their asylum
application after a positive credible fear
determination, failure of a noncitizen to
appear for an Asylum Merits interview
might result in the issuance of an order
of removal, no changes to 8 CFR
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208.10(a) are being made in this IFR.
Failure to appear may result in referral
of the noncitizen to section 240 removal
proceedings before an IJ as well as
dismissal of the asylum application. See
8 CFR 208.10(a).
Tenth, in 8 CFR 235.3(b)(2)(iii) and
(b)(4)(ii), this rule establishes the
regulatory authority for consideration
for parole of noncitizens in expedited
removal or in expedited removal with
pending credible fear determinations
consistent with the current regulation at
8 CFR 212.5(b).
Eleventh, the rule includes a technical
amendment to 8 CFR 212.5(b) to
incorporate a reference to 8 CFR
235.3(b).
Twelfth, in 8 CFR 235.3(c)(2), this
rule includes a technical amendment to
establish the regulatory authority for
consideration for parole of noncitizens
whose asylum applications are retained
by USCIS for further consideration
following a positive credible fear
determination consistent with the
current regulation at 8 CFR 212.5(b).
Thirteenth, the IFR includes edits to
8 CFR 208.14 and 8 CFR 1208.14 to
emphasize that asylum officers’
decisions on approval, denial, referral,
or dismissal of an asylum application
remain subject to review within USCIS,
and an edit to 8 CFR 208.14(c)(1) to
make clear that an asylum applicant
described in 8 CFR 208.14(c)(4)(ii)(A), if
not granted asylum, may first be placed
into expedited removal and receive a
positive credible fear screening before
being referred to an IJ.
2. Revisions to the Proposed DOJ
Regulations
In the fourteenth change from the
NPRM, this rule neither adopts the
NPRM’s proposal to create a new IJ
review process when USCIS does not
grant asylum nor requires the applicant
to affirmatively request such review.
Instead, this rule requires DHS to refer
noncitizens whose applications for
asylum are not granted to section 240
removal proceedings by issuing a Notice
to Appear (‘‘NTA’’). However, this rule
adds 8 CFR 1240.17 to DOJ’s
regulations, which will impose
streamlining measures to enable such
proceedings to be completed more
expeditiously than ordinary section 240
proceedings involving cases that
originate from the credible fear process.
The rules and procedures that apply
during all section 240 proceedings will
generally apply to cases governed by the
new 8 CFR 1240.17, but the rule’s
additional procedural requirements will
further ensure efficient adjudication
while preserving fairness.
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Fifteenth, this rule does not adopt the
NPRM’s proposed evidentiary
limitations, which would have required
the noncitizen to demonstrate that any
additional evidence or testimony to be
considered by the IJ was not duplicative
of that considered by the asylum officer
and was necessary to fully develop the
record. Instead, with the exception of
time limits, the long-standing
evidentiary standards for section 240
removal proceedings will apply as
provided in new 8 CFR 1240.17(g)(1).
To ensure expeditious adjudication, this
rule imposes deadlines for the
submission of evidence as specified in
new 8 CFR 1240.17(f). In general, new
8 CFR 1240.17(f)(2) requires the
respondent to submit any additional
documentary evidence by the time of
the status conference which, under new
8 CFR 1240.17(f)(1), is held 30 days, or
the next available date no later than 35
days, after the master calendar hearing
unless a continuance or a filing
extension is granted. Under new 8 CFR
1240.17(f)(3)(i), DHS must file any
documents 15 days prior to the merits
hearing or, if the IJ determines a merits
hearing is not warranted, 15 days
following the status conference. New 8
CFR 1240.17(f)(3)(ii) allows the
respondent to submit a supplemental
filing replying to DHS and identifying
any additional witnesses or
documentation 5 days prior to the
merits hearing or, if the IJ determines a
merits hearing is not warranted, 25 days
following the status conference. These
deadlines may be extended in
accordance with the continuances and
extension provisions in new 8 CFR
1240.17(h), and an IJ may otherwise
accept late-filed evidence pursuant to
new 8 CFR 1240.17(g)(2) under certain
circumstances, including if required to
do so under statute or the Constitution.
Sixteenth, the rule provides that
streamlined section 240 removal
proceedings for cases covered by the
new 8 CFR 1240.17, where the USCIS
Asylum Merits interview record is
transmitted to EOIR for review, will
generally be adjudicated under an
expedited timeline. The master calendar
hearing will occur 30 to 35 days after
DHS commences proceedings as
provided in new 8 CFR 1240.17(b) and
(f)(1). Any merits hearing will be held
60 days after the master calendar
hearing, or on the next available date no
later than 65 days after the master
calendar hearing, see 8 CFR
1240.17(f)(2), subject to continuance
and filing extension requests as outlined
in new 8 CFR 1240.17(h). This rule also
imposes time limits for an IJ to issue a
decision as provided in new 8 CFR
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1240.17(f)(5). To ensure expeditious
adjudication, this rule adopts the
NPRM’s requirement that USCIS must
file the complete record of proceedings
for the Asylum Merits interview,
including the transcript and decision,
with the immigration court and serve it
on the respondent pursuant to new 8
CFR 1240.17(c). Additionally, as in the
NPRM, this rule does not require the
respondent to complete and file a new
asylum application, but instead
provides that the record of the positive
credible determination shall be treated
as satisfying the application filing
requirements subject to any
supplementation or amendment, and
shall further be deemed to satisfy EOIR’s
application filing requirements for any
spouse or child included in the cases
referred by USCIS and who has not
separately filed an asylum application
that was adjudicated by USCIS, as
provided in new 8 CFR 1208.3(a)(2). See
8 CFR 1240.17(e).
Seventeenth, to prepare cases for
expeditious adjudication, this rule
requires IJs to hold status conferences to
take place 30 days after the master
calendar hearing, or if a hearing cannot
be held on that date, on the next
available date no later than 35 days after
the master calendar hearing, as outlined
in new 8 CFR 1240.17(f)(2). This rule
requires both parties to participate at the
status conference, although the level of
participation required by the respondent
depends on whether the respondent has
legal representation. At a minimum, as
required by new 8 CFR
1240.17(f)(2)(i)(A), if the respondent
will contest removal or seek any
protection(s) for which the asylum
officer did not determine the respondent
eligible, the respondent shall indicate
whether the respondent intends to
testify, present any witnesses, or offer
additional documentation. If a
respondent thereafter obtains legal
representation, nothing in the IFR
prohibits respondent’s counsel from
supplementing statements or
submissions made by the respondent
during the status conference so long as
there is no delay to the merits hearing
or a filing deadline or, if the case will
be delayed, the respondent satisfies the
IFR’s provisions governing continuances
and filing extensions. Under new 8 CFR
1240.17(f)(2)(ii) and (f)(3), if DHS will
participate in the case, DHS shall, at the
status conference or in a written
statement filed no later than 15 days
prior to the scheduled merits hearing (or
if the IJ determines that no such hearing
is warranted, no later than 15 days
following the status conference), set
forth its position on the respondent’s
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application and identify contested
issues of law or fact, among other
things. Where DHS has elected to
participate in the case but does not
timely provide its position as required
under paragraph (f)(2)(ii), the IJ has
authority pursuant to new 8 CFR
1240.17(f)(3)(i) to deem claims or
arguments previously advanced by the
respondent unopposed, subject to
certain exceptions. The purpose of the
status conference and these procedural
requirements is to identify and narrow
the issues and ready the case for a
merits hearing.
Eighteenth, under new 8 CFR
1240.17(f)(2)(i)(B), a respondent may
choose to concede removability and not
seek asylum, in which case the IJ will
issue an order of removal and deny
asylum, but the IJ shall, with a limited
exception, give effect to a determination
by an asylum officer that the respondent
is eligible for statutory withholding of
removal or protection under the CAT.
DHS may not appeal a grant of statutory
withholding of removal or protection
under the CAT in this context to the BIA
except to argue that the IJ should have
denied the application(s) based on
certain evidence, as provided in new 8
CFR 1240.17(i)(2).
Nineteenth, new 8 CFR 1240.17(h)
establishes standards for continuances
during these streamlined section 240
removal proceedings. The rule adopts a
‘‘good cause’’ standard for respondentrequested continuances or filing
extensions that would delay any merits
hearing up to certain limits as detailed
in new 8 CFR 1240.17(h)(2)(i). Any such
continuance or extension generally shall
not exceed 10 days. When the
respondent has received continuances
or filing extensions that cause a merits
hearing to occur more than 90 days after
the master calendar hearing, the rule
requires the respondent to meet a
heightened standard for further
continuances or extensions as provided
in new 8 CFR 1240.17(h)(2)(ii). Pursuant
to new 8 CFR 1240.17(h)(2)(iii), any
further continuances or extensions
requested by the respondent that would
cause a merits hearing to occur more
than 135 days after the master calendar
hearing may be granted only if the
respondent demonstrates that failure to
grant the continuance or extension
would be contrary to statute or the
Constitution. DHS may receive
continuances or extensions based on
significant Government need, as
outlined in new 8 CFR 1240.17(h)(3),
which will not count against the limits
on respondent-requested continuances.
Further, as provided in new 8 CFR
1240.17(h)(2)(iv) and (h)(4), any delay
due to exigent circumstances shall not
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18083
count toward the limits on continuances
or extensions.
Twentieth, new 8 CFR 1240.17(f)(4)(i)
and (ii) provide that in certain
circumstances the IJ may decide the
respondent’s application without
holding a merits hearing, including
where neither party has elected to
provide testimony and DHS has
declined to cross-examine the
respondent or where the IJ intends to
grant the application and DHS has not
elected to examine the respondent or
present evidence or witnesses. Under
these provisions, the IJ shall still hold
a hearing if the IJ decides that a hearing
is necessary to fulfill the IJ’s duty to
fully develop the record.
Twenty-first, new 8 CFR 1240.17(i)(2)
provides that, where the asylum officer
does not grant asylum but determines
the respondent is eligible for statutory
withholding of removal or CAT relief,
and where the IJ subsequently denies
asylum and issues a removal order, the
IJ shall generally give effect to the
asylum officer’s determination(s). In
such circumstances, the IJ shall issue a
removal order, but the IJ shall give effect
to the asylum officer’s determination by
granting statutory withholding of
removal or protection under the CAT
unless DHS presents evidence or
testimony that specifically pertains to
the respondent, that was not in the
record of proceedings for the USCIS
Asylum Merits interview, and that
demonstrates that the respondent is not
eligible for the protection in question.
Twenty-second, this rule sets forth
certain exceptions from the procedures
and timelines summarized above. Under
new 8 CFR 1240.17(k), such exceptions
include the following circumstances:
The respondent was under the age of 18
on the date that the NTA was issued and
is not in consolidated removal
proceedings with an adult family
member; the respondent has produced
evidence demonstrating prima facie
eligibility for relief or protection other
than asylum, statutory withholding of
removal, voluntary departure, or CAT
relief and the respondent is seeking to
apply for, or has applied for, such relief
or protection; the respondent has
produced evidence supporting a prima
facie showing that the respondent is not
subject to removal, and the question of
removability cannot be resolved
simultaneously with the adjudication of
the applications for asylum and related
protection; the IJ finds the respondent
subject to removal to a country other
than the country or countries in which
the respondent claimed a fear of
persecution, torture, or both before the
asylum officer and the respondent
claims a fear of persecution, torture, or
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both in that alternative country or
countries; the case is on remand or has
been reopened following the IJ’s order;
or the respondent exhibits indicia of
mental incompetency.
Finally, DOJ is making technical edits
in 8 CFR 1003.42 to conform with
changes to DHS regulations proposed in
the NPRM and adopted in this rule
related to the credible fear screening
process in new 8 CFR 208.30(e).
D. Provisions of the IFR
The Departments carefully considered
the 5,235 public comments received,
and this IFR generally adopts the
framework proposed in the NPRM with
certain modifications as explained in
this rule. This rule also relies on the
justifications articulated in the NPRM,
except as reflected in this preamble.
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1. Credible Fear Screening Process
The Departments are generally
returning to the regulatory framework
governing the credible fear screening
process in place before various
regulatory changes were made from the
end of 2018 through the end of 2020,
which currently are not in effect.4 As
4 On November 9, 2018, the Departments issued
an IFR that barred noncitizens who entered the
United States in contravention of a covered
presidential proclamation or order from eligibility
for asylum, required that they receive a negative
credible fear finding on their asylum claims, and
required that their statutory withholding and CAT
claims be considered under the higher reasonable
fear screening standard. See Aliens Subject to a Bar
on Entry Under Certain Presidential Proclamations;
Procedures for Protection Claims, 83 FR 55934,
55939, 55943 (Nov. 9, 2018) (‘‘Presidential
Proclamation Bar IFR’’). A month later, the U.S.
District Court for the Northern District of California
preliminarily enjoined the Departments from
implementing the IFR, E. Bay Sanctuary Covenant
v. Trump, 354 F. Supp. 3d 1094, 1121 (N.D. Cal.
2018), and the Ninth Circuit affirmed, E. Bay
Sanctuary Covenant v. Biden, 993 F.3d 640, 680
(9th Cir. 2021).
On July 16, 2019, the Departments published
another IFR, entitled ‘‘Asylum Eligibility and
Procedural Modifications,’’ 84 FR 33829 (July 16,
2019) (‘‘Third Country Transit (TCT) Bar IFR’’),
which generally barred noncitizens from asylum
eligibility if they entered or attempted to enter the
United States across the Southwest border after
failing to apply for protection from persecution or
torture while in any one of the third countries
through which they transited, required a negative
credible fear finding for such noncitizens’ asylum
claims, and required their withholding and CAT
claims be considered under the higher reasonable
fear screening standard. Id. at 33837–38. The U.S.
District Court for the District of Columbia vacated
the TCT Bar IFR. Capital Area Immigrants’ Rights
Coal. v. Trump, 471 F. Supp. 3d 25, 45–57 (D.D.C.
2020). The Departments issued a final rule on
December 17, 2020, entitled ‘‘Asylum Eligibility
and Procedural Modifications,’’ 85 FR 82260 (Dec.
17, 2020) (‘‘TCT Bar rule’’), which again attempted
to bar from asylum eligibility those noncitizens who
transited through a third country before arriving at
the border. The U.S. District Court for the Northern
District of California subsequently issued a
preliminary injunction against implementation of
the TCT Bar rule, which remains in place as of this
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provided in this IFR, DHS is amending
8 CFR 208.30(b) to return to providing
that noncitizens subject to expedited
removal who indicate an intention to
apply for asylum, or who express a fear
of persecution or torture, or a fear of
return to the noncitizen’s country, shall
be screened by a USCIS asylum officer
for a credible fear of persecution or
torture (rather than a credible fear of
persecution, reasonable possibility of
persecution, or reasonable possibility of
torture). All references in 8 CFR 208.30
and 8 CFR 235.6 to a ‘‘credible fear of
persecution, reasonable possibility of
persecution, or a reasonable possibility
of torture’’ are replaced with ‘‘credible
fear of persecution or torture’’ or
‘‘credible fear.’’
DHS is further amending 8 CFR
208.30(b) to provide that the asylum
officer to whom such a noncitizen is
referred for a credible fear screening
may, in USCIS’s discretion and with
supervisory concurrence, refer the
noncitizen for proceedings under
section 240 of the Act without making
a credible fear determination.
DHS is amending 8 CFR 208.30(c) to
provide for the inclusion of a
noncitizen’s concurrently arriving
spouse or child in the noncitizen’s
positive credible fear evaluation and
determination, unless the noncitizen
declines such inclusion. Additionally,
DHS is amending 8 CFR 208.30(c) to
provide asylum officers with the
discretion to include a noncitizen’s
other concurrently arriving family
members in the noncitizen’s positive
credible fear evaluation and
determination for purposes of family
unity.
writing. E. Bay Sanctuary Covenant v. Barr, 519 F.
Supp. 3d 663, 668 (N.D. Cal. Feb. 2021).
Around the same time that the Departments
issued the final TCT Bar rule, they also issued the
final rule entitled ‘‘Procedures for Asylum and
Withholding of Removal; Credible Fear and
Reasonable Fear Review,’’ 85 FR 80274 (Dec. 11,
2020) (‘‘Global Asylum rule’’). That rule revised the
credible fear screening process to require that all
the mandatory bars to asylum and withholding be
considered during the credible fear screening
process and established a new screening standard
for withholding of removal and CAT protection. On
January 8, 2021, the U.S. District Court for the
Northern District of California preliminarily
enjoined the Departments from implementing the
Global Asylum rule. Pangea Legal Servs. v. DHS,
512 F. Supp. 3d 966, 977 (N.D. Cal. 2021) (‘‘Pangea
II’’). That preliminary injunction remains in place
as of this writing.
Finally, the Departments also published a final
rule entitled ‘‘Security Bars and Processing,’’ 85 FR
84160 (Dec. 23, 2020) (‘‘Security Bars rule’’), which
added an additional bar to asylum and withholding
that would be applied to the credible fear screening
process. The Departments have delayed the
Security Bars rule’s effective date to December 31,
2022, as the Departments consider possible action
to rescind or revise the rule. See Security Bars and
Processing; Delay of Effective Date, 86 FR 73615
(Dec. 28, 2021).
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DHS is amending 8 CFR 208.30(e) to
return to defining ‘‘credible fear of
persecution’’ as ‘‘a significant
possibility, taking into account the
credibility of the statements made by
the [noncitizen] in support of the
[noncitizen’s] claim and such other facts
as are known to the [asylum] officer,
that the [noncitizen] can establish
eligibility for asylum under section 208
of the Act or for withholding of removal
under section 241(b)(3) of the Act.’’ DHS
is further amending 8 CFR 208.30(e) to
return to defining ‘‘credible fear of
torture’’ as ‘‘a significant possibility that
the [noncitizen] is eligible for
withholding of removal or deferral of
removal under the Convention Against
Torture, pursuant to [8 CFR] 208.16 or
[ ] 208.17.’’
Additionally, as provided in the
NPRM, DHS is amending 8 CFR
208.30(e)(5) to return to the existing and
two-decade-long practice of not
applying at the credible fear screening
the mandatory bars to applying for, or
being granted, asylum that are contained
in sections 208(a)(2)(B)–(D) and (b)(2) of
the Act, including any bars established
by regulation under section 208(b)(2)(C)
of the Act, or bars to eligibility for
statutory withholding of removal, with
limited exceptions. DHS is maintaining
the regulations related to the threshold
screening under the safe third country
agreement with Canada in 8 CFR
208.30(e)(6), but making technical edits
to change ‘‘credible fear of persecution,
reasonable possibility of persecution, or
reasonable possibility of torture’’ to
‘‘credible fear of persecution or torture’’
to align the terminology with the rest of
this IFR. DHS will continue to require
supervisory review of all credible fear
determinations before they can become
final. See 8 CFR 208.30(e)(8).
Consistent with the NPRM, this IFR
amends 8 CFR 208.30(g) to return to
providing that once an asylum officer
has made a negative credible fear
determination, if a noncitizen refuses or
fails to either request or decline IJ
review, such refusal or failure to make
an indication will be considered a
request for IJ review. In those instances,
the noncitizen will be served with a
Form I–863, Notice of Referral to
Immigration Judge. If, upon review of an
asylum officer’s negative credible fear
determination, the IJ finds the
noncitizen possesses a credible fear of
persecution or torture, the IJ shall vacate
the Form I–860, Notice and Order of
Expedited Removal, and remand the
case to DHS for further consideration of
the application for asylum.
Alternatively, DHS may commence
section 240 removal proceedings, during
which the noncitizen may file an
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application for asylum and withholding
of removal. If the IJ concurs with the
negative credible fear determination,
DHS can execute the individual’s
expedited removal order, promptly
removing the individual from the
United States.
In comparison to the NPRM, in this
IFR, DHS is amending 8 CFR 208.30(g)
to provide that USCIS may, in its
discretion, reconsider a negative
credible fear determination with which
an IJ has concurred, provided such
reconsideration is requested by the
noncitizen or initiated by USCIS no
more than 7 days after the concurrence
by the IJ, or prior to the noncitizen’s
removal, whichever date comes first,
and further provided that no previous
request for consideration has already
been made.5 There is no change for
noncitizens who do not elect to have
their determination reviewed by an IJ.
Any reconsideration request made prior
to review by an IJ will be treated as an
election for review by an IJ. See 8 CFR
208.30(g)(1).
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2. Applications for Asylum
Under section 235(b)(1)(B)(ii) of the
Act, noncitizens who receive a positive
credible fear determination from a
USCIS asylum officer are referred for
‘‘further consideration of the application
for asylum.’’ As provided in the NPRM,
this rule establishes a new process by
which such ‘‘further consideration’’ may
occur, wherein a noncitizen will have
their asylum claim adjudicated
following an Asylum Merits interview
before a USCIS asylum officer in the
first instance, rather than by an IJ in
section 240 removal proceedings. See 8
CFR 208.30(f).
In issuing both the NPRM and this
IFR, the Departments concluded that the
expedited removal process presented an
opportunity for establishing a more
efficient process for making protection
determinations for those coming to our
borders. The credible fear interview
process creates a unique opportunity for
the protection claim to be presented to
a trained asylum officer and
documented; that documentation can
then initiate and facilitate a merits
adjudication. Unlike those noncitizens
who are placed directly into section 240
removal proceedings after apprehension
at the border, noncitizens placed instead
into expedited removal and who
subsequently make a fear claim are
referred to USCIS for an interview under
oath. Rather than move noncitizens who
5 Reconsideration requests made by noncitizens
of negative credible fear determinations already
affirmed by an IJ are colloquially known as requests
for reconsideration (‘‘RFRs’’).
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receive positive credible fear
determinations directly into section 240
proceedings—which is what happens to
noncitizens apprehended at the border
who are not placed into expedited
removal—the Departments have
determined that it is appropriate to
establish a more efficient process that
includes the involvement of USCIS and
the creation of a documented record of
the noncitizen’s protection claim during
the credible fear screening process. By
treating the record of the credible fear
determination as an asylum application
and by issuing a follow-up interview
notice when the credible fear
determination is served, USCIS will be
able to promptly schedule and conduct
an interview on the merits of the
noncitizen’s protection claims and issue
a final decision. For those noncitizens
not granted asylum by USCIS, the IFR’s
process will also create a more complete
record of the principal applicant’s
protection claims, as well as those of
their spouse or child included on the
application and interviewed during the
Asylum Merits interview. EOIR can then
use the rationale of the USCIS
determination in a streamlined section
240 removal proceeding. Consistent
with the NPRM, DHS is amending 8
CFR 208.3 to address application and
filing requirements for noncitizens over
whom USCIS retains jurisdiction for
further consideration of asylum
applications pursuant to the Asylum
Merits process established by this rule.
DHS is amending 8 CFR 208.3(a) to
provide, in new 8 CFR 208.3(a)(2), that
the written record of a positive credible
fear finding satisfies the asylum
application filing requirements in 8 CFR
208.3(a)(1). DHS is further amending 8
CFR 208.3(a) to provide, in new 8 CFR
208.3(a)(1) and (2), that noncitizens
placed in the Asylum Merits process are
subject neither to the general
requirement in 8 CFR 208.3(a)(1) that
asylum applicants file a Form I–589,
Application for Asylum and for
Withholding of Removal, nor to the
benefit request submission requirements
of 8 CFR 103.2.
Consistent with the NPRM, DHS is
also amending 8 CFR 208.3(a) to provide
that the written record of the positive
credible fear determination shall be
considered a complete asylum
application for purposes of the one-year
filing deadline at 8 CFR 208.4(a),
requests for employment authorization
based on a pending application for
asylum under 8 CFR 208.7, and the
completeness requirement at 8 CFR
208.9(a); shall not be subject to the
requirements of 8 CFR 103.2; and shall
be subject to the conditions and
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consequences in 8 CFR 208.3(c) upon
signature at the Asylum Merits
interview, as described in new 8 CFR
208.3(a)(2). DHS is amending 8 CFR
208.3(c)(3) to provide that receipt of a
properly filed asylum application under
8 CFR 208.3(a) commences the period
after which a noncitizen may file an
application for employment
authorization based on a pending
asylum application. DHS is further
amending 8 CFR 208.3(a) to provide, in
new 8 CFR 208.3(a)(2), that the date that
the positive credible fear determination
is served on the noncitizen shall be
considered the date of filing and receipt.
DHS is further amending 8 CFR 208.3(a)
to provide, in new 8 CFR 208.3(a)(2),
that biometrics captured during
expedited removal for the principal
applicant and any dependents may be
used to verify identity and for criminal
and other background checks for
purposes of an asylum application
under the jurisdiction of USCIS and any
subsequent immigration benefit.
DHS is amending current 8 CFR
208.4(c), rather than 8 CFR 208.3(a)(2)
as provided in the NPRM, and
redesignating it as 8 CFR 208.4(b), with
certain modifications as compared to
the NPRM, to provide the noncitizen the
opportunity to subsequently amend or
correct the biographic or credible fear
information in the Form I–870, Record
of Determination/Credible Fear
Worksheet, or supplement the
information collected during the process
that concluded with a positive credible
fear determination, within a specified
time frame (7 or 10 days, depending on
the method of submission) prior to the
scheduled Asylum Merits interview.
DHS is further amending current 8 CFR
208.4(c) to provide, in new 8 CFR
208.4(b)(2), that, finding good cause in
an exercise of USCIS’s discretion, the
asylum officer may consider
amendments or supplements submitted
after the 7- or 10-day submission
deadline or may grant the applicant an
extension of time during which the
applicant may submit additional
evidence, subject to the limitation on
extensions described in 8 CFR
208.9(e)(2). In the absence of exigent
circumstances, an asylum officer shall
not grant any extensions for submission
of additional evidence that would
prevent an Asylum Merits decision from
being issued to the applicant within 60
days of service of the positive credible
fear determination, as described in new
8 CFR 208.9(e)(2).
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3. Proceedings for Further Consideration
of the Application for Asylum by USCIS
Through Asylum Merits Interview for
Noncitizens With Credible Fear
Under the framework in place prior to
this rulemaking, if an asylum officer
determined that a noncitizen subject to
expedited removal had a credible fear of
persecution or torture, DHS placed the
noncitizen before an immigration court
for adjudication of the noncitizen’s
claims by initiating section 240 removal
proceedings. Section 235(b)(1)(B)(ii) of
the INA, 8 U.S.C. 1225(b)(1)(B)(ii),
however, authorizes a procedure for
‘‘further consideration of [an]
application for asylum’’ that may
commence outside of section 240
removal proceedings.
Consistent with the NPRM, DHS is
amending 8 CFR 208.2(a) to provide that
USCIS may take initial jurisdiction to
further consider the application for
asylum, in an Asylum Merits interview,
of a noncitizen, other than a stowaway
and a noncitizen physically present in
or arriving in the Commonwealth of the
Northern Mariana Islands (‘‘CNMI’’),
found to have a credible fear of
persecution or torture. DHS is amending
8 CFR 208.9(b) to provide that the
purpose of the Asylum Merits interview
shall be to elicit all relevant and useful
information bearing on the applicant’s
eligibility for asylum. In comparison to
the NPRM, DHS is further amending 8
CFR 208.9(b) to provide that, in the case
of a noncitizen whose case is retained
by USCIS for an Asylum Merits
interview, an asylum officer will also
elicit all relevant and useful information
bearing on the applicant’s eligibility for
statutory withholding of removal and
CAT protection. This rule further
provides in 8 CFR 208.16(a) that, in the
case of a noncitizen whose case is
retained by or referred to USCIS for an
Asylum Merits interview and whose
asylum application is not approved, the
asylum officer will determine whether
the noncitizen is eligible for statutory
withholding of removal under 8 CFR
208.16(b) or withholding or deferral of
removal pursuant to the CAT under 8
CFR 208.16(c).
In comparison to the NPRM, DHS is
amending 8 CFR 208.9(a) to provide that
USCIS shall not schedule an Asylum
Merits interview for further
consideration of an asylum application
following a positive credible fear
determination fewer than 21 days after
the noncitizen has been served a record
of the positive credible fear
determination. The asylum officer shall
conduct the interview within 45 days of
the date that the positive credible fear
determination is served on the
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noncitizen subject to the need to
reschedule an interview due to exigent
circumstances, as provided in new 8
CFR 208.9(a)(1). Consistent with the
NPRM, DHS is amending 8 CFR 208.9
to specify the procedures for such
interviews before an asylum officer.
With limited exception, these
amendments generally provide that the
same procedures applicable to
affirmative asylum interviews will also
apply to interviews under this rule,
such as the right to have counsel
present, 8 CFR 208.9(b), at no expense
to the Government.
In this IFR, DHS also includes
language from existing regulations in 8
CFR 208.9(d) that was inadvertently not
included in the NPRM’s proposed
regulatory text related to the USCIS’s
discretion to limit the length of a
statement or comment and require its
submission in writing. As was stated in
the NPRM, DHS is amending 8 CFR
208.9(f) to provide, in new 8 CFR
208.9(f)(2), that for Asylum Merits
interviews, a verbatim transcript of the
interview will be included in the
referral package to the immigration
judge. However, DHS is removing the
language proposed in the NPRM
regarding the record also including a
verbatim audio or video recording in
new 8 CFR 208.9(f)(2). DHS believes
that recording the interview in order to
produce a verbatim transcript that will
be included in the record is sufficient to
meet the aims of the rule.6
DHS is amending 8 CFR 208.9(g) to
provide, in new 8 CFR 208.9(g)(2), that
if a noncitizen is unable to proceed
effectively in English at an Asylum
Merits interview, the asylum officer
shall arrange for the assistance of an
interpreter in conducting the interview.
In comparison to the NPRM, this rule
provides in new 8 CFR 208.9(g)(2) that
if a USCIS interpreter is unavailable,
USCIS will attribute any resulting delay
to USCIS for purposes eligibility for
employment authorization.
In comparison to the revisions
proposed in the NPRM, this IFR leaves
existing 8 CFR 208.10 unchanged—thus
providing that a noncitizen’s failure to
appear for an Asylum Merits interview
may result in the referral of the
application for consideration in section
240 removal proceedings before an IJ (as
opposed to the issuance of an order of
removal). See 8 CFR 208.10(a)(1).
In 8 CFR 208.14(b), USCIS continues
to implement its authority to grant
asylum in any case within its
6 The Departments may consider making available
a process by which parties to EOIR proceedings
under 8 CFR 1240.17 will be able to timely review,
upon request, the recording of the USCIS Asylum
Merits interview.
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jurisdiction. In comparison to the
NPRM, DHS is amending 8 CFR
208.14(c) and 208.16(a) and (c) to
provide that if an asylum officer
conducting an Asylum Merits interview
for further consideration of an asylum
application after a positive credible fear
determination does not grant asylum to
an applicant, the asylum officer will
determine whether the applicant is
eligible for statutory withholding of
removal or CAT protection. The asylum
officer will not issue an order of
removal as proposed in the NPRM, nor
issue a final decision on an applicant’s
request for statutory withholding of
removal or CAT protection. Instead, the
asylum officer will refer the
application—together with the
appropriate charging document and
written findings of, and the
determination on, eligibility for
statutory withholding of removal or
CAT protection—to an IJ for
adjudication in streamlined section 240
removal proceedings. See 8 CFR
208.14(c); 8 CFR 208.16(a), (b), (c)(4); 8
CFR 1208.14(c). The referral of the
asylum application of a principal
applicant to the IJ will also include any
dependent of that principal applicant,
as appropriate. See 8 CFR 208.3(a)(2),
208.14(c)(1). If the asylum application
includes a dependent who has not filed
a separate application and the principal
applicant is determined to not to be
eligible for asylum, the asylum officer
will elicit sufficient information to
determine whether there is a significant
possibility that the dependent has
experienced or fears harm that would be
an independent basis for protection
prior to referring the family to the IJ for
a hearing. See 8 CFR 208.9(b), (i). If a
spouse or child who was included in
the principal’s request for asylum does
not separately file an asylum
application that is adjudicated by
USCIS, the principal’s asylum
application will be deemed by EOIR to
satisfy EOIR’s application filing
requirements for the spouse or child as
principal applicants. See 8 CFR
1208.3(a)(2).
4. Streamlined Section 240 Removal
Proceedings Before the Immigration
Judge
DOJ is adding 8 CFR 1240.17, which
shall govern section 240 removal
proceedings for respondents whose
cases originate from the credible fear
process and who have not been granted
asylum after an initial adjudication by
an asylum officer, pursuant to 8 CFR
208.14(c)(1). The general rules and
procedures that govern all other removal
proceedings under section 240 apply to
removal proceedings covered by this
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rule with certain exceptions designed to
streamline the proceedings and account
for the unique procedural posture of
these cases.
Under new 8 CFR 1240.17(b), USCIS
will issue an NTA to any noncitizen not
granted asylum by USCIS after an
Asylum Merits interview held pursuant
to 8 CFR 208.2(a), with the master
calendar hearing in these streamlined
section 240 proceedings scheduled for
30 to 35 days after service of the NTA.
Under new 8 CFR 1240.17(e), the record
of the proceedings for the interview
before the asylum officer and the
asylum officer’s decision shall be
admitted as evidence and considered by
the IJ. Moreover, this rule provides that
a respondent is not required to
separately prepare and file a Form I–
589, Application for Asylum and for
Withholding of Removal, and that the
record of the positive credible fear
determination satisfies the application
filing requirements for the principal
applicant as well as for any dependent
included in the referral and who did not
separately file an asylum application
that was adjudicated by USCIS. See 8
CFR 208.3(a), 1208.3(a), 1240.17(e). That
is, any spouse or child included in the
referral will be deemed to have satisfied
EOIR’s application filing requirements
as a principal applicant.
The Departments have determined
that it is appropriate for cases under this
rule to proceed on a streamlined time
frame before the IJ as claims will have
been significantly developed and
analyzed by USCIS before the IJ
proceedings start, the record will be
available for review by the IJ, and
respondents will not be required to
prepare and file an asylum application.
Accordingly, the rule establishes
timelines for certain hearings to occur as
provided in new 8 CFR 1240.17(f)(1)–
(4). As set forth in new 8 CFR
1240.17(h), the rule imposes limitations
on the length of continuances and filing
extensions that can be granted before a
respondent must satisfy a heightened
standard to receive additional
continuances or filing extensions that
have the effect of further delaying a
hearing required under the rule. The
rule also imposes certain procedural
requirements and gives IJs additional
tools designed to narrow the issues and
ready the case for a merits hearing, if
necessary. Under new 8 CFR
1240.17(f)(1) and (2), the rule requires
the IJ to hold a status conference 30
days after the master calendar hearing
or, if a status conference cannot be held
on that date, on the next available date
no later than 35 days after the master
calendar hearing, and imposes
obligations on both parties to participate
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at the conference, although the level of
participation required by the respondent
depends on whether the respondent has
legal representation. If DHS indicates
that it will participate in the case, DHS
has an obligation under new 8 CFR
1240.17(f)(2)(ii) and (f)(3) to set forth its
position on the respondent’s application
and identify contested issues of law or
fact (including which elements, if any,
of the respondent’s claim(s) it is
challenging), among other things. In
certain circumstances, where DHS does
not respond in a timely manner to the
respondent’s claims, the IJ has authority
to deem those claims unopposed, as
provided in new 8 CFR 1240.17(f)(3)(i).
However, DHS may respond at the
merits hearing to any arguments or
claimed bases for asylum first advanced
by the respondent after the status
conference. See 8 CFR 1240.17(f)(3)(i).
Where DHS has indicated that it will
not participate in a merits hearing, the
rule allows DHS, in certain, limited
instances, to retract this position prior
to the merits hearing, as provided in
new 8 CFR 1240.17(f)(2)(ii). The rule
allows IJs to hold additional status
conferences if the case is not ready for
a merits hearing, as provided in new 8
CFR 1240.17(f)(2).
Under new 8 CFR 1240.17(f)(4), the IJ
may forgo a merits hearing and decide
the respondent’s application on the
documentary record (1) if neither party
has requested to present testimony and
DHS has indicated that it waives crossexamination, or (2) if the noncitizen has
timely requested to present testimony,
DHS has indicated that it waives crossexamination and does not intend to
present testimony or produce evidence,
and the IJ concludes that the application
can be granted without further
testimony. The rule preserves the IJ’s
ability to hold a merits hearing if the IJ
decides that it is necessary to fulfill the
IJ’s duty to fully develop the record.
If the case cannot be decided on the
documentary record, the new 8 CFR
1240.17(f)(2) requires the IJ to hold a
merits hearing 60 days after the master
calendar hearing or, if a hearing cannot
be held on that date, on the next
available date no later than 65 days after
the master calendar hearing. At the
merits hearing, the respondent may
testify fully and offer any additional
evidence that has been submitted in
compliance with the time limits on
evidentiary filings under the normal
evidentiary standards that apply to 240
removal proceedings as provided in new
8 CFR 1240.17(f)(4)(iii)(A) and (g)(1). If
the proceedings cannot be completed at
the scheduled merits hearing, the IJ
shall schedule any continued merits
hearing as soon as possible but no later
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18087
than 30 days after the initial merits
hearing except in case of a continuance
or extension as provided in 8 CFR
1240.17(f)(4)(iii)(B). Under new 8 CFR
1240.17(f)(5), the IJ is required,
wherever practicable, to issue an oral
decision on the date of the final merits
hearing or, if the IJ concludes that no
hearing is necessary, no later than 30
days after the status conference. Where
issuance of an oral decision on such
date is not practicable, the IJ must issue
an oral or written decision as soon as
practicable, and in no case more than 45
days after the applicable date described
in the preceding sentence. See 8 CFR
1240.17(f)(5).
Under new 8 CFR 1240.17(i)(2), if the
IJ denies asylum but an asylum officer
has determined that the respondent is
eligible for statutory withholding of
removal or protection under the CAT
with respect to the proposed country of
removal, then the IJ shall enter an order
of removal but give effect to the asylum
officer’s eligibility determination by
granting the applicable form of
protection, unless DHS demonstrates
that evidence or testimony that
specifically pertains to the respondent
and that was not in the record of
proceedings for the USCIS Asylum
Merits interview establishes that the
respondent is not eligible for such
protection. Under new 8 CFR
1240.17(f)(2)(i)(B), the rule similarly
provides that where an asylum officer
has declined to grant asylum but has
determined that the respondent is
eligible for statutory withholding of
removal or protection under the CAT
with respect to the proposed country of
removal, the respondent may elect not
to contest removal and not pursue a
claim for asylum before the IJ but still
receive statutory withholding of
removal or CAT protection. In such a
case, the rule provides that the IJ shall
enter an order of removal but give effect
to the asylum officer’s eligibility
determination by granting the
applicable form of protection, unless
DHS makes a prima facie showing
through evidence that specifically
pertains to the respondent and that was
not in the record of proceedings for the
USCIS Asylum Merits interview that the
respondent is not eligible for such
protection. Similarly, new 8 CFR
1240.17(d) further provides that an IJ
must give effect to an asylum officer’s
determination that a noncitizen is
eligible for statutory withholding of
removal or protection under the CAT,
even if the noncitizen is ordered
removed in absentia, unless DHS makes
a prima facie showing through evidence
that specifically pertains to the
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respondent and that was not in the
record of proceedings for the USCIS
Asylum Merits interview that the
respondent is not eligible for such
protection. In addition, new 8 CFR
1240.17(l) makes clear that DHS may, in
keeping with existing regulations, seek
to terminate such protection.7
Finally, the rule specifically exempts
certain cases that cannot be expedited
under the circumstances from the
timelines and other expedited aspects of
the streamlined 240 proceedings. See 8
CFR 1240.17(k). Such exceptions
include the following circumstances:
The respondent was under the age of 18
on the date that the NTA was issued and
is not in consolidated removal
proceedings with an adult family
member, 8 CFR 1240.17(k)(1); the
respondent has produced evidence of
prima facie eligibility for relief or
protection other than asylum, statutory
withholding of removal, protection
under the CAT, and voluntary
departure, and the respondent is seeking
to apply for, or has applied for, such
relief or protection, 8 CFR
1240.17(k)(2); 8 the respondent has
produced evidence that supports a
prima facie showing that the respondent
is not removable and the IJ determines
that the issue of whether the respondent
is removable cannot be resolved
simultaneously with the adjudication of
the applications for asylum and related
protection, 8 CFR 1240.17(k)(3); the IJ
finds the respondent subject to removal
to a country other than the country or
countries in which the respondent
claimed a fear of persecution, torture, or
both before the asylum officer and the
respondent claims a fear of persecution,
torture, or both in that alternative
country or countries, 8 CFR
1240.17(k)(4); the case is on remand or
has been reopened following the IJ’s
order, 8 CFR 1240.17(k)(5); or the
respondent exhibits indicia of mental
incompetency, 8 CFR 1240.17(k)(6). The
provisions at 8 CFR 1240.17(f), (g), and
(h), which pertain to the schedule of
proceedings, to the consideration of
evidence and testimony, and to
continuances, adjournments, and filing
7 Nothing in this rule alters the existing regulatory
provisions governing termination of withholding or
deferral; these provisions apply to any noncitizen
whose removal has been withheld or deferred,
whether through the procedure established in this
rule or otherwise. See 8 CFR 208.17(d), 208.24(f),
1208.17(d), 1208.24(f).
8 The rule does not specify the particular type of
evidence that must be produced in order to
demonstrate prima facie eligibility for relief. Such
evidence could include testimonial evidence as
well as documentary evidence. The rule further
does not require that a completed application for
the relief at issue be filed with the immigration
court.
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extensions, will not apply in such cases.
The other provisions in 8 CFR 1240.17,
however, will apply.
5. Parole
DHS is amending 8 CFR
235.3(b)(2)(iii) to permit parole of
detained individuals whose
inadmissibility is being considered in
the expedited removal process, or who
have been ordered removed under the
expedited removal process, only on a
case-by-case basis for urgent
humanitarian reasons or significant
public benefit, which includes, as
interpreted in longstanding regulations,
see 8 CFR 212.5(b), circumstances in
which continued detention is not in the
public interest, provided that the
noncitizen presents neither a security
risk nor a risk of absconding. Similarly,
DHS is amending 8 CFR 235.3(b)(4)(ii)
to permit parole of detained individuals
pending a credible fear interview and
any review of an asylum officer’s
credible fear determination by an IJ only
on a case-by-case basis for urgent
humanitarian reasons or significant
public benefit, including if continued
detention is not in the public interest,
provided that the noncitizen presents
neither a security risk nor a risk of
absconding. This rule further finalizes,
as proposed, that such a grant of parole
would be for the limited purpose of
parole out of custody and cannot serve
as an independent basis for employment
authorization under 8 CFR
274a.12(c)(11). See 8 CFR
235.3(b)(2)(iii), (b)(4)(ii). The IFR also
includes a technical amendment to 8
CFR 212.5(b) to incorporate a reference
to 8 CFR 235.3(b). Parole is not
guaranteed but instead considered on a
case-by-case basis to determine whether
it is warranted as a matter of discretion;
DHS also may impose reasonable
conditions on parole such as periodic
reporting to U.S. Immigration and
Customs Enforcement (‘‘ICE’’). See INA
212(d)(5)(A), 8 U.S.C. 1182(d)(5)(A); 8
CFR 212.5(d).9
Additionally, DHS is including in this
rule a technical amendment to 8 CFR
235.3(c)(2) to provide that parole of
noncitizens with positive credible fear
determinations whose asylum
applications are retained by USCIS for
further consideration through the
Asylum Merits process is permissible
only on a case-by-case basis for urgent
humanitarian reasons or significant
public benefit, including if continued
detention is not in the public interest,
9 Noncitizens who are paroled are not considered
to be ‘‘admitted’’ to the United States. See INA
101(a)(13)(B), 212(d)(5)(A); 8 U.S.C. 1101(a)(13)(B),
1182(d)(5)(A).
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provided that the noncitizen presents
neither a security risk nor a risk of
absconding. This technical amendment
is necessary to clarify that the parole
authority pertaining to noncitizens
awaiting an Asylum Merits interview
with USCIS under this rule will be
consistent with 8 CFR 212.5, just as the
parole authority pertaining to detained
noncitizens subject to expedited
removal who are placed in section 240
removal proceedings is consistent with
8 CFR 212.5. As noted above, parole is
not guaranteed but instead considered
on a case-by-case basis to determine
whether it is warranted as a matter of
discretion.
E. Summary of Costs and Benefits
The primary individuals and entities
that this rule is expected to affect are:
(1) Noncitizens who are placed into
expedited removal and who receive a
credible fear screening; (2) the support
networks of asylum applicants who
receive a positive credible fear
determination; (3) USCIS; and (4) EOIR.
The expected impacts to these
individuals and entities and to others
are detailed in Section V.B of this
preamble. In brief, by reducing undue
delays in the asylum adjudication
system, and by providing a variety of
procedural safeguards, the rule protects
equity, human dignity, and fairness
given that individuals who are eligible
for asylum or other protection may
receive that protection more promptly,
while individuals who are ineligible
may more promptly be ordered
removed. In the Departments’ judgment,
these benefits—which are difficult or
impossible to quantify—along with the
benefits of the rule that are more
amenable to quantification, amply
justify the aggregate costs of the rule.
The rule’s impact on affected
noncitizens (and, in turn, on their
support networks) may vary
substantially from person to person
depending on, among other things,
whether the individual receives a
positive credible fear determination and
whether the individual’s asylum claim
is granted or not granted by USCIS. For
example, some individuals may benefit
more from an earlier grant of asylum
because they may be able to enter the
labor force sooner. And individuals who
establish credible fear may benefit from
cost savings associated with no longer
having to file a Form I–589, Application
for Asylum and for Withholding of
Removal.
The Departments have estimated the
human resource- and informationrelated expenditures required for USCIS
to implement this rule. These estimates
are developed along three population
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bounds to account for possible
variations in the number of credible fear
screenings in future years.
Implementation of the rule also is
expected to reduce EOIR’s workload,
allowing EOIR to focus efforts on other
priority work and to reduce the growth
of its substantial current backlog. That
expected reduction in workload would
result from (1) cases in which USCIS
grants asylum never reaching EOIR,
resulting in a potential 15 percent
reduction in EOIR’s caseload originating
from credible fear screening (assuming
historic grant rates), and (2) many of the
cases reaching EOIR being resolved with
less investment of immigration court
time and resources than they would
have required if referred directly to
EOIR in the first instance.
An important caveat to the
Departments’ estimates of the potential
costs and benefits associated with this
rule is that it will take time to fully
implement the rule, as the Departments
intend to take a phased approach to
implementing the rule.
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F. Effective Date
This IFR will be effective 60 days
from the date of publication in the
Federal Register.
This rule applies prospectively and
only to adults and families who are
placed in expedited removal
proceedings and indicate an intention to
apply for asylum, a fear of persecution
or torture, or a fear of return to their
home country, after the rule’s effective
date. The rule does not apply to
unaccompanied children, as they are
statutorily exempt from expedited
removal proceedings. See 8 U.S.C.
1232(a)(5)(D)(i) (providing that ‘‘any
unaccompanied alien child’’ whom DHS
seeks to remove ‘‘shall be . . . placed in
removal proceedings under section 240’’
of the INA); see also 6 U.S.C. 279(g)(2)
(defining ‘‘unaccompanied alien
child’’).10 The rule also does not apply
to individuals in the United States who
are not apprehended at or near the
border and subject to expedited
removal.11 Such individuals will
10 In lieu of being placed in section 240 removal
proceedings, unaccompanied children from
contiguous countries who meet special criteria may
be permitted to withdraw their applications for
admission and be voluntarily returned to their
country of nationality or country of last habitual
residence. See 8 U.S.C. 1232(a)(2).
11 The former Immigration and Naturalization
Service (‘‘INS’’) initially implemented expedited
removal processes only for certain noncitizens
arriving at ports of entry. In 2002, DHS, by
designation, expanded the application of expedited
removal to certain noncitizens who (1) entered the
United States by sea, either by boat or other means,
(2) were not admitted or paroled into the United
States, and (3) had not been continuously present
in the United States for at least 2 years. Notice
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continue to have their asylum claims
heard in section 240 removal
proceedings in the first instance, or
through an affirmative asylum
application under section 208 of the
INA, 8 U.S.C. 1158, if they have not yet
been placed in immigration
proceedings. The rule also does not
apply to (1) stowaways or (2)
noncitizens who are physically present
in or arriving in the CNMI who are
determined to have a credible fear. Such
individuals will continue to be referred
to asylum-and-withholding-only
proceedings before an IJ under 8 CFR
208.2(c).
III. Discussion of the IFR
The principal purpose of this IFR is
to simultaneously increase the
promptness, efficiency, and fairness of
the process by which noncitizens who
cross the border without appropriate
documentation are either removed or, if
eligible, granted protection. The IFR
accomplishes this purpose both by
instituting a new process for resolving
the cases of noncitizens who have been
found to have a credible fear of
persecution or torture and by facilitating
the use of expedited removal for more
of those who are eligible, and especially
for populations whose detention
presents particular challenges. When
individuals placed into the expedited
removal process make a fear claim, they
are referred to a USCIS asylum officer,
who interviews them to determine
whether they have a credible fear of
persecution or torture. See INA
235(b)(1)(A)(ii), 8 U.S.C.
1225(b)(1)(A)(ii); 8 CFR 208.30. Under
Designating Aliens Subject to Expedited Removal
Under Section 235(b)(1)(A)(iii) of the Immigration
and Nationality Act, 67 FR 68924 (Nov. 13, 2002).
In 2004, DHS published an immediately effective
notice in the Federal Register to expand the
application of expedited removal to certain
noncitizens encountered within 100 miles of the
border and to noncitizens who entered the United
States without inspection fewer than 14 days before
they were encountered. Designating Aliens for
Expedited Removal, 69 FR 48877 (Aug. 11, 2004).
In 2019, DHS expanded the process to the full
extent authorized by statute to reach certain
noncitizens, not covered by prior designations, who
entered the country without inspection less than
two years before being apprehended and who were
encountered anywhere in the United States.
Designating Aliens for Expedited Removal, 84 FR
35409 (July 23, 2019). President Biden has directed
DHS to consider whether to modify, revoke, or
rescind that 2019 expansion. Executive Order
14010, Creating a Comprehensive Regional
Framework To Address the Causes of Migration, To
Manage Migration Throughout North and Central
America, and To Provide Safe and Orderly
Processing of Asylum Seekers at the United States
Border, 86 FR 8267, 8270–71 (Feb. 2, 2021). On
March 21, 2022, DHS published a Federal Register
Notice rescinding the 2019 designation. See
Rescission of the Notice of July 23, 2019,
Designating Aliens for Expedited Removal, 87 FR
16022 (Mar. 21, 2022).
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procedures in place immediately prior
to the effective date of this IFR,
individuals who receive a positive
credible fear determination are referred
to an immigration court for section 240
removal proceedings, during which they
have the opportunity to apply for
asylum and other forms of relief or
protection from removal. See 8 CFR
208.30(f) (2018) (providing that if a
noncitizen, other than a stowaway, ‘‘is
found to have a credible fear of
persecution or torture, the asylum
officer will so inform the [noncitizen]
and issue an NTA, for full consideration
of the asylum and withholding of
removal claim in proceedings under
section 240 of the Act’’). As explained
in the NPRM, it may take years before
the individual’s protection claim is first
adjudicated by an IJ. This delay creates
additional stress and uncertainty for
those ultimately determined to merit
asylum and other forms of humanitarian
protection, as they are left in limbo as
to whether they might still be removed,
are unable to lawfully work until their
asylum application has been granted or
has remained pending for several
months, and are unable to petition for
qualified family members, some of
whom may still be at risk of harm.
Moreover, the ability to stay in the
United States for years waiting for an
initial decision may motivate
unauthorized border crossings by
individuals who otherwise would not
have sought to enter the United States
and who lack a meritorious protection
claim. Such additional entrants only
further increase the backlog and
lengthen the delays.
To respond to this problem, this rule
at 8 CFR 208.2(a)(1)(ii) and 208.9
provides USCIS the authority to
adjudicate in the first instance the
asylum claims of individuals who
receive a positive credible fear
determination, and further provides that
USCIS does so following a
nonadversarial interview by an asylum
officer. The rule also provides at 8 CFR
208.3(a)(2) that the record of a credible
fear interview will serve as an asylum
application for noncitizens whose cases
are retained by or referred back to
USCIS for adjudication after a positive
credible fear determination, thereby
allowing cases originating with a
credible fear screening to be adjudicated
substantially sooner. Both the
Departments and the noncitizen can
avoid the burden caused by delays
associated with otherwise requiring the
noncitizen to file a Form I–589,
Application for Asylum and for
Withholding of Removal. See Section
IV.D.4.a of this preamble. By
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authorizing USCIS to adjudicate in the
first instance the asylum claims of
individuals who receive a positive
credible fear determination and by
making it possible for this adjudication
to be made promptly and independently
of EOIR, the Departments predict that
the rule will also help to stem the rapid
growth of the EOIR caseload, described
in greater detail in the NPRM. See 86 FR
46937. As for the noncitizen, this
change reduces potential barriers to
protection for eligible applicants by
enabling asylum seekers to meet the
statutory requirement to apply for
asylum within one year of arrival,
avoiding the risk of filing delays, and
immediately beginning the waiting
period of work authorization eligibility.
See id. at 46916. Any spouse or child
who arrived with the principal asylum
applicant and is included as a
dependent on the principal applicant’s
positive credible fear determination may
make a separate claim for protection and
submit their own principal asylum
application to USCIS for consideration.
As noted in the NPRM, the current
system for processing protection claims
made by individuals encountered at or
near the border and who establish
credible fear was originally adopted in
1997. From 2018 through 2020,
however, several attempts were made to
change the credible fear screening
process. Many of these attempts have
been initially vacated or enjoined, and
the implementation of others has been
delayed pending consideration of
whether they should be revised or
rescinded.12 The Global Asylum rule,
which is enjoined, revised regulations to
provide that noncitizens with positive
credible fear determinations would be
placed in asylum-and-withholding-only
proceedings before an IJ. See 85 FR
80276. In the Global Asylum rule, the
Departments explained their view that
placing such noncitizens in asylum-andwithholding-only proceedings before an
IJ would ‘‘bring the proceedings in line
with the statutory objective that the
expedited removal process be
streamlined and efficient,’’ id., and later
noted that it would ‘‘lessen the strain on
the immigration courts by limiting the
focus of such proceedings and thereby
streamlining the process,’’ id. at 80286.
The Departments provided that these
asylum-and-withholding-only
proceedings would follow the same
rules of procedure that apply in section
240 proceedings and that a noncitizen
could appeal their case to the BIA and
Federal circuit courts, as necessary. See
id. at 80289. The Departments
12 See supra note 4 (discussing recent regulations
and their current status).
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acknowledged that IJs often adjudicate
multiple forms of relief in a single
removal proceeding, in addition to
asylum, statutory withholding of
removal, or CAT protection claims, and
stated that those additional issues
‘‘generally only serve to increase the
length of the proceedings’’ and that
‘‘there may be rare scenarios in which
[noncitizens] subject to expedited
removal are eligible for a form of relief
other than asylum.’’ Id. In the Global
Asylum rule, the Departments
concluded that placing noncitizens with
positive credible fear determinations
into more limited asylum-andwithholding-only proceedings properly
balanced the need to prevent
noncitizens from being removed to
countries where they may face
persecution or torture with ensuring
efficiency in the overall adjudication
process. See id.
This rule offers another approach. It
establishes a streamlined and simplified
adjudication process for individuals
encountered at or near the border,
placed into expedited removal, and
determined to have a credible fear of
persecution or torture, with the aim of
deciding protection claims in a more
timely fashion while ensuring
appropriate safeguards against error.13
The rule authorizes USCIS to adjudicate
in the first instance the asylum claims
of individuals who receive positive
credible fear determinations under the
expedited removal framework in section
235(b)(1) of the INA, 8 U.S.C. 1225(b)(1).
The procedures that USCIS asylum
officers will use to adjudicate these
claims will be nonadversarial, and the
decisions will be made within time
frames consistent with those established
by Congress in section 208(d)(5)(A) of
the INA, 8 U.S.C. 1158(d)(5)(A).14
The Departments believe that the
approach in this rule, in contrast to the
approach outlined in the Global Asylum
rule, will allow for noncitizens’ claims
13 Section 4(b)(i) of Executive Order 14010,
Creating a Comprehensive Regional Framework to
Address the Causes of Migration, To Manage
Migration Throughout North and Central America,
and To Provide Safe and Orderly Processing of
Asylum Seekers at the United States Border,
instructed the Secretary to review the procedures
for individuals placed into expedited removal at or
near the border and issue a report with
recommendations ‘‘for creating a more efficient and
orderly process that facilitates timely adjudications
[of asylum and protection claims] and adherence to
standards of fairness and due process.’’ 86 FR 8267,
8270 (Feb. 2, 2021).
14 See INA 208(d)(5)(A)(ii)–(iii), 8 U.S.C.
1158(d)(5)(A)(ii)–(iii) (specifying that an initial
interview or hearing on an asylum application
should generally commence within 45 days after
the filing of the application and that final
administrative adjudication should generally be
completed within 180 days after the filing of the
application).
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to be heard more efficiently and fairly.
As further explained in this rule,
allowing noncitizens with positive
credible fear determinations to have
their asylum, statutory withholding, and
CAT protection claims heard in a
nonadversarial setting before an asylum
officer capitalizes on the investment of
time and expertise that USCIS has
already made and, for the subset of
cases in which asylum is granted by
USCIS, saves investment of time and
resources by EOIR and ICE. See Sections
II.C. and IV.D.5 of this preamble. The
extensive and well-rounded training
that asylum officers receive is designed
to enable them to conduct
nonadversarial interviews in a fair and
sensitive manner. This rule will also
enable meritorious cases to be resolved
more quickly, reducing the overall
asylum system backlogs and using
limited asylum officer and IJ resources
more efficiently. If the asylum officer
does not grant asylum following an
Asylum Merits interview, the noncitizen
will be referred to an IJ for streamlined
section 240 removal proceedings, with a
structure that provides for the prompt
resolution of their claims and that
allows the noncitizen to seek other
forms of relief. If the asylum application
includes a dependent who has not filed
a separate application and the principal
applicant is determined not to be
eligible for asylum, the asylum officer
will elicit sufficient information to
determine whether there is a significant
possibility that the applicant’s
dependent has experienced or fears
harm that would be an independent
basis for protection prior to referring the
family to the IJ for a hearing. This will
allow EOIR to consider all family
members to have separately filed an
asylum application once the family is
placed into the streamlined section 240
removal proceedings.
This IFR will help more effectively
achieve many of the goals outlined in
the Global Asylum rule—including
improving efficiency, streamlining the
adjudication of asylum, statutory
withholding of removal, and CAT
protection claims, and lessening the
strain on the immigration courts—albeit
with a different approach. This rule
helps meet the goal of lessening the
strain on the immigration courts by
having USCIS asylum officers
adjudicate asylum claims in the first
instance, rather than IJs. As explained
further in this rule, the Departments
anticipate that the number of cases
USCIS refers to EOIR for adjudication
will decrease. See Sections IV.F.1.a and
V.B.4.b.ii of this preamble. In contrast to
the Global Asylum rule, in this rule, the
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Departments are amending regulations
to include several time frames for the
adjudication process and particular
procedural requirements designed to
streamline the overall process and take
advantage of the record created by the
asylum officer, while still providing
noncitizens with a full and fair
opportunity to present testimony and
evidence in support of their claims
before an IJ. See Sections II.A.4 and III.D
of this preamble. Accordingly, these
changes better meet the Departments’
goals of improving efficiency and
streamlining the process. In addition,
upon reconsideration, the Departments
recognize that giving noncitizens the
opportunity to seek other forms of relief
within the context of streamlined
section 240 removal proceedings helps
reduce barriers to accessing other
immigration benefits that may be
available, and that the potential benefits
to noncitizens of having such an
opportunity outweigh efficiency
concerns.
The Departments clarify that nothing
in this rule is intended to displace
DHS’s (and, in particular, USCIS’s)
prosecutorial discretion to place a
covered noncitizen in, or to withdraw a
covered noncitizen from, expedited
removal proceedings and issue an NTA
to place the noncitizen in ordinary
section 240 removal proceedings at any
time after they are referred to USCIS for
a credible fear determination. See 8 CFR
208.30(b), (f); Matter of J–A–B– & I–J–V–
A–, 27 I&N Dec. 168, 171 (BIA 2017);
Matter of E–R–M– & L–R–M–, 25 I&N
Dec. 520, 523 (BIA 2011). Moreover,
should any provision of the rule
governing the USCIS process for cases
covered by 8 CFR 208.2(a)(1)(ii) be
enjoined or vacated, EOIR has the
discretion to place into ordinary section
240 proceedings any case referred to
EOIR under this section.
A. Credible Fear Screening Process
The credible fear screening
regulations under this rulemaking
generally recodify the current screening
process, returning the regulatory
language, in large part, to what was in
place prior to the various regulatory
changes made from the end of 2018
through the end of 2020. Noncitizens
encountered at or near the border or
ports of entry and determined to be
inadmissible pursuant to INA
212(a)(6)(C) or (a)(7), 8 U.S.C.
1182(a)(6)(C) or (a)(7), can be placed in
expedited removal and provided a
credible fear screening if they indicate
an intention to apply for asylum, a fear
of persecution or torture, or a fear of
return to their home countries. See INA
235(b)(1)(A)(ii), (B), 8 U.S.C.
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1225(b)(1)(A)(ii), (B); 8 CFR 235.3(b)(4),
1235.3(b)(4). Individuals claiming a fear
or an intention to apply for protection
are referred to USCIS asylum officers for
an interview and consideration of their
fear claims under the ‘‘significant
possibility’’ standard, which presently
applies to all relevant protection claims
because the regulatory changes
referenced above have been vacated or
enjoined.15
The Departments are returning to
codifying the historical practice of
applying the ‘‘significant possibility’’
standard across all forms of protection
screened in the credible fear process.
This rule adopts the ‘‘significant
possibility’’ standard for credible fear
screening for purposes of asylum,
statutory withholding of removal, and
CAT protection. While the statutory text
at INA 235(b)(1)(B)(v), 8 U.S.C.
1225(b)(1)(B)(v), only defines ‘‘credible
fear’’ for purposes of screening asylum
claims, the Departments believe that the
efficiency gained in screening the same
or a closely related set of facts using the
same legal standard at the same time is
substantial and should not be
overlooked. Moreover, the credible fear
screening process is preliminary in
nature; its objective is to sort out,
without undue decision costs, which
cases merit further consideration. See
generally INA 235(b)(1)(B); 8 U.S.C.
1225(b)(1)(B). Efficiently using one
standard of law at the preliminary step
is consistent with that objective, even
though the ultimate adjudication of a
noncitizen’s claim for each form of
protection may require a distinct
analysis.
The standard for establishing a
credible fear of persecution under the
INA requires ‘‘a significant possibility,
taking into account the credibility of the
statements made by the [noncitizen] in
support of the [noncitizen’s] claim and
such other facts as are known to the
officer, that the [noncitizen] could
establish eligibility for asylum under
section 208’’ of the INA. INA
235(b)(1)(B)(v), 8 U.S.C.
1225(b)(1)(B)(v). While the ‘‘significant
possibility’’ standard for the purpose of
screening for asylum is established by
statute, the statute does not specify a
standard to be used in screening for
statutory withholding of removal or
CAT protection. In June 2020, the
Departments proposed alternative
standards for statutory withholding of
removal and CAT protection. See
Procedures for Asylum and Withholding
of Removal; Credible Fear and
Reasonable Fear Review, 85 FR 36264,
15 See supra note 4 (discussing recent regulations
and their current status).
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18091
36268 (June 15, 2020) (‘‘Global Asylum
NPRM’’). Under that proposed rule,
‘‘asylum officers would consider
whether [noncitizens] could establish a
credible fear of persecution, a
reasonable possibility of persecution, or
a reasonable possibility of torture.’’ Id.
at 36269. In finalizing that rule, the
Departments noted that in changing the
standard of law for withholding of
removal and deferral of removal, an
individual’s ‘‘screening burdens would
become adequately analogous to the
merits burdens, where the [individual’s]
burdens for statutory withholding of
removal and protections under the CAT
regulations are higher than the burden
for asylum.’’ Global Asylum rule, 85 FR
80277. However, pursuant to an
Executive order and with the additional
context of the court’s injunction against
the implementation of the Global
Asylum rule in Pangea II,16 the
Departments have reviewed and
reconsidered that rule. See Executive
Order 14012, Restoring Faith in Our
Legal Immigration Systems and
Strengthening Integration and Inclusion
Efforts for New Americans, 86 FR 8277
(Feb. 2, 2021) (‘‘E.O. on Legal
Immigration’’) (ordering review of
existing regulations for consistency with
the E.O. on Legal Immigration). In line
with this review, the Departments have
revisited the approach of having
divergent standards applied during the
credible fear screening and determined
that keeping one standard in screening
for asylum, statutory withholding, and
CAT protection better promotes an
efficient credible fear screening process.
In multiple rulemaking efforts, the
Departments promulgated divergent
standards for asylum and withholding
of removal, along with variable
standards for individuals barred from
certain types of protection.17 However,
in working to create efficiencies within
this process, as well as recognizing that
the Departments have signaled their
intention to either modify or rescind
these rules,18 adhering to the legal
standard that was set by Congress in
section 235(b)(1)(B)(v) of the Act, 8
U.S.C. 1225(b)(1)(B)(v), is the logical
16 See supra note 4 (discussing recent regulations
and their current status).
17 See supra note 4 (describing the TCT Bar IFR,
Presidential Proclamation Bar IFR, and Security
Bars rule).
18 See Executive Office of the President, Office of
Management and Budget (‘‘OMB’’), Office of
Information and Regulatory Affairs (‘‘OIRA’’),
Spring 2021 Unified Agenda of Regulatory and
Deregulatory Actions, https://www.reginfo.gov/
public/do/eAgendaHistory (last visited Mar. 5,
2022) (select DHS or DOJ); Executive Office of the
President, OMB, OIRA, Fall 2021 Unified Agenda
of Regulatory and Deregulatory Actions, https://
www.reginfo.gov/public/do/eAgendaMain (last
visited Mar. 5, 2022) (select DHS or DOJ).
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choice. See 86 FR 46914. Upon
reconsideration, the Departments
believe that the varied legal standards
created by different rulemakings, and
enjoined or vacated by legal challenges,
defeat their intended purpose, and
complicate and extend the initial
screening process provided for in INA
section 235. Having asylum officers
apply varied legal standards would
generally lead to the need to elicit
additional testimony from noncitizens
at the time of the credible fear screening
interview, which lengthens credible fear
interviews and increases adjudication
times. In the Departments’ view, the
delays associated with complicating and
extending every credible fear interview
likely outweigh any efficiencies gained
by potential earlier detection of
individuals who may be barred from or
ineligible for certain types of protection.
For example, when the TCT Bar IFR was
in effect,19 asylum officers were
required to spend additional time
during any interview where the bar
potentially applied developing the
record related to whether the bar
applied, whether an exception to the bar
might have applied, and, if the
noncitizen appeared to be barred and
did not qualify for an exception to the
bar, developing the record sufficiently
such that a determination could be
made according to the higher reasonable
fear standard. This additional time
spent developing the record when the
higher reasonable fear standard applied
decreased the efficiency of the screening
interviews themselves and complicated
the analysis asylum officers were
required to perform, thus contributing to
the overall lengthening of the entire
process.
In the Global Asylum NPRM, the
Departments stated that ‘‘[r]aising the
standards of proof to a ‘reasonable
possibility’ for the screening of
19 The TCT Bar IFR went into effect on July 16,
2019, see 84 FR 33829, and was vacated on June
30, 2020, see Capital Area Immigrants’ Rights Coal.
v. Trump, 471 F. Supp. 3d at 45–57. The TCT Bar
rule went into effect on January 19, 2021. See 85
FR 82260. However, it did not have an impact on
credible fear processing. The TCT Bar rule did not
directly make any amendments to the credible fear
regulations at 8 CFR 208.30 and instead relied on
changes to the credible fear regulations made by the
Global Asylum rule in order to apply the TCT bar
in credible fear. On January 8, 2021, the Global
Asylum rule was preliminarily enjoined. See
Pangea II, 512 F. Supp. 3d 966. As a result of the
preliminary injunction in Pangea II, the
amendments to 8 CFR 208.30 made by the Global
Asylum rule were enjoined. Thus, the bar to asylum
eligibility at 8 CFR 208.13(c)(4) established in the
TCT Bar rule did not apply in credible fear while
the Global Asylum rule remained enjoined. The
TCT Bar rule itself was enjoined on February 16,
2021. See E. Bay Sanctuary Covenant, 519 F. Supp.
3d at 668. Therefore, only the TCT Bar IFR ever
went into effect.
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[noncitizens] seeking statutory
withholding of removal and CAT
protection would allow the Departments
to better screen out non-meritorious
claims and focus limited resources on
claims much more likely to be
determined to be meritorious by an
immigration judge.’’ 85 FR 36271.
However, based on the Departments’
experience implementing divergent
screening standards for asylum,
statutory withholding of removal, and
CAT protection while the TCT Bar IFR
was in effect, no evidence has been
identified that this approach resulted in
more successful screening out of nonmeritorious claims while ensuring the
United States complied with its nonrefoulement obligations.
The Departments also reasoned in the
Global Asylum NPRM: ‘‘Adopting a
higher standard for statutory
withholding and CAT screenings would
not hinder the streamlined process
envisioned for expedited removal.
Asylum officers already receive
extensive training and guidance on
applying the ‘reasonable possibility’
standard in other contexts because they
are determining whether a reasonable
possibility of persecution or torture
exists in reasonable fear determinations
pursuant to 8 CFR 208.31. In some
cases, asylum officers would need to
spend additional time eliciting more
detailed testimony from [noncitizens] to
account for the higher standard of proof;
however, the overall impact on the time
asylum officers spend making screening
determinations would be minimal.’’ 85
FR 36271. However, the Departments
have reconsidered these predictions,
again based on the experience
implementing divergent screening
standards while the TCT Bar IFR was in
effect. Beyond the additional time
asylum officers themselves spent
conducting these screening interviews,
making determinations, and recording
their assessments, supervisory asylum
officers reviewing these cases spent
additional time assessing whether the
varying standards of proof were
properly applied to the forms of relief
for which asylum officers screened. This
effort also required the additional
investment of time and resources from
Asylum Division headquarters,
including training and quality assurance
staff who had to develop and deliver
guidance and trainings on the new
process, monitor the work being
conducted in the field to ensure
compliance with regulations and
administrative processes, and provide
guidance to asylum officers and
supervisory asylum officers on
individual cases. Attorneys from the
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USCIS Office of Chief Counsel had to
spend time and resources reviewing and
advising on training materials and
guidance issued by the Asylum
Division, as well as on individual cases
on which legal advice was sought to
ensure proper application of the
divergent screening standards on
various forms of relief. IJs reviewing
negative determinations by asylum
officers were also compelled to spend
additional time ensuring the proper
application of these screening
standards, compared to the time spent
reviewing determinations under a single
standard in the status quo ante. The
Departments failed to account in the
relevant rulemakings for the necessity of
expending these additional resources
beyond time spent by asylum officers
themselves making screening
determinations.
The Departments also stated in the
Global Asylum NPRM: ‘‘The procedural
aspects of making screening
determinations regarding fear of
persecution and of torture would remain
largely the same. Moreover, using a
higher standard of proof in the
screening context for those seeking
statutory withholding of removal or
protection under the CAT regulations in
the immigration courts allows the
Departments to more efficiently and
promptly distinguish between aliens
whose claims are more likely or less
likely to ultimately be meritorious.’’ 85
FR 36271. However, for the reasons
detailed above, the Departments’
experience implementing divergent
screening standards while the TCT Bar
IFR was in effect demonstrated that
these predictions of increased efficiency
and promptness did not materialize,
undermining congressional intent that
the screening process in the expedited
removal context operate nimbly and in
a truly expedited manner.
In clarifying that the ‘‘significant
possibility’’ standard applies not only to
credible fear screening for asylum, but
also to credible fear screening for
statutory withholding and CAT
protection, the Departments will help
ensure that the expedited removal
process remains truly expedited, and
will allow for asylum officers to adhere
to a single legal standard in screening
claims for protection from persecution
and torture in the expedited removal
process.
Similarly, through this rulemaking,
the Departments are generally returning
the regulatory text to codify the pre2018, and current, practice of screening
for eligibility for asylum and statutory
withholding of removal while not
applying most bars to asylum or
withholding of removal in the credible
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fear screening process. The Global
Asylum rule, which has been enjoined,
attempted to require the application of
a significantly expanded list of
mandatory bars during credible fear
screenings and mandated a negative
credible fear finding should any of the
bars apply to the noncitizen at that
initial stage. See 85 FR 80278; supra
note 4. In the Global Asylum NPRM, the
Departments justified this change by
stating: ‘‘From an administrative
standpoint, it is pointless and inefficient
to adjudicate claims for relief in section
240 proceedings when it is determined
that an alien is subject to one or more
of the mandatory bars to asylum or
statutory withholding at the screening
stage. Accordingly, applying those
mandatory bars to aliens at the ‘credible
fear’ screening stage would eliminate
removal delays inherent in section 240
proceedings that serve no purpose and
eliminate the waste of adjudicatory
resources currently expended in vain.’’
85 FR 36272. However, upon
reconsideration, the Departments have
determined that, in most cases, the
stated goal of promoting administrative
efficiency can be better accomplished
through the mechanisms established in
this rulemaking rather than through
applying mandatory bars at the credible
fear screening stage. The Departments
now believe that it is speculative
whether, had the Global Asylum rule
been implemented, a meaningful
portion of the EOIR caseload might have
been eliminated because some
individuals who were found at the
credible fear screening stage to be
subject to a mandatory bar would not
have been placed into section 240
proceedings. This is particularly true in
light of the Global Asylum rule’s
preservation of a noncitizen’s ability to
request review of a negative credible
fear determination (including the
application of mandatory bars at the
credible fear stage) by an IJ, as well as
that rule’s allowance for individuals
found subject to a mandatory bar to
asylum at the credible fear screen stage
to nonetheless have their asylum claims
considered by an IJ in asylum-andwithholding-only proceedings if they
demonstrate a reasonable possibility of
persecution or torture and are not
subject to a bar to withholding of
removal. Requiring asylum officers to
broadly apply mandatory bars during
credible fear screenings would have
made these screenings less efficient,
undermining congressional intent that
the expedited removal process be truly
expeditious, and would further limit
DHS’s ability to use expedited removal
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to an extent that is operationally
advantageous.
Requiring asylum officers to broadly
apply the mandatory bars at credible
fear screening would increase credible
fear interview and decision times
because asylum officers would be
expected to devote time to eliciting
testimony, conducting analysis, and
making decisions about all applicable
bars. For example, when the TCT Bar
IFR was in effect,20 asylum officers were
required to spend additional time
during any interview where the bar
potentially applied developing the
record related to whether the bar
applied, whether an exception to the bar
might have applied, and, if the
noncitizen appeared to be barred and
did not qualify for an exception to the
bar, developing the record sufficiently
such that a determination could be
made according to the higher reasonable
fear standard. As another example, a
‘‘particularly serious crime’’ is not
statutorily defined in detail, beyond an
aggravated felony,21 and offenses
typically are designated as particularly
serious crimes through case-by-case
adjudication—the kind of fact-intensive
inquiry requiring complex legal analysis
that would be more appropriate in a full
adjudication before an asylum officer or
in section 240 proceedings with the
availability of judicial review than in
credible fear screenings.22 Presently,
asylum officers ask questions related to
all mandatory bars to develop the record
sufficiently and identify potential bars
but, since mandatory bars are not
currently being applied in the credible
fear determination, the record does not
need to be developed to the level of
detail that would be necessary if the
issue of a mandatory bar was outcomedeterminative for the credible fear
determination. If a mandatory bar were
to become outcome determinative, it
would be necessary to develop the
20 See
supra note 19.
INA 208(b)(2)(A)(ii), (B)(i), 8 U.S.C.
1158(b)(2)(A)(ii), (B)(i).
22 See Matter of Frentescu, 18 I&N Dec. 244, 247
(BIA 1982) (setting out multi-factor test to
determine whether a noncitizen has committed a
particularly serious crime, including ‘‘the nature of
the conviction, the circumstances and underlying
facts of the conviction, the type of sentence
imposed, and, most importantly, whether the type
and circumstances of the crime indicate that the
alien will be a danger to the community’’); see also
Matter of L–S–, 22 I&N Dec. 645, 649 (BIA 1999) (en
banc); Matter of G–G–S–, 26 I&N Dec. 339, 343–43
(BIA 2014) (‘‘We have held that for an alien who
has not been convicted of an aggravated felony or
whose aggravated felony conviction did not result
in an aggregate term of imprisonment of 5 years or
more, it is necessary to examine the nature of the
conviction, the type of sentence imposed, and the
circumstances and underlying facts of the
conviction to determine whether the crime was
particularly serious.’’).
21 See
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18093
record sufficiently to make a decision
about the mandatory bar such that,
depending on the facts, the interview
would go beyond its congressionally
intended purpose as a screening for
potential eligibility for asylum or related
protection—and a fail-safe to minimize
the risk of refoulement—and would
instead become a decision on the relief
or protection itself. The level of detailed
testimony necessary in some cases to
make such a decision would require
asylum officers to spend significantly
more time developing the record during
the interview and conducting additional
research following the interview.
IJs reviewing negative credible fear
determinations where a mandatory bar
was applied would, depending on the
facts, similarly face a more complicated
task, undermining the efficiency of that
process as well. Applying a mandatory
bar often involves a complex legal and
factual inquiry. While asylum officers
are trained to gather and analyze such
information to determine the
applicability of mandatory bars in
affirmative asylum adjudications, they
are currently instructed to assess
whether certain bars may apply in the
credible fear screening context. See
USCIS, Credible Fear of Persecution and
Torture Determinations Lesson Plan 42–
43 (Feb. 13, 2017). The latter assessment
is designed to identify any mandatory
bar issues requiring further exploration
for IJs and the ICE attorneys
representing DHS in section 240
removal proceedings, see 6 U.S.C.
252(c), rather than to serve as a
comprehensive analysis upon which a
determination on the applicability of a
bar may be based.23 Because of the
complexity of the inquiry required to
develop a sufficient record upon which
to base a decision to apply certain
mandatory bars, such a decision is, in
general and depending on the facts,
most appropriately made in the context
of a full merits interview or hearing,
whether before an asylum officer or an
IJ, and not in a screening context.
Furthermore, the Departments
recognize that considerations of
procedural fairness counsel against
applying mandatory bars that entail
extensive fact-finding during the
credible fear screening process. In
23 See USCIS, Credible Fear of Persecution and
Torture Determinations Lesson Plan 44 (Feb. 13,
2017) (‘‘The officer must keep in mind that the
applicability of these bars requires further
evaluation that will take place in the full hearing
before an immigration judge if the applicant
otherwise has a credible fear of persecution or
torture. In such cases, the officer should consult a
supervisory officer follow procedures on ‘flagging’
such information for the hearing, and prepare the
appropriate paperwork for a positive credible fear
finding.’’).
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response to the Global Asylum NPRM,
a commenter emphasized that each of
the mandatory bars involves intensive
legal analysis and asserted that
requiring asylum officers to conduct this
analysis during a screening interview
would result in ‘‘the return of many
asylum seekers to harm’s way.’’ Global
Asylum rule, 85 FR 80294. Another
commenter expressed the concern that
‘‘countless asylum-seekers could be
erroneously knocked out of the process
based on hasty decisions,
misunderstandings, and limited
information.’’ Id. at 80295. Upon review
and reconsideration, due to the
intricacies of the fact-finding and legal
analysis often required to apply
mandatory bars, the Departments now
believe that individuals found to have a
credible fear of persecution generally
should be afforded the additional time,
procedural protections, and opportunity
to further consult with counsel that the
Asylum Merits process or section 240
removal proceedings provide.
In light of these concerns, the
Departments have reconsidered their
position stated in the preamble to the
Global Asylum NPRM that any removal
delays resulting from the need to fully
consider the mandatory bars in section
240 proceedings ‘‘serve no purpose’’
and amount to ‘‘adjudicatory resources
currently expended in vain.’’ 85 FR
36272. As stated above, the Departments
now believe that, in many cases,
especially when intensive fact-finding is
required, the notion that consideration
of mandatory bars at the credible fear
screening stage would result in
elimination of removal delays for
individuals subject to the bars is
speculative. Moreover, to the extent
consideration of mandatory bars in
section 240 proceedings does result in
delays to removal, the Departments
believe in light of the public comments
cited above that such delays do serve
important purposes—particularly in
cases with complicated facts—namely,
ensuring that the procedures and forum
for determining the applicability of
mandatory bars appropriately account
for the complexity of the inquiry and
afford noncitizens potentially subject to
the mandatory bars a reasonable and fair
opportunity to contest their
applicability. Adjudicatory resources
designed to ensure that noncitizens are
not refouled to persecution due to the
erroneous application of a mandatory
bar are not expended in vain. Rather,
the expenditure of such resources helps
keep the Departments in compliance
with Federal law and international
treaty obligations.
Given the need to preserve the
efficiencies Congress intended in
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making credible fear screening part of
the expedited removal process and to
ensure procedural fairness for those
individuals found to have a significant
possibility of establishing eligibility for
asylum or statutory withholding of
removal but for the potential
applicability of a mandatory bar, the
Departments have decided that the
Global Asylum rule’s broad-based
application of mandatory bars at the
credible fear screening stage should be
rescinded.24
If an asylum officer determines that
an individual does not have a credible
fear of persecution or torture, the
individual can request that an IJ review
the asylum officer’s negative credible
fear determination. See INA
235(b)(1)(B)(iii)(III), 8 U.S.C.
1225(b)(1)(B)(iii)(III); 8 CFR 208.30(g),
1208.30(g). The Departments also are recodifying the treatment of a failure or
refusal on the part of a noncitizen to
request IJ review of a negative credible
fear determination as a request for IJ
review. See 8 CFR 208.30(g)(1),
1208.30(g)(2)(i). In the Global Asylum
rule, the Departments amended
regulations to treat a noncitizen’s refusal
to indicate whether they would like IJ
review as declining IJ review. See 85 FR
80296. The Departments explained that
treating refusals as requests for review
serves to create unnecessary and undue
burdens and that it is reasonable to
require an individual to answer
affirmatively when asked by an asylum
officer if they would like IJ review. See
id. In this rule, the Departments are
reverting to the pre-existing regulations.
Upon reconsideration, the Departments
recognize that there may be numerous
explanations for a noncitizen’s refusal
or failure to indicate whether they
would like to seek IJ review—and
indeed there will be cases in which a
noncitizen wants review but fails to
explicitly indicate it. The Departments
now conclude that treating any refusal
or failure to elect review as a request for
IJ review, rather than as a declination of
such review, is fairer and better
accounts for the range of explanations
for a noncitizen’s failure to seek review.
Treating such refusals or failures to elect
review as requests for IJ review
appropriately ensures that any
noncitizen who may wish to pursue IJ
24 In addition to the proposed changes to the DOJ
portions of the regulations in the NPRM related to
the application of mandatory bars in the credible
fear process, the IFR also includes a similar edit to
8 CFR 1003.42(d)(1). Both 8 CFR 1003.42 and 8 CFR
1208.30 relate to IJs’ review of asylum officers’
credible fear determinations, and the Departments
intend for the regulations to be consistent with
regard to the treatment of mandatory bars in the
credible fear review process.
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review (that is, any noncitizen who has
not, in fact, declined IJ review) has the
opportunity to do so. A noncitizen who
genuinely wishes to decline review may
of course withdraw the request for
review before the IJ; in such a case, the
IJ will return the noncitizen’s case to
DHS for execution of the expedited
removal order. See 8 CFR 1208.30(g)(2).
In comparison to the NPRM, in this
rule, the Departments are amending 8
CFR 208.30(g) to provide, in new 8 CFR
208.30(g)(1)(i), that USCIS may, in its
discretion, reconsider a negative
credible fear determination with which
an IJ has concurred, provided the
request for reconsideration is received
from the noncitizen or their attorney or
initiated by USCIS no more than 7 days
after the concurrence by the IJ, or prior
to the noncitizen’s removal, whichever
date comes first. USCIS’s
reconsideration of any such request is
discretionary. After an IJ has concurred
with a negative credible fear
determination, DHS can execute the
individual’s expedited removal order,
promptly removing the individual from
the United States. Under no
circumstances, however, will USCIS
accept more than one request for
reconsideration.
The Departments carefully considered
the public comments received in
response to the NPRM related to the
proposal to foreclose any DHS
reconsideration of negative credible fear
determinations. Based on those
comments, the Departments decided to
retain the existing regulatory language
related to DHS reconsideration, see 8
CFR 208.30(g), but to place reasonable
procedural limits on the practice.
Accordingly, the Departments are
amending the regulation to include
numerical and time limitations and
clarify that DHS may, in its discretion,
reconsider a negative credible fear
determination with which an IJ has
concurred. These procedural limitations
and clarifications are necessary to
ensure that reconsideration requests to
USCIS do not obstruct the streamlined
process that Congress intended in
creating expedited removal. These
changes also are consistent with the
statutory scheme of INA 235(b)(1)(B), 8
U.S.C. 1225(b)(1)(B), under which it is
the IJ review of the negative credible
fear determination that serves as the
check to ensure that noncitizens who
have a credible fear of persecution or
torture are not returned based on an
erroneous screening determination by
USCIS. The expedited removal statute
and its implementing regulations
generally prohibit any further
administrative review or appeal of an
IJ’s decision made after review of a
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negative credible fear determination.
See INA 235(b)(1)(B)(iii)(III), (C), 8
U.S.C. 1225(b)(1)(B)(iii)(III), (C); 8 CFR
1003.42(f)(2), 1208.30(g)(2)(iv)(A).
Congress similarly has made clear its
intent that expedited removal should
remain a streamlined, efficient process
by limiting judicial review of many
determinations in expedited removal.
See INA 242(a)(2)(A), (e), 8 U.S.C.
1252(a)(2)(A), (e). These statutory
provisions limiting administrative and
judicial review and directing
expeditious determinations reflect clear
congressional intent that expedited
removal be a truly expedited process.
The numerical and time limitations
promulgated in this rule are consistent
with congressional intent and with the
purpose of the current regulation
allowing for such requests. The
Departments believe that, over time, the
general allowance for reconsideration by
USCIS asylum offices came to be used
beyond its original intended scope.
Such requests have not used a
formalized process, since there is
currently no formal mechanism for
noncitizens to request reconsideration
of a negative credible fear determination
before USCIS; instead, they are
entertained on an informal, ad hoc basis
whereby individuals contact USCIS
asylum offices with their
reconsideration requests after an IJ has
affirmed the negative credible fear
determination. This informal, ad hoc
allowance for such requests, including
multiple requests, has proven difficult
to manage. To deal with these many
requests, USCIS has had to devote time
and resources that could more
efficiently be used on initial credible
fear and reasonable fear determinations,
affirmative asylum cases, and now,
Asylum Merits interviews with the
present rule.
B. Applications for Asylum
If the noncitizen is found to have a
credible fear, this IFR changes the
procedure as described above. Under
this rule, rather than referring the
individual to an IJ for an adversarial
section 240 removal proceeding in the
first instance, or, as provided for in a
presently enjoined regulation, asylumand-withholding-only proceedings
before an IJ,25 the individual’s asylum
application instead may be retained for
further consideration by USCIS through
a nonadversarial interview before an
asylum officer. See 8 CFR 208.30(f).
Similarly, if, upon review of an asylum
officer’s negative credible fear
25 See Global Asylum rule, 85 FR 80276; supra
note 4 (discussing recent regulations and their
current status).
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determination, an IJ finds that an
individual does have a credible fear of
persecution or torture, the individual
also can be referred back to USCIS for
further consideration of the individual’s
asylum claim. See 8 CFR 1003.42,
1208.30(g). To eliminate delays between
a positive credible fear determination
and the filing of an application for
asylum, the Departments are amending
regulations to provide, in new 8 CFR
208.3(a)(2), that the written record of the
credible fear determination created by
USCIS during the credible fear process,
and subsequently served on the
individual together with the service of
the credible fear decision itself, will be
treated as an ‘‘application for asylum,’’
with the date of service on the
individual considered the date of filing.
Every individual who receives a
positive credible fear determination and
whose case is retained by USCIS will be
considered to have filed an application
for asylum at the time the determination
is served on them. The application will
be considered filed or received as of the
service date for purposes of the one-year
filing deadline for asylum, see INA
208(a)(2)(B), 8 U.S.C. 1158(a)(2)(B), and
for starting the waiting period for
eligibility to file for employment
authorization based upon a pending
asylum application, see 8 CFR
208.3(c)(3). The Departments are
amending regulations to provide that
this application for asylum will be
considered a complete application for
purposes of 8 CFR 208.4(a), 208.7, and
208.9(a) in order to qualify for an
interview and adjudication, and will be
subject to the other conditions and
consequences provided for in 8 CFR
208.3(c) once the noncitizen signs the
documentation under penalty of perjury
and with notice of the consequences of
filing a frivolous asylum application at
the time of the Asylum Merits
interview, as provided in new 8 CFR
208.3(a)(2).26
26 In addition, the Departments are amending 8
CFR 1208.3 and 1208.4 to account for changes made
by this rule, including the provisions that will treat
the record of the credible fear determination as an
application for asylum in the circumstances
addressed by the rule. The amendment at 8 CFR
1208.3(c)(3) affects language that was enacted in the
rule entitled ‘‘Procedures for Asylum and
Withholding of Removal,’’ 85 FR 81698 (Dec. 16,
2020). The December 16, 2020, rulemaking made
various changes to DOJ regulations, including 8
CFR 1208.3(c)(3). Id. at 81750–51. The December
16, 2020, rulemaking is preliminarily enjoined. See
Order at 1, Nat’l Immigrant Justice Ctr. v. Exec.
Office for Immigration Review, No. 21–cv–56
(D.D.C. Jan. 14, 2021). This rule makes changes to
the regulations only as necessary to effectuate its
goals. The Departments anticipate that additional
changes to the relevant regulations, including
rescission of or revision to the language added by
the preliminarily enjoined regulation, will be made
through later rulemakings. See Executive Office of
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The Departments will implement
these changes to the credible fear
process by having the USCIS asylum
officer conducting the credible fear
interview advise the noncitizen of the
consequences of filing a frivolous
asylum application and capture the
noncitizen’s relevant information
through testimony provided under oath.
During the credible fear interview, as 8
CFR 208.30(d) already provides and will
continue to provide under the IFR, the
asylum officer will ‘‘elicit all relevant
and useful information’’ for the credible
fear determination, create a summary of
the material facts presented by the
noncitizen during the interview, review
the summary with the noncitizen, and
allow the noncitizen to correct any
errors. The record created will contain
the necessary biographical information
and sufficient information related to the
noncitizen’s fear claim to be considered
an application. As a matter of
longstanding practice in processing
families through credible fear
screenings, the information captured by
the asylum officer during the credible
fear interview will contain information
about the noncitizen’s spouse and
children, if any, including those who
were not part of the credible fear
determination—but under this rule only
a spouse or child who was included in
the credible fear determination issued
pursuant to 8 CFR 208.30(c) or who has
a pending asylum application with
USCIS pursuant to 8 CFR 208.2(a)(1)(ii)
can be included as a dependent on the
request for asylum.27 See 8 CFR
208.3(a)(2). Any spouse or child
included as a dependent on the credible
fear determination may request to file a
separate asylum application as a
the President, OMB, OIRA, Fall 2021 Unified
Agenda of Regulatory and Deregulatory Actions,
https://www.reginfo.gov/public/do/eAgenda
ViewRule?pubId=202110&RIN=1125-AB15 (last
visited Feb. 28, 2022).
27 While only a spouse or child included on the
credible fear determination or who presently has an
asylum application pending with USCIS after a
positive credible fear determination can be
included as a dependent on the subsequent asylum
application under this process, the noncitizen
granted asylum remains eligible to apply for
accompanying or follow-to-join benefits for any
qualified spouse or child not included on the
asylum application, as provided for in 8 CFR
208.21. The Departments believe that it is
procedurally impractical to attempt to include a
spouse or child on the application when the spouse
or child has not previously been placed into
expedited removal and subsequently referred to
USCIS after a positive credible fear determination.
This is similar to the inability to include a spouse
or child not in section 240 removal proceedings on
the asylum application of a principal asylum
applicant who is in such section 240 removal
proceedings. Under such circumstances, there is no
clear basis for issuing a final order of removal
against such an individual spouse or child should
the asylum application not be approved.
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principal applicant with USCIS at any
time while the principal’s asylum
application is pending with USCIS. See
8 CFR 208.3(a)(2). A copy of the
principal applicant’s application for
asylum—the record of the credible fear
determination, including the asylum
officer’s notes from the interview, the
summary of material facts, and other
materials upon which the determination
was based—will be provided to the
noncitizen at the time that the positive
credible fear determination is served.
See 8 CFR 208.30(f). As provided in new
8 CFR 208.4(b)(2), the noncitizen may
subsequently amend or correct the
biographic or credible fear information
in the Form I–870, Record of
Determination/Credible Fear Worksheet,
or supplement the information collected
during the process that concluded with
a positive credible fear determination,
up until 7 days prior to the scheduled
Asylum Merits interview before a USCIS
asylum officer, or for documents
submitted by mail, postmarked no later
than 10 days before the scheduled
Asylum Merits interview. The asylum
officer, finding good cause in an
exercise of USCIS discretion, may
consider amendments or supplements
submitted after the 7- or 10-day
submission deadline or may grant the
applicant an extension of time during
which the applicant may submit
additional evidence, subject to the
limitation on extensions described in 8
CFR 208.9(e)(2). In new 8 CFR
208.9(e)(2), this rule further provides
that, in the absence of exigent
circumstances, an asylum officer shall
not grant any extensions for submission
of additional evidence that would
prevent the Asylum Merits decision
from being issued to the applicant
within 60 days of service of the positive
credible fear determination. The
Departments believe that such
limitations are necessary to ensure that
the process remains expeditious while
maintaining fairness.
The information required to be
gathered during the credible fear
screening process is based on the
noncitizen’s own testimony under oath
in response to questions from a trained
USCIS asylum officer. Thus, the
Departments believe that the screening
would provide sufficient information
upon which to ascertain the basis of the
noncitizen’s request for protection.
Under this rule, noncitizens who
receive a positive credible fear
determination would have an asylum
application on file with the Government
within days of their credible fear
screenings, thereby meeting the oneyear asylum filing deadline, avoiding
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the risk of filing delays, and
expeditiously beginning the waiting
period for employment authorization
eligibility.
C. Proceedings for Further
Consideration of the Application for
Asylum by USCIS Through Asylum
Merits Interview for Noncitizens With
Credible Fear
In this IFR, consistent with the
NPRM, the Departments are amending
regulations to authorize USCIS asylum
officers to conduct Asylum Merits
interviews for individuals whose cases
are retained for further consideration by
USCIS following a positive credible fear
determination or returned to USCIS if
an IJ vacates an asylum officer’s
negative credible fear finding.28 The
Departments carefully considered the
comments received in response to the
NPRM focused on timelines related to
Asylum Merits interviews, and, in this
IFR, are including regulatory language
clarifying timelines for scheduling
hearings and providing asylum
decisions.
As provided in 8 CFR 208.9(a)(1),
USCIS will not schedule an Asylum
Merits interview for further
consideration of an asylum application
following a positive credible fear
determination fewer than 21 days after
the noncitizen has been served a record
of the positive credible fear
determination, unless the applicant
requests in writing that an interview be
scheduled sooner. The asylum officer
shall conduct the interview within 45
days of the date that the positive
credible fear determination is served on
the noncitizen—i.e., the date the asylum
application is considered filed, see 8
CFR 208.3(a)(2)—subject to the need to
reschedule an interview due to exigent
circumstances. See 8 CFR 208.9(a)(1).
These timelines are consistent with the
INA, which provides that, ‘‘in the
absence of exceptional circumstances,
the initial interview or hearing on the
asylum application shall commence not
later than 45 days after the date an
application is filed.’’ INA
208(d)(5)(A)(ii), 8 U.S.C.
1158(d)(5)(A)(ii).
The nonadversarial Asylum Merits
interview process will provide several
procedural safeguards, such as the
following: (1) The applicant may have
28 In addition to the proposed changes to the DHS
portion of the regulations in the NPRM, the IFR also
includes a similar edit to 8 CFR 1003.42(d)(1). This
edit is intended to ensure consistency with 8 CFR
1003.42 and the proposed edits to 8 CFR
1208.30(g)(2) so that both provisions properly direct
that a case where an IJ vacates a negative credible
fear finding will be referred back to USCIS as
intended by both the NPRM and the IFR.
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counsel or a representative present, may
present witnesses, and may submit
affidavits of witnesses and other
evidence, 8 CFR 208.9(b); (2) the
applicant or applicant’s representative
will have an opportunity to make a
statement or comment on the evidence
presented and the representative will
also have the opportunity to ask followup questions of the applicant and any
witness, 8 CFR 208.9(d)(1); (3) a
verbatim transcript of the interview will
be included in the referral package to
the IJ, with a copy also provided to the
noncitizen, 8 CFR 208.9(f)(2),
1240.17(c); (4) an asylum officer will
arrange for the assistance of an
interpreter if the applicant is unable to
proceed effectively in English, and if a
USCIS interpreter is unavailable, USCIS
will attribute any resulting delay to
USCIS for purposes of eligibility for
employment authorization, 8 CFR
208.9(g); and (5) the failure of a
noncitizen to appear for an interview
may result in the referral of the
noncitizen to section 240 removal
proceedings before an IJ, 8 CFR
208.10(a)(1)(iii), unless USCIS, in its
own discretion, excuses the failure to
appear, 8 CFR 208.10(b)(1). The
Departments believe that these
procedural safeguards will enhance
efficiency and further the expeditious
adjudication of noncitizens’ asylum
claims, while at the same time balancing
due process and fairness concerns. The
protection claims considered in Asylum
Merits interviews will be adjudicated in
a separate queue, apart from
adjudications of affirmative asylum
applications filed directly with USCIS.
Allowing the cases of individuals who
receive a positive credible fear
determination to remain with USCIS for
the Asylum Merits interview, rather
than initially referring the case to an IJ
for an adversarial section 240 removal
proceeding or, as provided for in a
presently enjoined regulation, for an
asylum-and-withholding-only
proceeding,29 will capitalize on the
investment of time and expertise that
USCIS has already made and, for the
subset of cases in which asylum is
granted by USCIS, save investment of
time and resources by EOIR and ICE. It
will also enable meritorious cases to be
resolved more quickly, reducing the
overall asylum system backlogs and
using limited asylum officer and IJ
resources more efficiently. The Asylum
Merits interview process affords
noncitizens a fair opportunity to present
their claims. In addition, noncitizens
29 See Global Asylum rule, 85 FR 80276; supra
note 4 (discussing recent regulations and their
current status).
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who are not granted asylum will be
referred to an immigration court for a
streamlined section 240 removal
proceeding, which means that an IJ will
consider their asylum and, as necessary,
statutory withholding and CAT
protection claims. Overall, these ample
procedural safeguards will ensure due
process, respect human dignity, and
promote equity.
Section 235(b)(1)(B)(ii) of the INA, 8
U.S.C. 1225(b)(1)(B)(ii), authorizes a
procedure for ‘‘further consideration’’ of
asylum applications that is separate
from section 240 removal proceedings.
As the Department of Justice recognized
over two decades ago, ‘‘the statute is
silent as to the procedures for those who
. . . demonstrate a credible fear of
persecution.’’ Inspection and Expedited
Removal of Aliens; Detention and
Removal of Aliens; Conduct of Removal
Proceedings; Asylum Procedures, 62 FR
10312, 10320 (Mar. 6, 1997) (interim
rule). It ‘‘does not specify how or by
whom this further consideration should
be conducted.’’ Inspection and
Expedited Removal of Aliens; Detention
and Removal of Aliens; Conduct of
Removal Proceedings; Asylum
Procedures, 62 FR 444, 447 (Jan. 3,
1997) (proposed rule).
By not specifying what ‘‘further
consideration’’ entails, the statute leaves
it to the Departments to determine.
Under the familiar Chevron framework,
it is well-settled that such ‘‘ambiguity
constitutes an implicit delegation from
Congress to the agency to fill in the
statutory gaps.’’ FDA v. Brown &
Williamson Tobacco Corp., 529 U.S.
120, 159 (2000) (citing Chevron, U.S.A.,
Inc. v. Natural Resources Defense
Council, Inc., 467 U.S. 837, 844 (1984));
see also Epic Sys. Corp. v. Lewis, 138 S.
Ct. 1612, 1629 (2018) (noting that
Chevron rests on ‘‘the premise that a
statutory ambiguity represents an
implicit delegation to an agency to
interpret a statute which it administers’’
(quotation marks and citation omitted)).
An agency may exercise its delegated
authority to plug the gap with any
‘‘reasonable interpretation’’ of the
statute. Chevron, 467 U.S. at 844.
By its terms, the phrase ‘‘further
consideration’’ is open-ended. The fact
that Congress did not specify the nature
of the proceedings for those found to
have a credible fear, see INA
235(b)(1)(B)(ii), 8 U.S.C.
1225(b)(1)(B)(ii), contrasts starkly with
two other provisions in the same section
that expressly require or deny section
240 removal proceedings for certain
other classes of noncitizens. In one
provision, INA 235(b)(2)(A), 8 U.S.C.
1225(b)(2)(A), Congress provided that an
applicant for admission who ‘‘is not
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clearly and beyond a doubt entitled to
be admitted’’ must be ‘‘detained for a
proceeding under [INA 240].’’ And in
another, INA 235(a)(2), 8 U.S.C.
1225(a)(2), Congress provided that ‘‘[i]n
no case may a stowaway be considered
. . . eligible for a hearing under [INA
240].’’ This shows that Congress knew
how to specifically require or prohibit
referral to a section 240 removal
proceeding when it wanted to do so.
‘‘Where Congress includes particular
language in one section of a statute but
omits it in another section of the same
Act, it is generally presumed that
Congress acts intentionally and
purposely in the disparate inclusion or
exclusion.’’ Salinas v. United States
R.R. Ret. Bd., 141 S. Ct. 691, 698 (2021)
(quotation marks and citation omitted).
The D.C. Circuit has ‘‘consistently
recognized that a congressional mandate
in one section and silence in another
often suggests not a prohibition but
simply a decision not to mandate any
solution in the second context, i.e., to
leave the question to agency discretion.’’
Catawba Cnty., N.C. v. EPA, 571 F.3d
20, 36 (D.C. Cir. 2009) (quotation marks
and citation omitted). That Congress’s
silence in section 235(b)(1)(B)(ii) of the
INA, 8 U.S.C. 1225(b)(1)(B)(ii), permits
the Departments discretion to establish
procedures for ‘‘further consideration’’
is reinforced by the fact that the
noncitizens whom DHS has elected to
process using the expedited removal
procedure are expressly excluded from
the class of noncitizens who are
statutorily guaranteed section 240
removal proceedings under section
235(b)(2)(A) of the INA, 8 U.S.C.
1225(b)(2)(A).
If, following an Asylum Merits
interview described in this IFR, USCIS
grants asylum, the individual may be
allowed to remain in the United States
indefinitely with the status of asylee
and eventually may apply for lawful
permanent residence. See INA 208(c)(1),
209(b), 8 U.S.C. 1158(c)(1), 1159(b). If
asylum is not granted, the asylum
officer will refer the application,
together with the appropriate charging
document and the record of the Asylum
Merits interview, for adjudication in
streamlined section 240 removal
proceedings before an IJ. See 8 CFR
208.14(c)(1), 1240.17(a).
The Departments carefully considered
the public comments received in
response to the NPRM and reconsidered
the proposals outlined in the NPRM
related to having USCIS asylum officers
make final decisions regarding statutory
withholding of removal and CAT
protection claims and issue removal
orders. See 86 FR 46917–19. In this IFR,
DHS is amending 8 CFR 208.9(b) to
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18097
provide that, in the case of a noncitizen
whose case is retained by or referred to
USCIS for further consideration through
an Asylum Merits interview, an asylum
officer will also elicit all relevant and
useful information bearing on the
applicant’s eligibility for statutory
withholding of removal or CAT
protection. This IFR further provides in
8 CFR 208.16(a) and (c) that if the
asylum application is not granted, the
asylum officer will determine whether
the noncitizen is eligible for statutory
withholding of removal under 8 CFR
208.16(b) or CAT protection under 8
CFR 208.16(c). Asylum officers will not
issue orders of removal to applicants
who are not granted asylum as proposed
in the NPRM, but rather will refer
applicants who are not granted asylum
to the immigration court for
consideration of their protection claims
in streamlined section 240 removal
proceedings before an IJ. See 8 CFR
208.14(c)(1), 208.16(a). USCIS will not
issue a final decision on an applicant’s
request for statutory withholding of
removal or CAT protection. Rather,
pursuant to new 8 CFR 1240.17(d),
(f)(2)(i)(B), and (i)(2), if an asylum
officer does not grant asylum but
determines the noncitizen is eligible for
statutory withholding of removal or
CAT protection and the IJ does not grant
asylum, the IJ will issue a removal order
and, subject to certain exceptions, give
effect to USCIS’s determination.
If the asylum application includes a
dependent who has not filed a separate
application, the asylum officer will, as
appropriate and prior to referring the
family to streamlined section 240
proceedings before an IJ, elicit
information sufficient to determine
whether there is a significant possibility
that the applicant’s dependent has
experienced or fears harm that would be
an independent basis for protection in
the event that the principal applicant is
not granted asylum. See 8 CFR 208.9(b),
(i). If a spouse or child who was
included in the principal applicant’s
request for asylum does not separately
file an asylum application that is
adjudicated by USCIS, the principal’s
asylum application will be deemed by
EOIR to satisfy EOIR’s application filing
requirements for the spouse or child as
principal applicants. See 8 CFR
208.3(a)(2), 1208.3(a)(2). This provision
will allow any spouse or child in the
streamlined procedure to exercise their
right to seek protection on an
independent basis without the need for
delaying the proceedings to allow for
the preparation and filing of an I–589,
Application for Asylum and for
Withholding of Removal. The
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Departments have determined that these
changes meet the goals of this rule, such
as improving efficiency while allowing
noncitizens to receive a full and fair
opportunity to be heard, and are also
responsive to commenters’ concerns
raised in response to the NPRM, as
detailed in Sections IV.D.5 and 6 of this
preamble. While USCIS will not make
final decisions regarding statutory
withholding of removal and CAT
protection claims and issue removal
orders, it is appropriate for USCIS to
make eligibility determinations
regarding statutory withholding of
removal and protection under the CAT.
As a threshold issue, applications for
asylum, statutory withholding of
removal, and protection under the CAT
are all factually linked. While the legal
standards and requirements differ
among the forms of relief and
protection, the relevant applications
will substantially share the same set of
operative facts that an asylum officer
would have already elicited, including
through evidence and testimony, in the
nonadversarial Asylum Merits
interview. Moreover, asylum officers
receive extensive training, and develop
extensive expertise, in assessing claims
and country conditions, and are
qualified to determine whether an
applicant will face harm in the
proposed country. See INA 235(b)(1)(E),
8 U.S.C. 1225(b)(1)(E); 8 CFR 208.1(b).
Asylum officers also receive training on
the standards and eligibility issues
related to determinations for statutory
withholding of removal and CAT
protection in order to conduct credible
fear screening interviews and make
appropriate credible fear determinations
under 8 CFR 208.30(e). See 8 CFR
208.1(b).
While asylum officers will also not
make final decisions regarding a
dependent’s eligibility for asylum,
statutory withholding of removal, and
CAT protection claims if the dependent
has not received a prior separate
positive credible fear determination or
filed a separate principal asylum
application with USCIS, it is
appropriate for asylum officers to elicit
sufficient information regarding each
dependent’s eligibility for protection in
order to allow for those claims to be on
the record and appropriately considered
should the family be placed into
streamlined section 240 removal
proceedings. In many cases, the family
members will likely substantially share
the same set of operative facts that an
asylum officer would have already
elicited from the principal applicant,
including through evidence and
testimony, during the same
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nonadversarial Asylum Merits
interview. Accordingly, the additional
questioning that will ordinarily be
needed to develop the record enough to
facilitate an IJ’s adjudication of any
claims through streamlined section 240
proceedings is expected to be modest.
Moreover, any dependent who wishes to
be adjudicated as a principal applicant
by USCIS may file a separate
application with USCIS prior to referral
to removal proceedings.
Where a noncitizen’s asylum
application is not granted by USCIS,
automatic referral to streamlined section
240 proceedings—as further discussed
in Section III.D of this preamble—
ensures that the application of the
principal applicant and any family
members may be reviewed by the IJ. In
the streamlined section 240
proceedings, the IJ will adjudicate de
novo the noncitizen’s and any family
members’ applications for asylum and,
if USCIS determined them ineligible for
statutory withholding of removal or
protection under the CAT, such claims
as well. Statutory withholding of
removal and CAT protection are
nondiscretionary forms of protection,
the granting of which is mandatory
upon a showing of eligibility. See, e.g.,
Myrie v. Att’y Gen. United States, 855
F.3d 509, 515–16 (3d Cir. 2017); Benitez
Ramos v. Holder, 589 F.3d 426, 431 (7th
Cir. 2009). Because an asylum officer
does not issue an order of removal
under the IFR, it is appropriate to wait
until the IJ enters the order of removal
before generally giving effect to USCIS’s
statutory withholding of removal and
CAT protection eligibility
determinations. See Matter of I–S– & C–
S–, 24 I&N Dec. 432, 433 (BIA 2008).
D. Streamlined Section 240 Removal
Proceedings Before the Immigration
Judge
Upon careful consideration of the
comments received in response to the
NPRM, as discussed in Section IV of
this preamble, this IFR does not adopt
the IJ review proceedings proposed in
the NPRM. See 86 FR 46946–47 (8 CFR
1003.48, 1208.2(c) (proposed)). Instead,
the Departments will place noncitizens
whose applications for asylum are not
granted by USCIS, as well as any spouse
or children included on the noncitizen’s
application, in section 240 proceedings
that will be streamlined as provided in
new 8 CFR 1240.17. See 8 CFR
1240.17(a), (b). As provided in new 8
CFR 1240.17(a), IJs must conduct these
proceedings in accordance with the
procedures and requirements set forth
in section 208 of the Act, 8 U.S.C. 1158.
Currently, further consideration of an
asylum application by an individual in
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expedited removal is done through
section 240 proceedings. See, e.g., 8 CFR
208.30(f) (2020); 30 8 CFR part 1240,
subpart A (2020). Such proceedings
follow issuance of an NTA, which
informs the noncitizen of DHS’s charges
of inadmissibility or removability, INA
239(a)(1), 8 U.S.C. 1229(a)(1), and these
proceedings provide an opportunity for
the noncitizen to make his or her case
to an IJ, INA 240(a)(1), 8 U.S.C.
1229a(a)(1). Parties in section 240
removal proceedings have a wide range
of well-established rights, including the
following: The right to representation at
no expense to the Government, INA
240(b)(4)(A), 8 U.S.C. 1229a(b)(4)(A); a
reasonable opportunity to examine
evidence, present evidence, and crossexamine witnesses, INA 240(b)(4)(B), 8
U.S.C. 1229a(b)(4)(B); the right to seek
various forms of relief, 8 CFR
1240.1(a)(1)(ii)–(iii); the right to file a
motion to continue, 8 CFR 1003.29; and
the right to appeal specified decisions to
the BIA, 8 CFR 1003.3(a), 1003.38(a),
and to later file a petition for review in
the appropriate U.S. Court of Appeals,
INA 242, 8 U.S.C. 1252.
Under the IFR, USCIS will have
authority to adjudicate asylum claims
brought by noncitizens subject to
expedited removal and found to have a
credible fear of persecution or torture
rather than immediately referring such
cases for adjudication by IJs in section
240 removal proceedings. The
Departments have determined that
noncitizens who subsequently are not
granted asylum by USCIS should be
referred to section 240 removal
proceedings that will be streamlined as
described in new 8 CFR 1240.17. The
well-established rights that apply in
section 240 proceedings will continue to
apply during the 240 proceedings
described in new 8 CFR 1240.17, but the
latter will include new procedures
designed to streamline the process
while continuing to ensure fairness.
The Departments believe that these
cases can be adjudicated more
expeditiously than other cases in
section 240 removal proceedings.
Unlike other cases, noncitizens subject
to this IFR will have had a full
opportunity to present their protection
claims to an asylum officer. Moreover,
as established in new 8 CFR 1240.17(c)
and (e), IJs and parties in any
subsequent streamlined section 240
removal proceedings will have the
benefit of a fully developed record and
30 The Global Asylum rule would have revised
the process, placing such noncitizens into asylumand-withholding-only proceedings instead of
section 240 proceedings, see 85 FR 80276, but it
was enjoined, see supra note 4.
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decision prepared by USCIS.31 Because
the USCIS Asylum Merits interview will
create a record that includes testimony
and documentary evidence, the
Departments believe that less time will
be needed in immigration court
proceedings to build the evidentiary
record. Thus, cases will be resolved
more expeditiously before the IJ. The
Departments recognize that, in some
instances, IJs may need to take
additional testimony and evidence—
beyond what is contained in the USCIS
record—to fully develop the record. See,
e.g., 8 CFR 1240.17(f)(4)(iii). By
providing IJs with the ability to rely
upon the previously developed record
in most cases, while preserving the
flexibility for IJs to take new evidence
and testimony when warranted, without
the additional motions practice
contemplated by the NPRM’s
provisions, the IFR creates more
streamlined, efficient adjudications
overall. Accordingly, the Departments
believe that it is possible to achieve the
purposes of the NPRM—to increase
efficiency and maintain procedural
fairness—by making procedural changes
to streamline existing 240 proceedings
instead of establishing the IJ review
proceedings proposed under the NPRM.
In keeping with this goal, the IFR
provides that these section 240
proceedings will be subject to particular
procedural requirements designed to
streamline the overall process and take
advantage of the record created by the
asylum officer while still providing
noncitizens with a full and fair
opportunity to present testimony and
evidence in support of their claims.
Where the IJ would not be able to take
advantage of that record, the
streamlining measures do not apply.
Thus, new 8 CFR 1240.17(k) exempts
certain cases from the streamlined
process, including, for example, where
the respondent has produced evidence
of prima facie eligibility for relief or
protection other than asylum, statutory
withholding of removal, CAT
protection, or voluntary departure, 8
CFR 1240.17(k)(2); where the
respondent has raised a substantial
defense to the removal charge,32 8 CFR
31 New 8 CFR 1240.17(c) provides that DHS will
serve the record of proceedings for the Asylum
Merits interview and the asylum officer’s written
decision on the respondent and on the immigration
court no later than the date of the master calendar
hearing; it further provides that, in the exceptional
case in which service is not effectuated by that date,
the schedule of proceedings pursuant to new 8 CFR
1240.17(f) will be delayed until service is
effectuated.
32 As stated in note 8, supra, the rule does not
specify that a particular type of evidence is required
in order to show prima facie eligibility for relief,
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1240.17(k)(3); or where the designated
country of removal is different from the
one that the asylum officer considered
in adjudicating the noncitizen’s
application for asylum or protection, 8
CFR 1240.17(k)(4).33 New 8 CFR
1240.17(k) makes other exceptions for
certain vulnerable noncitizens and it
exempts cases that have been reopened
or remanded. See 8 CFR 1240.17(k)(1),
(5), (6). Accordingly, with these
exceptions, the Departments believe that
these proceedings can be expedited
given the limited forms of relief and
protection that will need to be
adjudicated by the IJ and given that the
IJ and the parties will benefit from the
record developed before USCIS.
The IFR provides additional
procedures that will contribute to
efficient adjudication. As provided in
revised 8 CFR 208.3(a)(2) and 8 CFR
1208.3(a)(2) and new 8 CFR 1240.17(e),
the IFR treats the record underlying the
positive credible fear determination as
the noncitizen’s asylum application, as
well as an asylum application for any
spouse or child included as a dependent
on the application for purposes of
EOIR’s filing requirements if USCIS
does not grant the principal applicant’s
application and if the spouse or child
does not separately file an asylum
application that is adjudicated by
USCIS. This procedure obviates the
need for the noncitizen and any
dependent to prepare and file a new
application before the IJ. IJs are also
required to hold status conferences to
identify and narrow issues under new 8
CFR 1240.17(f)(1), (2). The USCIS
Asylum Merits interview record and
decision will permit the parties and the
and such evidence could include testimonial
evidence as well as documentary evidence.
33 Under this IFR, a noncitizen’s accompanying
spouse and children may be included in the request
for asylum if they were included in the credible fear
determination. See 8 CFR 208.3(a)(2), 208.30(c).
Where a noncitizen is accompanied by a spouse or
children, and the noncitizen is found to have a
credible fear of persecution or torture, the family
has the choice to have the spouse and children be
included as dependents on the asylum application
or to separately seek asylum as principal applicants.
See 8 CFR 208.3(a)(2), 208.30(c). Should the family
choose to have the spouse and children proceed
solely as dependents, the asylum officer will, as
appropriate, elicit sufficient information to
determine whether there is a significant possibility
that the applicant’s spouse or child has experienced
or fears harm that would be an independent basis
for protection in the event that the principal
applicant is not granted asylum prior to referring
the family to the IJ for a hearing. See 8 CFR
208.9(b), (i). If a spouse or child who was included
in the principal applicant’s request for asylum does
not separately file an asylum application that is
adjudicated by USCIS, the principal’s asylum
application will be deemed by EOIR to satisfy
EOIR’s application filing requirements for the
spouse or child as principal applicants. See 8 CFR
1208.3(a)(2).
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IJ to identify any errors or omissions in
the record, narrow issues, and provide
any additional bases for asylum or
related protection. Specifically, the rule,
as provided in new 8 CFR 1240.17(f)(2)
and (3), imposes obligations on the
parties to identify and narrow the issues
prior to the merits hearing, although the
obligations on the noncitizen depend on
whether the noncitizen has
representation. As provided by new 8
CFR 1240.17(f)(2)(ii)(A), DHS must state
whether it intends to rest on the existing
record, waive cross-examination of the
respondent, otherwise participate in the
proceedings before the IJ, or waive
appeal in the event the IJ grants
protection. This position may be
retracted by DHS, orally or in writing,
prior to the issuance of the IJ’s decision,
if DHS seeks consideration of evidence
pursuant to the standard laid out in 8
CFR 1240.17(g)(2). See 8 CFR
1240.17(f)(2)(ii)(C). Moreover, if DHS
indicates that it will participate in the
case, at the status conference or via a
subsequent written statement it shall
state its position on the respondent’s
claim(s); state which elements of the
respondent’s claim(s) it is contesting
and which facts it is disputing, if any,
and provide an explanation of its
position; identify any witnesses it
intends to call; provide any additional
non-rebuttal or non-impeachment
evidence; and state the status of the
identity, law enforcement, or security
investigations or examinations required
by section 208(d)(5)(A)(i) of the Act, 8
U.S.C. 1158(d)(5)(A)(i), and 8 CFR
1003.47. See 8 CFR 1240.17(f)(2)(ii),
(f)(3). If DHS does not timely respond,
either at the status conference or in its
written statement, to one or more of the
respondent’s arguments or claimed
bases for asylum, including which
arguments raised by the respondent
DHS is disputing and which facts it is
contesting, the IJ has authority to deem
those arguments or claims unopposed,
provided, however, that DHS may
respond at the merits hearing to any
arguments or claimed bases for asylum
first advanced by the respondent after
the status conference. See 8 CFR
1240.17(f)(3)(i). The IFR creates
additional efficiencies by permitting IJs
to decide applications on the
documentary record in certain
circumstances, including where neither
party has elected to present testimony
and DHS has not elected to crossexamine the noncitizen or where the IJ
determines that the application can be
granted without further testimony and
DHS declines to cross-examine the
noncitizen. See 8 CFR 1240.17(f)(4)(i),
(ii). Notwithstanding these provisions,
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however, the IJ shall hold a hearing if
the IJ decides that a hearing is necessary
to fulfill the IJ’s duty to fully develop
the record. See id.
The IFR also gives appropriate effect
to the asylum officer’s determination of
a noncitizen’s eligibility for statutory
withholding of removal or protection
under the CAT. This serves to increase
efficiency and provides a safeguard
where an asylum officer has already
found that the noncitizen could be
subject to persecution or torture if
removed. In general, in cases where the
IJ denies asylum and issues a removal
order, the IJ will give effect to the
asylum officer’s determination of
eligibility for statutory withholding of
removal or protection under the CAT;
the IJ may not sua sponte review the
asylum officer’s determination. See 8
CFR 1240.17(d), (f)(2)(i)(B), (i)(2).
However, these provisions account for
the possibility that DHS may submit
evidence or testimony that specifically
pertains to the respondent and that was
not included in the record of
proceedings for the USCIS Asylum
Merits interview in order to demonstrate
that the respondent is not eligible for
the protection(s) the asylum officer
determined. See id. In such a case, the
IJ will, based on the review of this new
evidence or testimony, make a separate
determination regarding the
noncitizen’s eligibility for statutory
withholding of removal or protection
under the CAT, as relevant.
1. Schedule of Proceedings
The Departments are imposing
procedural adjudication time frames
and limitations on continuances and
filing extensions during streamlined
section 240 removal proceedings under
this IFR. The Departments believe that
these time frames and limitations are
justified given both the streamlining
procedures discussed above and the fact
that such cases will come to the IJ with
a complete asylum application and
following a nonadversarial interview
before an asylum officer at which a
comprehensive record, including a
verbatim transcript and decision, has
been assembled.
Under new 8 CFR 1240.17, the
Departments will impose procedural
time frames on IJs with respect to their
hearing schedules. Specifically, an IJ
will hold a master calendar hearing 30
days after service of the NTA or, if a
hearing cannot be held on that date, on
the next available date no later than 35
days after service. As provided by new
8 CFR 1240.17(f)(1) and (2), the IJ will
hold a status conference 30 days after
the master calendar hearing or, if a
status conference cannot be held on that
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date, on the next available date no later
than 35 days after the master calendar
hearing, followed by a merits hearing, if
necessary, 60 days after the master
calendar hearing or, if a hearing cannot
be held on that date, on the next
available date no later than 65 days after
the master calendar hearing.34 If needed,
under new 8 CFR 1240.17(f)(4)(iii), the
IJ may hold a subsequent merits hearing
to resolve any lingering issues or
complete testimony no later than 30
days after the initial merits hearing. As
further discussed below, the IJ may
grant continuances and filing extensions
under specified standards. See 8 CFR
1240.17(h). Finally, under 8 CFR
1240.17(f)(5), whenever practical, the IJ
shall issue an oral decision on the date
of the final merits hearing or, if the IJ
determines that no such hearing is
warranted, no more than 30 days after
the status conference; and where
issuance of an oral decision on such
date is not practicable, the IJ shall issue
an oral or written decision as soon as
practicable, no later than 45 days after
the final merits hearing or, if the IJ
concludes that no hearing is necessary,
no later than 75 days after the status
conference.35
The combined effect of these
provisions should fully achieve the
NPRM’s efficiency goals while allowing
noncitizens to receive a full and fair
hearing in streamlined section 240
removal proceedings rather than
through the IJ review process
contemplated by the NPRM. The wellestablished rights that apply in ordinary
section 240 proceedings will continue to
apply during the streamlined section
240 proceedings described in new 8
CFR 1240.17, but certain new
procedures will streamline the process
by taking advantage of the record
created by the asylum officer and ensure
a prompt, efficient, and fair hearing on
the respondent’s claim.
34 Because the timing of the merits hearing is tied
to the date that the status conference occurs, the
Departments note that any delay of the status
conference will necessarily result in a
corresponding delay of the merits hearing. In other
words, if the status conference occurs 45 days after
the master calendar hearing rather than 30–35 days
after it because, for example, the respondent
requested a continuance to seek counsel or the
immigration court had to close on the original date
of the status conference, see 8 CFR 1240.17(h), the
merits hearing would still occur 30–35 days after
the status conference—on days 75–80.
35 In other words, where it is not practicable to
issue an oral decision on the date of the final merits
hearing, the immigration judge has up to 45 days
to issue a decision. Where an IJ has determined that
a merits hearing is not necessary, and it is not
practicable to issue a decision within 30 days after
the status conference, the IJ has up to an additional
45 days within which to issue a decision.
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a. Pre-Hearing Procedures
In order to best prepare the case for
adjudication, new 8 CFR 1240.17(f)
establishes initial procedures to ensure
that the IJ has a complete picture of the
case and the relevant issues prior to
conducting any merits hearing that may
be needed. As provided in new 8 CFR
1240.17(f)(1), at the master calendar
hearing, the IJ will perform the
functions required by 8 CFR 1240.10(a),
including advising the respondent of the
right to be represented, at no expense to
the Government, by counsel of the
respondent’s own choosing. See 8 CFR
1240.17(f)(1). Additionally, the IJ will
advise as to the nature of the
streamlined section 240 removal
proceedings, including that the
respondent has pending applications for
asylum, statutory withholding of
removal, and withholding or deferral of
removal under the CAT, as appropriate;
that the respondent has the right to
testify, call witnesses, and present
evidence in support of these
applications; and of the deadlines that
govern the submission of evidence. See
id. Finally, except where the noncitizen
is ordered removed in absentia, at the
conclusion of the master calendar
hearing the IJ will schedule a status
conference to take place 30 days after
the master calendar hearing or, if
necessary, on the next available hearing
date no later than 35 days after the
master calendar hearing. See id. The IJ
will also advise as to the requirements
for the status conference. See id. The
adjournment of the case until the status
conference will not be considered a
noncitizen-requested continuance under
new 8 CFR 1240.17(h)(2). See id.
The purpose of the status conference
is to take pleadings, identify and narrow
any issues, and determine whether the
case can be decided on the documentary
record alone or, if a merits hearing
before the IJ is needed, to ready the case
for such a hearing. See 8 CFR
1240.17(f)(2). In general, the
Departments expect that the parties will
use the record of the Asylum Merits
interview as a tool to prepare the
proceeding for the IJ’s adjudication. See
id.
At the status conference, the
noncitizen must indicate, orally or in
writing, whether the noncitizen intends
to contest removal or seek any
protection(s) for which the asylum
officer did not determine the noncitizen
eligible. See 8 CFR 1240.17(f)(2)(i). The
IJ will also advise the noncitizen that
the respondent has the right to testify,
call witnesses, and present evidence in
support of the noncitizen’s application;
and of the deadlines that govern the
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submission of evidence. If a noncitizen
expresses an intent to contest removal
or seek protection for which the asylum
officer did not determine the noncitizen
eligible, the noncitizen must, orally or
in writing: (1) Indicate whether the
noncitizen plans to testify before the IJ;
(2) identify any witnesses the noncitizen
plans to call at the merits hearing; and
(3) provide any additional
documentation in support of the
applications. See 8 CFR
1240.17(f)(2)(i)(A). A represented
noncitizen is further required to: (4)
Describe any alleged errors or omissions
in the asylum officer’s decision or the
record of proceedings before the asylum
officer; (5) articulate or confirm any
additional bases for asylum and related
protection, whether or not they were
presented or developed before the
asylum officer; and (6) state any
additional requested forms of relief or
protection. If a noncitizen is
unrepresented, the IJ will ask questions
and guide the proceedings in order to
elicit relevant information from the
noncitizen and otherwise fully develop
the record. See Quintero v. Garland, 998
F.3d 612, 623–30 (4th Cir. 2021)
(describing the general duty of the IJ to
develop the record, which is ‘‘especially
crucial in cases involving unrepresented
noncitizens’’); see also Matter of
S–M–J–, 21 I&N Dec. 722, 723–24, 729
(BIA 1997) (en banc) (also describing the
general duty of the IJ to develop the
record). If a noncitizen does not express
an intent to contest removal or seek
protection for which the asylum officer
did not determine the noncitizen
eligible, the IJ will order the noncitizen
removed and will not conduct further
proceedings. See 8 CFR
1240.17(f)(2)(i)(B). In such cases, where
the asylum officer determined the
noncitizen eligible for statutory
withholding of removal or protection
under the CAT, the IJ will issue a
removal order and will give effect to
that protection, unless DHS makes a
prima facie showing—through evidence
that specifically pertains to the
noncitizen and that was not included in
the record of proceedings for the USCIS
Asylum Merits interview—that the
noncitizen is not eligible for such
protection. See id.
For its part, DHS must indicate at the
status conference, orally or in writing,
whether it intends to: (1) Rest on the
record; (2) waive cross-examination of
the noncitizen; (3) otherwise participate
in the case; or (4) waive appeal if the IJ
decides to grant the noncitizen’s
application. See 8 CFR 1240.17(f)(2)(ii).
If DHS indicates that it will participate
in the case, it then must, orally or in
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writing: (1) State its position on each of
the noncitizen’s claimed grounds for
asylum or related protection; (2) state
which elements of the noncitizen’s
claim for asylum or related protection it
is contesting and which facts it is
disputing, if any, and provide an
explanation of its position; (3) identify
any witnesses it intends to call at any
merits hearing; (4) provide any
additional non-rebuttal or nonimpeachment evidence; and (5) state
whether the appropriate identity, law
enforcement, or security investigations
or examinations have been completed.
See id. DHS can provide this
information at the status conference or
by submitting a written statement under
8 CFR 1240.17(f)(3)(i) as outlined below.
See id.
At the status conference, as further
detailed below, the IJ will determine
whether further proceedings are
warranted; if they are, the IJ will
schedule the merits hearing to take
place 60 days after the master calendar
hearing or, if the merits hearing cannot
be held on that date, on the next
available date no later than 65 days after
the master calendar hearing. See 8 CFR
1240.17(f)(2). The IJ may also schedule
additional status conferences prior to
any merits hearing if the IJ determines
such conferences will contribute to
efficient resolution of the case. See id.
After the adjournment of the status
conference, where DHS intends to
participate in a case, DHS is required to
file a written statement providing
information required under 8 CFR
1240.17(f)(2)(ii) but that DHS did not
provide at the status conference, as well
as any other relevant information or
argument in response to the noncitizen’s
submissions. See 8 CFR 1240.17(f)(3)(i).
DHS’s written statement is due no later
than 15 days prior to the scheduled
merits hearing or, if the IJ determines
that no such hearing is warranted, no
later than 15 days following the status
conference. See id. The noncitizen may
also submit a supplemental filing after
the status conference to reply to any
statement submitted by DHS, identify
any additional witnesses, and provide
any additional documentation in
support of the respondent’s application.
See 8 CFR 1240.17(f)(3)(ii). Any such
filing is due no later than 5 days prior
to the scheduled merits hearing or, if the
IJ determines that no such hearing is
warranted, no later than 25 days
following the status conference. See id.
The IFR’s efficiencies and timeline are
predicated on the parties’ participation
in the status conference and other
procedural steps needed to narrow the
issues and prepare the case for
adjudication in advance of any merits
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18101
hearing before an IJ. This rule helps
‘‘ensure efficient adjudication by
focusing the immigration courts’ limited
resources on the issues that the parties
actually contest.’’ Matter of A–C–A–A–,
28 I&N Dec. 351, 352 (A.G. 2021). In this
regard, as described above, DHS ICE
Office of the Principal Legal Advisor
attorneys representing DHS in
immigration court (‘‘DHS attorneys’’)
play a critical role in narrowing the
issues during section 240 removal
proceedings. The Departments believe
that the rule’s requirements will
increase the overall efficiency of case
adjudications and help parties better
prepare their respective positions before
the IJ.
b. Merits Hearing(s)
Based on the parties’ statements and
submissions at the status conference,
the IJ will determine whether the
noncitizen’s application may be decided
on the documentary record without a
merits hearing or whether a merits
hearing is required. See 8 CFR
1240.17(f)(4)(i)–(iii). Specifically, an IJ
may decline to hold a merits hearing
and decide the application on the
documentary record if: (1) DHS has
indicated that it waives crossexamination and neither the noncitizen
nor DHS has requested to present
testimony under the pre-hearing
procedures described above, see 8 CFR
1240.17(f)(4)(i); or (2) the noncitizen has
timely requested to present testimony
and DHS has indicated that it waives
cross-examination and does not intend
to present testimony or produce
evidence, and the IJ concludes that the
asylum application can be granted
without further testimony, see 8 CFR
1240.17(f)(4)(ii). Notwithstanding these
provisions, the IJ shall hold a hearing if
the IJ decides that a hearing is necessary
to fulfill the IJ’s duty to fully develop
the record. See 8 CFR 1240.17(f)(4)(i),
(ii).36
36 The Departments emphasize that permitting the
IJ to issue decisions in some cases without holding
a hearing does not undermine the fairness or
integrity of asylum proceedings because the
respondent will already have testified, under oath,
before the asylum officer. The IFR’s framework only
allows for the IJ to render a decision without
scheduling a hearing in a manner that would not
prejudice the noncitizen or undermine the integrity
of asylum proceedings.
In Matter of Fefe, 20 I&N Dec. 116 (BIA 1989), the
BIA held that ‘‘[a]t a minimum . . . the regulations
require that an applicant for asylum and
withholding take the stand, be placed under oath,
and be questioned as to whether the information in
the written application is complete and correct.’’ Id.
at 118. The BIA determined that the regulations
required these procedures for fairness reasons and
to maintain ‘‘the integrity of the asylum process
itself.’’ Id. The provisions in this IFR that permit IJs
to decide applications without a hearing in certain
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If the IJ determines to hold a merits
hearing, the IJ will conduct that hearing
as in section 240 removal proceedings
generally. The IJ will swear the
noncitizen to the truth and accuracy of
any information or statements, hear all
live testimony requested by the parties,
and consider the parties’ submissions.
See 8 CFR 1240.17(f)(4)(iii)(A).
The Departments’ goal is for the IJ to
issue an oral decision at the conclusion
of a single merits hearing (when a merits
hearing is required) whenever
practicable, see 8 CFR
1240.17(f)(4)(iii)(A), (f)(5), but the
Departments recognize that not every
case may be resolved in that fashion.
The rule therefore allows the IJ
flexibility in such circumstances to hold
another status conference and take any
other steps the IJ considers necessary
and efficient for the resolution of the
case. See 8 CFR 1240.17(f)(4)(iii)(B). In
all circumstances, the IJ will be required
to schedule any subsequent merits
hearing no later than 30 days after the
initial merits hearing. Id.
2. Evidentiary Standard
This IFR provides that, in the
streamlined section 240 proceedings,
noncitizens and DHS will have the
opportunity to address alleged errors in
the USCIS Asylum Merits record,
present testimony, and submit
additional evidence. The longstanding
evidentiary standard for section 240
proceedings applies—evidence must be
relevant and probative, and its use must
be fundamentally fair. 8 CFR
1240.17(g)(1); see 8 CFR 1240.7(a) (‘‘The
immigration judge may receive in
evidence any oral or written statement
that is material and relevant to any issue
in the case . . . .’’); Nyama v. Ashcroft,
357 F.3d 812, 816 (8th Cir. 2004) (‘‘The
traditional rules of evidence do not
apply to immigration proceedings . . . .
‘The sole test for admission of evidence
is whether the evidence is probative and
its admission is fundamentally fair.’ ’’
(citations omitted) (citing Henry v. INS,
74 F.3d 1, 6 (1st Cir. 1996); quoting
Espinoza v. INS, 45 F.3d 308, 310 (9th
Cir. 1995))); Matter of Ramirez-Sanchez,
17 I&N Dec. 503, 505 (BIA 1980)
(holding that evidence must be
‘‘relevant and probative and its use not
fundamentally unfair’’). In addition, any
evidence submitted must be timely
(after taking into account a timely
request for a continuance or filing
extension that is granted), see 8 CFR
circumstances do not raise the same concerns that
animated the BIA’s decision in Matter of Fefe,
including because the cases covered by the IFR
involve noncitizens who have already received a
hearing on their asylum and protection claims
before an asylum officer.
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1240.17(g)(1), subject to certain
exceptions, see 8 CFR 1240.17(g)(2).
Evidence submitted after the deadline
set by the IJ but before the IJ issues a
decision in the case may be considered
only if it could not reasonably have
been obtained and presented before the
applicable deadline through the exercise
of due diligence, or it its exclusion
would violate a statute or the
Constitution.37 See id. As in all section
240 proceedings, the IJ will exclude
evidence that does not meet the
requirements described above. See 8
CFR 1240.17(g)(1).
The Departments are not adopting the
NPRM’s proposal that noncitizens
seeking to submit additional evidence
for IJ review would have to demonstrate
that it was not duplicative and was
necessary to develop the record. Instead,
the Departments believe the IFR’s
provisions will promote efficiency and
fairness by allowing the parties and
adjudicators to apply longstanding,
workable evidentiary standards. The
Departments believe that the NPRM’s
efficiency goals can be achieved in the
context of streamlined section 240
removal proceedings without the
NPRM’s evidentiary restrictions
because, unlike individuals in ordinary
section 240 removal proceedings,
noncitizens whose cases are subject to
this rule will already have received an
initial adjudication by USCIS, and their
case will come to the immigration court
with a fully developed record.
3. Timeline for Proceedings
As noted in the NPRM, the
Departments’ purpose for conducting
rulemaking on this topic is to develop
a ‘‘better and more efficient’’ system for
processing applications for asylum and
related relief brought by individuals
subject to expedited removal under
section 235 of the Act, 8 U.S.C. 1225. 86
FR 46907. Under the current
procedures, individuals who are first
placed in the expedited removal process
but who are subsequently found to have
a credible fear of persecution or torture
are placed in section 240 removal
proceedings before the immigration
court. 8 CFR 208.30(f) (2020). Under
existing procedures, these proceedings
often take several years to complete and
can be highly protracted and inefficient.
Further, as stated in the NPRM, the
current system was created at a time
when most noncitizens encountered at
the border were single adults from
37 In addition, as described below, under new 8
CFR 1240.17(h), a party may seek to have an
extension of a filing deadline. For example, a party
may seek to have a filing deadline extended if there
is an unexpected delay in receipt of the evidence
from a medical practitioner or other party.
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Mexico, relatively few of whom made
asylum claims. See 86 FR 46908. In
contrast, at present, a large share of
noncitizens encountered at the border
are families and unaccompanied
children, a significant portion of whom
express the intention to seek asylum.
See id.
Given the above, the IFR establishes
the timeline and procedures detailed
below to apply in all cases subject to the
streamlined section 240 removal
proceedings. The Departments believe
that these procedures serve important
efficiency interests while still
permitting noncitizens an appropriate
amount of time to prepare for
proceedings.
Immigration court proceedings
commence when DHS files the NTA,
and the master calendar hearing will
take place 30 days after the date the
NTA is served or, if a hearing cannot be
held on that date, on the next available
date no later than 35 days after service.
See 8 CFR 1240.17(b). Except where the
noncitizen is ordered removed in
absentia, the IJ will then schedule a
status conference 30 days after the
initial master calendar hearing or, if a
status conference cannot be held on that
date, on the next available date no later
than 35 days after the master calendar
hearing. See 8 CFR 1240.17(f)(1). From
there, if warranted, the merits hearing
will be scheduled 60 days after the
master calendar hearing or, if a hearing
cannot be scheduled on that date, on the
next available date no later than 65 days
after the master calendar hearing. See 8
CFR 1240.17(f)(2). If any subsequent
merits hearing is necessary, the IJ will
schedule it no later than 30 days after
the initial merits hearing. See 8 CFR
1240.17(f)(4)(iii)(B). Finally, whenever
practicable, the IJ shall issue an oral
decision on the date of the final merits
hearing or, if no such hearing is held, 30
days after the status conference. See 8
CFR 1240.17(f)(4)(iii)(A), (f)(5). If the IJ
cannot issue a decision on that date, the
IJ must issue an oral or written decision
as soon as practicable and no later than
45 days after the applicable date
described in the previous sentence. See
8 CFR 1240.17(f)(5).
Under the default timeline set forth in
the IFR, at least 90 days is provided
from the service of the NTA before the
merits hearing for the noncitizen to
secure counsel, obtain evidence, and
otherwise prepare—in addition to the
time the noncitizen had to secure
counsel and obtain evidence leading up
to the Asylum Merits interview. See
Matter of C–B–, 25 I&N Dec. 888, 889
(BIA 2012) (holding that ‘‘the [IJ] must
grant a reasonable and realistic period of
time to provide a fair opportunity for a
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noncitizen to seek, speak with, and
retain counsel’’). Moreover, as discussed
below, 8 CFR 1240.17(h) contemplates
continuances and filing extensions by
request of the parties. The Departments
believe these time frames, including the
standards for continuances and
extensions, ensure adequate time and
protect procedural fairness while also
meeting the Department’s goal of
creating efficient and streamlined
proceedings. Unlike in ordinary section
240 removal proceedings, noncitizens in
these streamlined section 240
proceedings will already have had an
incentive and time to obtain
representation prior to the
commencement of immigration court
proceedings. Similarly, noncitizens will
not be appearing in immigration court
on a totally blank slate; they will have
had notice regarding what sort of
evidence is needed and a prior
opportunity to obtain any available
evidence ahead of the Asylum Merits
interview. In addition, where a
noncitizen is placed in removal
proceedings under the procedures in the
IFR, the noncitizen will have already
applied before USCIS for asylum,
withholding of removal, and protection
under the CAT, as relevant. The
noncitizen will have had the
opportunity to testify before, and submit
evidence to, the asylum officer, and the
asylum officer will have fully evaluated
the noncitizen’s eligibility for asylum,
withholding of removal, and protection
under the CAT. Moreover, any
dependent would have also had the
opportunity to testify before the asylum
officer, and the asylum officer would
have elicited testimony from the
dependent for any independent basis for
eligibility for asylum, withholding of
removal, and protection under the CAT.
The IJ will be provided with the record
before USCIS, including the asylum
officer’s decision, the verbatim
transcript of the Asylum Merits
interview, and the evidence on which
the asylum officer relied in reaching the
decision. In the Departments’ view, it is
appropriate for cases under this IFR to
proceed on an expedited time frame
before the immigration courts as claims
will have been significantly developed
and analyzed before the proceedings
start.
4. Continuances and Filing Extensions
The IFR establishes modified
standards for continuances and filing
extensions in streamlined 240
proceedings. Generally, in immigration
proceedings, a noncitizen may file a
motion for continuance for good cause
shown. See 8 CFR 1003.29. The
regulations have incorporated this
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‘‘good cause’’ standard since 1987, see
8 CFR 3.27 (1987),38 and substantial
case law and agency guidance have
elaborated on its meaning, see, e.g.,
Matter of L–A–B–R–, 27 I&N Dec. 405,
413–19 (A.G. 2018) (clarifying the
framework for applying the ‘‘good
cause’’ standard when a noncitizen
requests a continuance to pursue
collateral relief); Matter of Hashmi, 24
I&N Dec. 785, 790 (BIA 2009) (setting
forth factors for consideration when
determining whether there is good cause
for a continuance so that a noncitizen
may pursue adjustment of status before
USCIS); Matter of Garcia, 16 I&N Dec.
653, 657 (BIA 1978) (holding that, in
general, IJs should favorably exercise
discretion to continue proceedings
when a prima facie approvable visa
petition and adjustment application are
submitted); Usubakunov v. Garland, 16
F.4th 1299, 1305 (9th Cir. 2021)
(holding that the denial of a noncitizen’s
motion for a continuance to permit his
attorney to be present at his merits
hearing amounted to a violation of his
statutory right to counsel). The
Departments believe that good cause
remains an appropriate standard for
most continuances because it provides
IJs with sufficient guidance and
discretion to manage their cases both
fairly and efficiently, and the IFR adopts
this standard as the default for
continuance requests by noncitizens in
streamlined section 240 proceedings,
subject to certain restrictions described
below.
Specifically, the IFR imposes limits
on the length of continuances that may
be granted for good cause. First, no
individual continuance for good cause
may exceed 10 days unless the IJ
determines that a longer continuance
would be more efficient. See 8 CFR
1240.17(h)(2)(i). This will ensure that
continuances do not delay proceedings
unnecessarily, either by being too long
or too short. The Departments recognize
that, on occasion, it may be appropriate
and more efficient to grant one lengthier
continuance to achieve its intended
38 See also Aliens and Nationality; Rules of
Procedure for Proceedings Before Immigration
Judges, 52 FR 2931, 2934, 2938 (Jan. 29, 1987) (final
rule). The regulation at 8 CFR 3.27 has been
redesignated twice—first to 8 CFR 3.29, second to
its current location at 8 CFR 1003.29—without
amending the regulatory text. See Executive Office
for Immigration Review; Rules of Procedures, 57 FR
11568, 11569 (Apr. 6, 1992) (interim rule); Aliens
and Nationality; Homeland Security;
Reorganization of Regulations, 68 FR 9824, 9830
(Feb. 28, 2003) (final rule). The regulatory text was
recently amended by ‘‘Procedures for Asylum and
Withholding of Removal,’’ 85 FR 81698, 81699,
81750 (Dec. 16, 2020) (final rule), but that rule has
been preliminarily enjoined, see Order at 1, Nat’l
Immigrant Justice Ctr. v. EOIR, No. 21–cv–56
(D.D.C. Jan. 14, 2021).
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purpose—for example, to gather
evidence that will take time to obtain or
to secure the availability of a witness—
such that it would not be necessary to
grant further continuances at the time
that the proceedings are scheduled to
reconvene. Cf. Meza Morales v. Barr,
973 F.3d 656, 665 (7th Cir. 2020)
(Barrett, J.) (‘‘ ‘[T]imeliness’ is not a hard
and fast deadline; some cases are more
complex and simply take longer to
resolve. Thus, not all mechanisms that
lengthen the proceedings of a case
prevent ‘timely’ resolution. That is
presumably why nobody appears to
think that continuances conflict with
the regulation’s timeliness
requirement.’’). Thus, this IFR provides
IJs with sufficient flexibility to grant
continuances for good cause to ensure
fairness of proceedings while
appropriately balancing efficiency
considerations.
Second, the IFR also establishes two
modified continuance procedures that
govern in specific factual circumstances
unique to streamlined section 240
removal proceedings. The Departments
believe that the IFR’s streamlined
section 240 proceedings warrant
modified standards for continuances
under certain conditions because the
IFR’s streamlined 240 proceedings occur
after noncitizens have had a
nonadversarial hearing before an asylum
officer and have had a chance to present
their claims for asylum and protection
from removal. Additionally, the
Departments have a considerable
interest in developing an efficient
process to fully and fairly adjudicate the
claims of those noncitizens who were
initially screened for expedited removal
but have demonstrated a credible fear of
persecution or torture. As noted in the
NPRM, section 235 of the Act, 8 U.S.C.
1225, developed a system that ‘‘was
initially designed for protection claims
to be the exception, not the rule, among
those encountered at or near the
border.’’ 86 FR 46909. Accordingly, the
IFR’s imposition of modified
requirements for continuances in
streamlined section 240 removal
proceedings is in keeping with the
NPRM’s purpose to develop more fair
and efficient processes to adjudicate the
claims of individuals encountered at or
near the border and found to have a
credible fear of persecution or torture.
Specifically, the IFR provides that IJs
should apply the ‘‘good cause’’ standard
only where the aggregate length of all
continuances and extensions requested
by the noncitizen does not cause a
merits hearing to take place more than
90 days after the master calendar
hearing. 8 CFR 1240.17(h)(2)(i). The IFR
then implements different criteria based
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on the length of the resulting delay for
deciding requests for continuances and
extensions by the noncitizen that would
cause a merits hearing to occur more
than 90 days after the master calendar
hearing. See 8 CFR 1240.17(h)(2)(ii)–
(iii).
Where a noncitizen-requested
continuance or filing extension would
cause a merits hearing to take place
between 91 and 135 days after the
master calendar hearing, an IJ should
grant a continuance or filing extension
if the noncitizen demonstrates that it is
necessary to ensure a fair proceeding
and the need for it exists despite the
noncitizen’s exercise of due diligence.
See 8 CFR 1240.17(h)(2)(ii). The length
of continuances and extensions under
this provision are, as a matter of
procedure, limited to the time necessary
to ensure a fair proceeding. See id.
Next, should the noncitizen request
any continuances or filing extensions
that would cause a merits hearing to
take place more than 135 days after the
master calendar hearing, the noncitizen
must demonstrate that failure to grant
the continuance or extension would be
contrary to statute or the Constitution. 8
CFR 1240.17(h)(2)(iii).
Noncitizens in removal proceedings
have the ‘‘right to a full and fair
hearing,’’ Arrey v. Barr, 916 F.3d 1149,
1157 (9th Cir. 2019) (collecting cases),
which ‘‘derives from the Due Process
Clause of the Fifth Amendment,’’
Cinapian v. Holder, 567 F.3d 1067, 1074
(9th Cir. 2009); see also Matter of
Sibrun, 18 I&N Dec. 354, 356 (BIA 1983)
(‘‘It should be emphasized that the full
panoply of procedural protections . . .
are not mandated for [noncitizens] in
these civil, administrative proceedings
. . . . All that is required here is that
the hearing be fundamentally fair.’’
(citations omitted)). A full and fair
hearing, ‘‘at a minimum, includes a
reasonable opportunity to present and
rebut evidence and to cross-examine
witnesses.’’ Grigoryan v. Barr, 959 F.3d
1233, 1240 (9th Cir. 2020) (citing
Cinapian, 567 F.3d at 1074 (citing, in
turn, section 240(b)(4)(B) of the Act, 8
U.S.C. 1229a(b)(4)(B))). When
adjudicating continuance and extension
requests pursuant to the IFR’s
heightened standards, IJs should
consider whether the request is related
to the noncitizen’s ability to reasonably
present his or her case or implicates any
of the rights found at section
240(b)(4)(B) of the Act, 8 U.S.C.
1229a(b)(4)(B). Thus, continuance
requests to present testimony and
evidence, to rebut evidence, or to crossexamine witnesses may meet the
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standards set forth in new 8 CFR
1240.17(h)(2)(ii) and (iii).39
In addition to the foregoing, the
Departments emphasize that the Act
provides noncitizens in section 240
removal proceedings with the right to
representation at no Government
expense, INA 240(b)(4)(A), 8 U.S.C.
1229a(b)(4)(A), and that the noncitizen
must be provided a reasonable
opportunity to obtain counsel. See
Matter of C–B–, 25 I&N Dec. 888, 889
(BIA 2012) (‘‘In order to meaningfully
effectuate the statutory and regulatory
privilege of legal representation where it
has not been expressly waived by a
noncitizen, the Immigration Judge must
grant a reasonable and realistic period of
time to provide a fair opportunity for
the noncitizen to seek, speak with, and
retain counsel.’’). Federal courts have
strictly reviewed IJ decisions to deny
continuances for seeking counsel or take
other actions that may impinge that
right in proceedings. See, e.g.,
Usubakunov, 16 F.4th at 1305 (holding
that the denial of a noncitizen’s motion
for a continuance to permit his attorney
to be present at his merits hearing
amounted to violation of his statutory
right to counsel); see also Leslie v. Att’y
Gen. of U.S., 611 F.3d 171, 180–81 (3d
Cir. 2010) (The ‘‘statutory and
regulatory right to counsel is also
derivative of the due process right to a
fundamentally fair hearing.’’);
Hernandez Lara v. Barr, 962 F. 3d 45,
54 (1st Cir. 2021) (‘‘The statutory right
to counsel is a fundamental procedural
protection worthy of particular
vigilance.’’). Accordingly, a continuance
to seek representation would be
sufficient to qualify for the heightened
continuance standards in these
streamlined 240 proceedings if denial
would violate a noncitizen’s right to
39 The Departments note, however, that the
decision to grant or deny a continuance or
extension will depend on the individual facts and
circumstances present in each case. See, e.g., De
Ren Zhang v. Barr, 767 F. App’x 101, 104–05 (2d
Cir. 2019) (collecting cases in which the Second
Circuit upheld an IJ’s denial of a continuance where
a noncitizen ‘‘had already received multiple
continuances, or had a significant amount of time
in which to gather and submit evidence’’ but, under
the particular circumstances of that case,
concluding that the IJ’s denial of a continuance was
an abuse of the IJ’s discretion); Bondarenko v.
Holder, 733 F.3d 899, 906–08 (9th Cir. 2013)
(holding that the denial of the noncitizen’s request
for a continuance to investigate the Government’s
forensic report was a violation of the noncitizen’s
right to due process); Cruz Rendon v. Holder, 603
F.3d 1104, 1111 (9th Cir, 2010) (determining that
‘‘the denial of the requested continuance’’ to obtain
evidence that bore directly on the noncitizen’s
eligibility for relief, ‘‘in conjunction with the
limitations placed upon her testimony, prevented
[the noncitizen] from fully and fairly presenting her
case’’).
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representation or another statutory or
constitutional right.40
The Departments emphasize that the
time periods that determine the relevant
continuance standard do not begin to
run until the day after the master
calendar hearing, at which the IJ will
advise noncitizens of their rights in the
streamlined section 240 proceedings,
including their right to representation,
at no expense to the Government, and
of the availability of pro bono legal
services, and will ascertain that
noncitizens have received a list of such
pro bono legal service providers. 8 CFR
1240.17(f)(1) (citing 8 CFR 1240.10(a));
see INA 240(b)(4), 8 U.S.C. 1229a(b)(4).
Furthermore, these calculations only
pertain to delay of hearings and
deadlines specifically included in this
regulation, namely, the status
conference hearing or a merits hearing
and any filing deadline that, if
extended, would have the effect of
delaying a hearing. Any continuances
with respect to interim hearings or
deadlines that may be set by the IJ do
not impact determination of the
continuance standard that applies in
this section.41 Continuances or filing
extensions granted due to exigent
circumstances, such as court closures or
40 This does not mean that a request for a
continuance to seek counsel can never be denied.
See Usubakunov, 16 F.4th at 1304 (‘‘We recognize
that immigration courts bear a crushing caseload
and an applicant cannot unreasonably delay the
administrative process, which has various
component parts and must be managed efficiently
by the IJ.’’); see also Arrey, 916 F.3d at 1158
(explaining that a noncitizen ‘‘is not denied the
right to counsel where continuing the hearing
would have been futile or where the IJ had done
everything he reasonably could to permit [the
noncitizen] to obtain counsel’’ (quotation marks and
citation omitted)). Such determinations are made on
a case-by-case basis. See Biwot v. Gonzales, 403
F.3d 1094, 1099 (9th Cir. 2005) (‘‘The inquiry is
fact-specific and thus varies from case to case. We
pay particular attention to the realistic time
necessary to obtain counsel; the time frame of the
requests for counsel; the number of continuances;
any barriers that frustrated a [noncitizen’s] efforts
to obtain counsel, such as being incarcerated or an
inability to speak English; and whether the
[noncitizen] appears to be delaying in bad faith.’’);
see also Gonzalez-Veliz v. Garland, 996 F.3d 942,
949 (9th Cir. 2021) (comparing cases granting and
denying requests for continuances to seek counsel).
41 In other words, the IJ would determine the
appropriate standard to consider when reviewing a
noncitizen’s request for a continuance by
considering how much the continuance would shift
the merits hearing. For example, the IJ would apply
the ‘‘good cause’’ standard under 8 CFR
1240.17(h)(2)(i) if a noncitizen requests an initial
continuance of the status conference for 10 days,
which would in turn cause the merits hearing to be
delayed by 10 days (because the merits hearing will
occur 30–35 days after the status conference).
However, if the noncitizen later requests further
continuances that would cause the status
conference to occur later than day 60, and in turn
would cause the merits hearing to occur later than
day 90, the IJ would apply the heightened
continuance standard under 8 CFR 1240.17(h)(2)(ii).
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illness of a party, will not count against
the aggregate limits on continuances, as
further explained below and as set forth
at new 8 CFR 1240.17(h)(4).
The Departments have also
contemplated DHS’s need for
continuances and provided for them in
appropriate situations. The IJ may grant
DHS a continuance and extend filing
deadlines based on significant
Government need, as set forth at new 8
CFR 1240.17(h)(3). The Departments
anticipate that significant Government
need will only arise in exceptional
cases. The IFR provides a nonexclusive
list of examples of significant
Government needs, including
‘‘confirming domestic or foreign law
enforcement interest in the respondent’’
and ‘‘conducting forensic analysis of
documents submitted in support of a
relief application or other fraud-related
investigations.’’ 8 CFR 1240.17(h)(3).
The Departments believe that requiring
DHS to demonstrate a significant
Government need for a continuance
serves efficiency interests without
undermining DHS’s opportunity to
present its case. First, DHS inherently
possesses the subject-matter expertise to
navigate section 240 proceedings in
general and does not face the same
obstacles as do noncitizens in exploring
and securing competent representation.
Second, noncitizens, not DHS, bear the
burden of proof throughout the majority
of streamlined section 240 proceedings.
Of particular relevance, noncitizens
generally bear the burden of
demonstrating eligibility for protectionbased relief. See, e.g., INA 208(b)(1)(B),
8 U.S.C. 1158(b)(1)(B). Third, DHS does
not face the same issues with respect to
access to counsel, especially when
taking into consideration the likelihood
that some noncitizens will be detained
during the course of proceedings. IJs
must be able to take such factors under
consideration when considering
continuance requests made by
noncitizens, but they are not relevant to
such requests made by DHS.
In addition, these timelines and
standards do not apply to an IJ’s ability
to continue a case, extend a filing
deadline, or adjourn a hearing due to
exigent circumstances, such as the
unavailability of the IJ, the parties, or
counsel due to illness, or the closure of
the immigration court. See 8 CFR
1240.17(h)(4). Such continuances must
be limited to the shortest time necessary
and each must be justified. See id. The
Departments recognize the magnitude
and weight of asylum claims, and the
importance of ensuring that asylum
procedures do not undermine the
fairness of proceedings. See Quintero,
998 F.3d at 632 (‘‘[N]eedless to say,
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these cases per se implicate extremely
weighty interests in life and liberty, as
they involve individuals seeking
protection from persecution, torture, or
even death.’’); Xue v. BIA, 439 F.3d 111,
113–14 (2d Cir. 2006) (‘‘We should not
forget, after all, what is at stake. For
each time we wrongly deny a
meritorious asylum [or withholding]
application, . . . we risk condemning
an individual to persecution. Whether
the danger is of religious discrimination,
extrajudicial punishment, forced
abortion or involuntary sterilization,
physical torture or banishment, we must
always remember the toll that is paid if
and when we err.’’); Matter of O–M–O–,
28 I&N Dec. 191, 197 (BIA 2021) (‘‘The
immigration court system has no more
solemn duty than to provide refuge to
those facing persecution or torture in
their home countries, consistent with
the immigration laws.’’). The
Departments believe that this rule
strikes the appropriate balance by
providing noncitizens with a full and
fair opportunity to present their
claims—first before USCIS and then, if
necessary, in streamlined section 240
removal proceedings—while ensuring
that such claims are adjudicated in a
timely and efficient manner.
5. Consideration of Statutory
Withholding of Removal and CAT
Protection
The NPRM proposed that, where
USCIS denied asylum, IJs would
reconsider the entire USCIS Asylum
Merits record de novo, including grants
of statutory withholding of removal and
protection under the CAT. See, e.g., 86
FR 46946 (8 CFR 1003.48(a) (proposed)).
Upon further review, including the
review of comments as discussed
further below, the Departments have
determined that IJs should generally
give effect to an asylum officer’s
determination that a noncitizen is
eligible for statutory withholding of
removal or protection under the CAT
subject to certain exceptions.
Specifically, under new 8 CFR
1240.17(i)(1), if an asylum officer finds
that the noncitizen is not eligible for
asylum or other protection sought, IJs
will adjudicate de novo all aspects of a
noncitizen’s application, including the
noncitizen’s eligibility for asylum and,
if necessary, statutory withholding of
removal or protection under the CAT.
However, if an asylum officer does not
grant asylum but finds that a noncitizen
is eligible for statutory withholding of
removal or protection under the CAT,
the noncitizen has two options.
First, the noncitizen may indicate that
the noncitizen does not intend to
contest removal or seek protection(s) for
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18105
which the asylum officer did not find
the noncitizen eligible, as described at
new 8 CFR 1240.17(f)(2)(i)(B). In that
case, unless DHS makes a prima facie
showing, through evidence that
specifically pertains to the noncitizen
and was not in the record of
proceedings for the USCIS Asylum
Merits interview, that the noncitizen is
not eligible for such protection(s), the IJ
will issue the removal order and give
effect to any protection for which the
asylum officer found the noncitizen
eligible, and no further proceedings will
be held.42
Second, and alternatively, the
noncitizen may contest the asylum
officer’s decision to not grant asylum, in
which case the IJ will adjudicate de
novo the noncitizen’s application for
asylum. See 8 CFR 1240.17(i)(2). If the
IJ subsequently denies asylum, then the
IJ will enter an order of removal and
give effect to the protections for which
the asylum officer deemed the
noncitizen eligible, unless DHS
demonstrates through evidence or
testimony that specifically pertains to
the respondent and that was not
included in the record of proceedings
for the USCIS Asylum Merits interview
that the noncitizen is not eligible for
such protection. See id.43
42 In addition, at 8 CFR 1240.17(d), the IFR
provides that a noncitizen who fails to appear and
who is ordered removed in absentia under section
240(b)(5)(A) of the INA, 8 U.S.C. 1229a(b)(5)(A),
will still receive the benefit of any protections from
removal for which the asylum officer found that the
noncitizen was eligible unless DHS makes a prima
facie showing through evidence that specifically
pertains to the noncitizen and that was not
included in the record of proceedings for the USCIS
Asylum Merits interview that the noncitizen is not
eligible for such protection. Where USCIS has
determined that an applicant is eligible for statutory
withholding of removal or protection under the
CAT, the United States would risk violating its
nonrefoulement obligations by nonetheless
removing the noncitizen to the country in which
they more likely than not would be subject to
persecution or torture due to the failure to appear.
That would particularly be so if the noncitizen’s
failure to attend the hearing were due to
misunderstanding, confusion, or a belief that no
further steps were necessary to preserve the
noncitizen’s eligibility for statutory withholding of
removal or protection under the CAT.
43 The Departments emphasize that the evidence
or testimony relied upon by DHS to demonstrate
that the noncitizen is not eligible for withholding
of removal or protection under the CAT must be
evidence or testimony not considered by the asylum
officer that pertains specifically to the noncitizen
and establishes that the noncitizen is not eligible.
For example, DHS could submit information that
arose from background checks conducted after the
asylum officer interview, but DHS cannot point to
a statement by the noncitizen in the Form I–213,
Record of Deportable/Inadmissible Alien. The
evidence or testimony must demonstrate the
noncitizen’s ineligibility for the protection that the
asylum officer determined the noncitizen was
eligible for. The IJ’s decision must be based on such
new evidence or testimony; the IJ may not
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The Departments have determined
that these changes are advisable for
several reasons. First, after reviewing
comments, the Departments have
declined to adopt certain provisions
proposed in the NPRM and instead have
set forth that after an asylum officer
does not grant asylum, an individual
will be automatically referred to
streamlined section 240 removal
proceedings. Automatic referral to
streamlined section 240 proceedings
means that every noncitizen whose
application is not approved by the
asylum officer will have the opportunity
to have their case reviewed by the IJ,
without first affirmatively requesting
review. During streamlined 240
proceedings, the noncitizen may elect to
have the IJ adjudicate de novo the
noncitizen’s asylum application, and
any protection claim for which the
asylum officer found the noncitizen
ineligible. At the same time, the rule
recognizes that an asylum officer’s
determination that a noncitizen is
eligible for protection should generally
be given effect in the interest of
efficiency and to ensure that the
noncitizen is not returned to a country
where an immigration official has
already determined that the noncitizen
may be persecuted or tortured.
It is appropriate for USCIS to make
eligibility determinations for statutory
withholding of removal and protection
under the CAT. As a threshold issue,
applications for asylum, statutory
withholding of removal, and protection
under the CAT are all factually linked.
While the legal standards and
requirements differ among the forms of
relief and protection, the relevant
applications will substantially share the
same set of operative facts that an
asylum officer would have already
elicited, including through evidence
and testimony, in the nonadversarial
proceeding. Moreover, asylum officers
receive extensive training, and develop
extensive expertise, in assessing claims
and country conditions and are
qualified to determine whether an
applicant will face harm in the
proposed country. See INA 235(b)(1)(E),
8 U.S.C. 1225(b)(1)(E); 8 CFR 208.1(b).
Asylum officers also receive training on
standards and eligibility issues related
to determinations for statutory
withholding of removal and CAT
protection in order to conduct credible
fear screening interviews and make
appropriate credible fear determinations
under 8 CFR 208.30(e). See 8 CFR
reconsider the asylum officer’s determination or
deny eligibility based merely on disagreement with
the asylum officer’s conclusions or evaluation of the
record before the asylum officer.
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208.1(b). Finally, statutory withholding
of removal and protection under the
CAT are nondiscretionary forms of
protection, the granting of which is
mandatory upon a showing of
eligibility. See, e.g., Myrie, 855 F.3d at
515–16; Benitez Ramos, 589 F.3d at 431.
Because the asylum officer does not
issue an order of removal under the IFR,
it is appropriate to wait until the IJ
enters the order of removal before giving
effect to USCIS’s statutory withholding
of removal and CAT protection
eligibility determinations. See Matter of
I–S– & C–S–, 24 I&N Dec. at 433.
Thus, this IFR recognizes that
applications for discretionary and
mandatory forms of protection will be
reviewed by IJs. However,
determinations that a noncitizen is
eligible for a mandatory form of
protection will be given effect by the IJs,
unless DHS demonstrates, through new
evidence specifically pertaining to the
noncitizen, that the noncitizen is not
eligible for such protection.
Considering the comments received
on the NPRM, the Departments
recognize that this procedure is an
intermediate approach between the
NPRM and the commenters’ suggestions
described below in Section IV.D.6 of
this preamble. Whereas the NPRM
would have allowed the IJ to sua sponte
review the asylum officer’s statutory
withholding and CAT determinations,
the IFR instead places the burden on
DHS to demonstrate, with new evidence
specific to the noncitizen, that the
noncitizen is not eligible for such
protections. The Departments have
determined that this process is most
efficient, given that there may be
particular instances, such as evidence of
fraud or criminal activity, where
overturning the asylum officer’s
eligibility determination is justified. If
the Departments provided no
mechanism in these streamlined section
240 removal proceedings through which
the asylum officer’s eligibility
determinations could be overturned,
DHS would have to follow the
procedures set forth in 8 CFR 208.17(d)
and 208.24(f) in instances where
overturning the asylum officer’s
eligibility determinations is justified.
Providing an exception where DHS
demonstrates that evidence or testimony
specifically pertaining to the noncitizen
and not in the record of proceedings for
the USCIS Asylum Merits interview
establishes that the noncitizen is not
eligible is substantially more efficient,
consistent with the overall aims of this
IFR.
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6. Exceptions to Streamlined Procedures
The IFR provides specific exceptions
that will allow certain noncitizens or
situations to be exempted from these
streamlined procedures and timelines
despite originating in the expedited
removal process and being referred to
immigration court following an asylum
officer’s initial adjudication. See 8 CFR
1240.17(k). These exceptions ensure
procedural fairness because not all cases
that might otherwise be placed in
streamlined section 240 removal
proceedings would in fact be suitable
for the expedited timeline.
At new 8 CFR 1240.17(k)(3), the IFR
provides an exception to the expedited
timeline if the noncitizen has raised a
substantial challenge to the charge that
the noncitizen is subject to removal—
e.g., if the noncitizen has a claim to U.S.
citizenship or the charge that the
noncitizen is subject to removal is not
supported by the record—and that
challenge cannot be resolved
simultaneously with the noncitizen’s
applications for asylum, statutory
withholding of removal, or withholding
or deferral of removal under the CAT.
Because the IFR places noncitizens
into section 240 proceedings, the
noncitizen can affirmatively elect to
apply for a wide range of relief in
addition to asylum, statutory
withholding of removal, and protection
under the CAT. See, e.g., 8 CFR
1240.1(a)(1)(ii) (providing IJs with the
authority to adjudicate a wide range of
applications for relief); 8 CFR
1240.11(a)(2) (‘‘The immigration judge
shall inform the [noncitizen] of his or
her apparent eligibility to apply for any
of the benefits enumerated in this
chapter and shall afford the [noncitizen]
an opportunity to make application
during the hearing . . . .’’). The IFR
therefore provides an exception to the
timeline if the noncitizen produces
evidence of prima facie eligibility for
relief or protection other than asylum,
statutory withholding of removal,
withholding or deferral of removal
under the CAT, or voluntary departure,
and is seeking to apply for, or has
applied for, such relief or protection.
See 8 CFR 1240.17(k)(2). For example, a
noncitizen who also is eligible to seek
adjustment of status under section 245
of the Act, 8 U.S.C. 1255, could provide
the IJ with proof of prima facie
eligibility and a copy of the submitted
Form I–130, Petition for Alien Relative,
and upon receipt of such evidence, the
timeline in 8 CFR 1240.17(f)–(h) would
not apply.44 Testimonial evidence, and
44 Although a submitted visa petition
demonstrating prima facie eligibility for relief
would be an optimal way to demonstrate
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out-of-court written statements, could
also be considered by immigration
judges as evidence of prima facie
eligibility for relief. The Departments
believe this exception from the timeline
is appropriate to allow effective
adjudication of the new relief being
sought because the IJ will not have the
benefit of an already developed record
regarding those forms of relief, which
the IJ will have for the noncitizen’s
application for asylum or other
protection.45
Similarly, the IFR provides an
exception where the IJ finds the
noncitizen subject to removal to a
different country from the country or
countries in which the noncitizen
claimed a fear of persecution and torture
before the asylum officer, and the
noncitizen claims a fear of persecution
or torture with respect to that alternative
country. See 8 CFR 1240.17(k)(4). The
Departments similarly believe the IFR’s
timeline should not apply in these
circumstances because the record would
need to be developed without the
benefit of previous adjudication.
The Departments have also
considered the effect of the streamlined
240 proceedings on vulnerable
populations. To ensure procedural
fairness, the Departments will exempt
the following categories of noncitizens
from these procedures: Noncitizens
under the age of 18 on the date the NTA
was issued, except noncitizens in
section 240 proceedings with an adult
family member, 8 CFR 1240.17(k)(1);
and noncitizens who have exhibited
indicia of mental incompetency, 8 CFR
1240.17(k)(6).
Finally, the expedited timeline does
not apply to cases that have been
reopened or remanded following the IJ’s
order. 8 CFR 1240.17(k)(5). Reopened
and remanded cases may present unique
qualification for this exception, there may exist
circumstances in which a filed petition would not
be possible to present on an expedited timeline due
to factors outside of a noncitizen’s control. For
example, a complaint for custody and motion for
Special Immigrant Juvenile classification (‘‘SIJ’’)
findings, as filed with a State court, along with a
statement and evidence as to other eligibility factors
listed on the Form I–360, Petition for Amerasian,
Widow(er), or Special Immigrant, could be
sufficient to permit the IJ to assess a respondent’s
prima facie eligibility for SIJ classification.
45 The Departments also note that this shift from
the NPRM to streamlined section 240 removal
proceedings addresses comments that the NPRM
would have improperly burdened noncitizens by
requiring them to file motions to vacate their
removal orders and by limiting noncitizens to only
one such motion. Further, by placing noncitizens
into streamlined 240 proceedings—thereby
allowing them to seek various forms of relief or
protection for which they may be eligible—the IFR
also addresses comments that the NPRM would
have authorized the IJs to exercise discretion over
whether to allow the respondent to apply for
additional forms of relief or protection.
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issues that are outside of the scope of
these streamlined 240 proceedings.
E. Other Amendments Related to
Credible Fear
In addition to the new procedures at
8 CFR 1240.17, this IFR amends 8 CFR
1003.42, 1208.2, 1208.3, 1208.4, 1208.5,
1208.14, 1208.16, 1208.18, 1208.19,
1208.22, 1208.30, and 1235.6. Except for
the amendments at 8 CFR 1003.42, the
Departments proposed amendments to
all of these sections in the NPRM in
order to: (1) Effectuate the
reestablishment of the ‘‘significant
possibility’’ standard in credible fear
review proceedings before EOIR; (2)
ensure that IJs, like asylum officers, do
not apply the mandatory bars at the
credible fear screening process; and (3)
ensure that the provisions providing for
the USCIS Asylum Merits process are
accurately reflected in EOIR’s
regulations where relevant, including
confirmation that the written record of
the positive credible fear determination
will count as an asylum application.
The IFR adopts these same changes with
limited technical amendments where
necessary to accord with the
streamlined section 240 proceedings
under new 8 CFR 1240.17.
The Departments also include
amendments to 8 CFR 1003.42(d)(1) in
this IFR. Although these amendments
were not included in the NPRM, they
are direct corollaries of the NPRM’s
proposed amendments and are
necessary to ensure consistency, both
internally within DOJ’s regulatory
provisions and more broadly between
DHS’s and DOJ’s regulations.
Specifically, the IFR amends 8 CFR
1003.42(d)(1) to ensure consistency with
the revisions to 8 CFR 208.30(e) related
to credible fear screening standards and
treatment of mandatory bars in the
credible fear screening process and with
the revisions to 8 CFR 1208.30(g)(2) so
that both provisions properly direct that
when an IJ vacates a negative credible
fear finding, the IJ will refer the case
back to USCIS as intended by the NPRM
and the IFR.
F. Parole
This rule amends the DHS regulations
governing the circumstances in which
parole may be considered for
individuals who are being processed
under the expedited removal provisions
of INA 235(b)(1), 8 U.S.C. 1225(b)(1).
Expedited removal is a procedure that
applies when an immigration officer
‘‘determines’’ that a noncitizen ‘‘arriving
in the United States,’’ or a noncitizen
covered by a designation who has not
been admitted or paroled into the
United States, is inadmissible under
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either INA 212(a)(6)(C), 8 U.S.C.
1182(a)(6)(C) (fraud or
misrepresentation), or INA 212(a)(7), 8
U.S.C. 1182(a)(7) (lack of proper
documents), and further determines that
the noncitizen should be placed in
expedited removal. INA 235(b)(1)(A)(i),
(iii), 8 U.S.C. 1225(b)(1)(A)(i), (iii).
Other noncitizens who are applicants
for admission—and whom an
immigration officer determines are not
clearly and beyond a doubt entitled to
be admitted—generally are referred for
ordinary removal proceedings under
INA 240, 8 U.S.C. 1229a. See INA
235(b)(2)(A), 8 U.S.C. 1225(b)(2)(A).
The statute generally provides for the
detention of noncitizens subject to
expedited removal pending a final
credible fear determination and, if no
such fear is found, until removed. See
INA 235(b)(1)(B)(iii)(IV), 8 U.S.C.
1225(b)(1)(B)(iii)(IV) (noncitizens in the
expedited removal process ‘‘shall be
detained pending a final determination
of credible fear of persecution and, if
found not to have such a fear, until
removed’’). The statute, likewise,
provides that noncitizens determined to
have a credible fear ‘‘shall be detained
for further consideration of the
application for asylum.’’ INA
235(b)(1)(B)(ii), 8 U.S.C.
1225(b)(1)(B)(ii). Congress has, however,
expressly granted DHS the authority to
release any applicant for admission
from detention via parole ‘‘on a case-bycase basis for urgent humanitarian
reasons or significant public benefit.’’
INA 212(d)(5)(A), 8 U.S.C.
1182(d)(5)(A). This includes DHS’s
authority to parole noncitizens detained
under section 235 of the Act, 8 U.S.C.
1225. See Jennings v. Rodriguez, 138 S.
Ct. 830, 837, 844 (2018).
The NPRM proposed to replace the
current narrow parole standard with a
standard that would permit parole ‘‘only
when DHS determines, in the exercise
of discretion, that parole is required to
meet a medical emergency, for a
legitimate law enforcement objective, or
because detention is unavailable or
impracticable (including situations in
which continued detention would
unduly impact the health or safety of
individuals with special
vulnerabilities).’’ 86 FR 46946 (8 CFR
235.3(b)(2)(iii) (proposed)); see id. at
46913–14. Having considered all
comments received on this issue, DHS
has determined that the current narrow
standard should be replaced not with
the standard proposed in the NPRM but
with the longstanding parole standard
applicable in other circumstances and
described in 8 CFR 212.5(b), with which
DHS officers and agents have substantial
experience. That provision describes
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five categories of certain noncitizens
detained under 8 U.S.C. 1225(b) who
may meet the parole standard of INA
212(d)(5), 8 U.S.C. 1182(d)(5), provided
they present neither a security risk nor
a risk of absconding: (1) Noncitizens
who have serious medical conditions
such that continued detention would
not be appropriate; (2) women who have
been medically certified as pregnant; (3)
certain juveniles; (4) noncitizens who
will be witnesses in proceedings
conducted by judicial, administrative,
or legislative bodies in the United
States; and (5) noncitizens whose
continued detention is not in the public
interest. See 8 CFR 212.5(b)(1)–(5).
Consistent with the statute and the
regulation, DHS will consider
noncitizens covered by this rule for
parole under this standard pending their
credible fear interview ‘‘only on a caseby-case basis,’’ 8 CFR 212.5(b), and may
impose reasonable conditions on parole
(including, for example, periodic
reporting to ICE) to ensure that the
noncitizen will appear at all hearings
and for removal from the United States
if required to do so, 8 CFR 212.5(c)–(d);
see INA 212(d)(5)(A), 8 U.S.C.
1182(d)(5)(A).
For purposes of making these case-bycase determinations concerning parole
of noncitizens pending a credible fear
interview, the Secretary recognizes that,
in circumstances where DHS has
determined that the continued detention
of a noncitizen who has been found not
to be a flight risk or a danger to the
community is not in the public interest,
the release of that noncitizen on parole
may serve ‘‘urgent humanitarian
reasons’’ or achieve ‘‘significant public
benefit.’’ INA 212(d)(5)(A), 8 U.S.C.
1182(d)(5)(A); see 8 CFR 212.5(b)(5).
The INA does not define these
ambiguous terms, leaving them to the
agency’s reasonable construction.46 In
implementing the statutory parole
authority, DHS and the former INS have
long interpreted the statute to permit
parole of noncitizens whose continued
46 See INA 103(a)(1), (3), 8 U.S.C. 1103(a)(1), (3);
see also Nat’l Cable & Telecomms. Ass’n v. Brand
X internet Servs., 545 U.S. 967, 980 (2005) (‘‘If a
statute is ambiguous, and if the implementing
agency’s construction is reasonable, Chevron
requires a federal court to accept the agency’s
construction of the statute, even if agency’s reading
differs from what the court believes is the best
statutory interpretation.’’ (citing Chevron, 467 U.S.
at 843–44)); Garfias-Rodriguez v. Holder, 702 F.3d
504, 515 (9th Cir. 2012) (en banc) (‘‘We defer to an
agency not because it is better situated to interpret
statutes, but because we have determined that
Congress created gaps in the statutory scheme that
cannot be filled through interpretation alone, but
require the exercise of policymaking judgment.’’
(citing Chevron, 467 U.S. at 865)); cf., e.g.,
Ibragimov v. Gonzales, 476 F.3d 125, 137 n.17 (2d
Cir. 2007) (deferring to another aspect of 8 CFR
212.5).
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detention is not in the public interest as
determined by specific agency officials.
Specifically, prior to the 1996
amendment to the INA that provided for
parole ‘‘on a case-by-case basis for
urgent humanitarian reasons or
significant public benefit,’’ Illegal
Immigration Reform and Immigrant
Responsibility Act of 1996 (‘‘IIRIRA’’),
Pub. L. 104–208, div. C, tit. VI, subtit.
A, sec. 602, 110 Stat. 3009, 3009–689,
the former INS had paroled individuals
‘‘whose continued detention’’ was ‘‘not
in the public interest,’’ 8 CFR
212.5(b)(5) (1995); see Detention and
Parole of Inadmissible Aliens; Interim
Rule With Request for Comments, 47 FR
30044, 30045 (July 9, 1982) (interim
rule). After the 1996 amendment, the
agency incorporated the new ‘‘case-bycase’’ requirement into its regulation,
while also providing, similar to prior
regulatory authority, that parole of
certain noncitizens, including those
who pose neither a security risk nor a
risk of absconding and whose
‘‘continued detention is not in the
public interest’’ would generally be
justified for ‘‘significant public benefit’’
or ‘‘urgent humanitarian reasons,’’
consistent with the 1996 statutory
amendment. 62 FR 10348; see id. at
10313.
Nothing in INA 212(d)(5)(A), 8 U.S.C.
1182(d)(5)(A), prohibits DHS from
considering its resources and detention
capacity when it determines, on a caseby-case basis, whether the parole of a
noncitizen otherwise subject to
detention under INA 235(b), 8 U.S.C.
1225(b), would have a significant public
benefit or would advance urgent
humanitarian reasons.47 Rather,
consistent with the statute, 8 CFR 212.5,
and longstanding practice, DHS may
take into account the important
prerogative for it to use its detention
resources for other individuals whose
detention is in the public interest,
including because of public safety or
national security reasons. As has been
the case for decades, DHS views
detention as not being in the public
interest where, in light of available
detention resources, and considered on
a case-by-case basis, detention of any
particular noncitizen would limit the
agency’s ability to detain other
noncitizens whose release may pose a
greater risk of flight or danger to the
47 See, e.g., New Mexico v. McAleenan, 450 F.
Supp. 3d 1130, 1174 n.5 (D. N.M. 2020) (‘‘This
vague [‘significant public benefit’] standard [in INA
212(d)(5)(A), 8 U.S.C. 1182(d)(5)(A)] conceivably
encompasses a wide range of public benefits, such
as conserving resources otherwise spent on housing
asylum seekers . . . .’’).
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community.48 With regard to
noncitizens detained pending a credible
fear interview, whose inadmissibility
was still being considered, or who had
been ordered removed in expedited
removal proceedings, the former INS, in
a 1997 rule, restricted the regulatory
authority for release on parole to where
parole is required for a ‘‘medical
emergency’’ or ‘‘a legitimate law
enforcement objective.’’ 8 CFR
235.3(b)(2)(iii), (b)(4)(ii) (current); see 62
FR 10356. As the NPRM explained, this
current narrow standard effectively
prevents DHS from placing into
expedited removal many noncitizens
who would otherwise be eligible for this
process, especially families, given the
practical constraints and the legal limits
of the Flores Settlement Agreement
(‘‘FSA’’).49 See 86 FR 46910. These
restrictions on DHS’s ability to detain
families in significant numbers and for
an appreciable length of time, coupled
with capacity constraints imposed by
the COVID–19 pandemic, have
effectively prevented the Government
from processing more than a very
limited number of families under
expedited removal. Amending the
regulation by which the former INS
previously constrained itself (and now
DHS) to considering parole for
noncitizens in the expedited removal
process far more narrowly than what the
statute authorizes will advance the
significant public benefit of allowing
DHS to place more eligible noncitizens,
particularly noncitizen families, in
48 See, e.g., ICE, Interim Guidance for
Implementation of Matter of M–S-, 27 I&N Dec. 509
(A.G. 2019) During the Stay of the Modified
Nationwide Preliminary Injunction in Padilla v.
ICE, No. 18–298, 2019 WL 2766720 (W.D. Wash.
July 2, 2019): Parole of Aliens Who Entered Without
Inspection, Were Subject to Expedited Removal,
and Were Found to Have a Credible Fear of
Persecution or Torture (July 15, 2019);
Memorandum from DHS Secretary John Kelly,
Implementing the President’s Border Security and
Immigration Enforcement Improvement Policies 3
(Feb. 20, 2017), https://www.dhs.gov/sites/default/
files/publications/17_0220_S1_Implementing-thePresidents-Border-Security-ImmigrationEnforcement-Improvement-Policies.pdf;
Memorandum from Gene McNary, INS
Commissioner, Parole Project for Asylum Seekers at
Ports of Entry and INS Detention 1 (Apr. 20, 1992).
49 Stipulated Settlement Agreement, Flores v.
Reno, No. 85–cv–4544 (C.D. Cal. Jan. 17, 1997); see
also 86 FR 46910 & n.27 (describing the FSA). The
FSA provides for a general policy favoring release
of minors and requires the expeditious transfer of
minors who are not released from custody,
including minors accompanied by their parents or
legal guardians, to a non-secure, state-licensed
program. See FSA ¶¶ 6, 12, 14, 19. When the former
ICE family residential centers were operational, the
court determined that such facilities were secure,
unlicensed facilities; therefore, DHS generally
released noncitizen children detained during their
immigration proceedings within 20 days. See Flores
v. Sessions, 394 F. Supp. 3d 1041, 1070–71 (C.D.
Cal. 2017).
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expedited removal proceedings, rather
than processing them through lengthy
and backlogged ordinary section 240
removal proceedings.
This approach will allow DHS to
more efficiently obtain orders of
removal for families who do not raise a
fear claim or who are found not to
possess a credible fear, thereby
facilitating their expeditious removal
without the need for lengthy
immigration court proceedings, and will
allow other families to have their fear
claims adjudicated in a more timely
manner. Accordingly, the flexibility of
the 8 CFR 212.5(b) standard—subject, of
course, to the limitations on the parole
authority contained in INA 212(d)(5), 8
U.S.C. 1182(d)(5)—will allow DHS to
achieve the significant public benefits of
more effectively utilizing the expedited
removal authority in response to
changing circumstances and promoting
border security. DHS expects that
expedited removal of families who do
not make a fear claim, or who are
determined not to have a credible fear
of persecution or torture, will reduce the
incentives for abuse by those who will
not qualify for protection and smugglers
who exploit the processing delays that
result from ordinary removal backlogs.
Finally, the contours of the category
of noncitizens ‘‘whose continued
detention is not in the public interest,’’
8 CFR 212.5(b)(5), have been developed
through directives and guidance. For
example, in 2009 ICE issued guidance
stating that ‘‘when an arriving alien
found to have a credible fear establishes
to the satisfaction of [ICE Detention and
Removal Operations (DRO)] his or her
identity and that he or she presents
neither a flight risk nor danger to the
community, DRO should, absent
additional factors (as described [later in
the directive]), parole the alien on the
basis that his or her continued detention
is not in the public interest.’’ ICE Policy
No. 11002.1 ¶ 6.2, Parole of Arriving
Aliens Found to Have a Credible Fear of
Persecution or Torture (Dec. 8, 2009),
https://www.ice.gov/doclib/dro/pdf/
11002.1-hd-parole_of_arriving_aliens_
found_credible_fear.pdf. DHS intends to
use further directives and guidance to
apply the parole standard to noncitizens
in expedited removal pending a credible
fear interview. DHS emphasizes that any
such directives or guidance will account
for the fact that there are important and
relevant differences between the
population of noncitizens who have
received a positive credible fear
determination and the population of
noncitizens in expedited removal who
have not received a credible fear
determination, including the expected
length of time before such an individual
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may be ordered removed and
considerations relevant to assessing
flight risk.
G. Putative Reliance Interests
In responses to comments below, the
Departments have addressed the
reliance interests in the status quo
asserted by commenters. See FCC v. Fox
Television Stations, Inc., 556 U.S. 502,
515 (2009) (requiring agencies to
consider ‘‘serious reliance interests’’
when changing policies); see also
Encino Motorcars, LLC v. Navarro, 579
U.S. 211, 222 (2016) (referring to
‘‘significant’’ and ‘‘serious’’ reliance
interests (quotation marks omitted)).
The governmental commenters do not
appear to have identified any reliance
interests. Although some commenters
identified what they believed would be
burdens on or injuries to State, county,
and local governments as a result of the
proposed rule—claims that are
addressed in the Departments’
responses to comments—none clearly
identified any significant reliance
interests in the current state of affairs.
The Departments perceive no serious
reliance interests on the part of any
State, county, or local governmental
entity in the currently existing
provisions the NPRM implicated or that
are affected by this IFR. Even if such
reliance interests exist, the Departments
would nevertheless promulgate this
regulation for the reasons stated in this
rule.
IV. Response to Public Comments on
the Proposed Rule
A. Summary of Public Comments
In response to the proposed rule, the
Departments received 5,235 comments
during the 60-day public comment
period. Approximately 1,347 of the
comments were letters submitted
through mass mailing campaigns, and
3,790 comments were unique
submissions. Primarily, individuals and
anonymous entities submitted
comments, as did multiple State
Attorneys General, legal service
providers, advocacy groups, attorneys,
religious and community organizations,
elected officials, and research and
educational institutions, among others.
Comments received during the 60-day
comment period are organized by topic
below. The Departments reviewed the
public comments received in response
to the proposed rule and address
relevant comments in this IFR, grouped
by subject area. The Departments do not
address comments seeking changes in
U.S. laws, regulations, or agency
policies that are unrelated to the
changes to made by this rule. This IFR
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does not resolve issues outside the
scope of this rulemaking. A brief
summary of comments the Departments
deemed to be out of scope or unrelated
to this rulemaking, making a substantive
response unnecessary, is provided at the
end of the section. Comments may be
reviewed at https://
www.regulations.gov, docket number
USCIS–2021–0012.
Following careful consideration of
public comments received, the
Departments in this IFR have made
modifications to the regulatory text
proposed in the NPRM. The rationale
for the proposed rule and the reasoning
provided in the background section of
that rule remain valid with respect to
those regulatory amendments, except
where a new or supplemental rationale
is reflected in this IFR. As a general
matter, the Departments believe that the
IFR addresses concerns expressed by a
majority of those who commented on
the NPRM’s proposed IJ review
procedure by establishing that where
the asylum officer denies a noncitizen’s
application for asylum, that noncitizen
will be placed into streamlined section
240 proceedings, rather than the
alternative procedure proposed in the
NPRM. While the Departments found a
number of the concerns raised by
commenters to be persuasive in making
this change, general statements that the
IFR addresses commenters’ concerns
should not be read to mean that the
Departments have adopted or agree with
commenters’ reasoning in whole or in
part.
The Departments welcome comments
on the IFR’s revisions that are submitted
in accordance with the instructions for
public participation in Section I of this
preamble. Among other topics, the
Departments invite comment on the
procedures for streamlined section 240
proceedings and whether any further
changes to those procedures would be
appropriate.
B. General Feedback on the Proposed
Rule
1. General Support for the Proposed
Rule
a. Immigration Policy Benefits
Comments: Several commenters
supported the proposed rule on the
basis of immigration policy benefits,
including: Reducing duplication of
effort between USCIS asylum officers
and IJs by allowing asylum officers to
adjudicate claims that originated
through the USCIS-administered
credible fear screening process with less
or no expenditure of immigration court
time or resources; improving the process
to better serve traumatized populations;
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expediting the asylum application
process and allowing covered asylum
seekers to receive protection sooner;
making the asylum application process
more efficient and fair; helping to better
manage migrant flows and increase
security at the Southwest border; and
providing due process, dignity, and
equity within the system.
Response: The Departments
acknowledge the commenters’ support
for the rule.
b. Positive Impacts on Applicants, Their
Support Systems, and the Economy
Comments: A few commenters
supported the proposed rule, without
substantive rationale, on the basis of
positive impacts on applicants, their
support systems, and the U.S. economy.
Some commenters supported the
proposed rule and expressed gratitude
for helping people who are in fear for
their lives and encouraged facilitating a
smoother pathway for noncitizens once
they get through the initial process
successfully. Another commenter stated
that the rule represents a fundamental
shift that will help eligible asylum
applicants receive humanitarian
protection and not keep asylum seekers
in limbo for years while awaiting a final
status determination. An individual
commenter supporting the rule wrote
that asylum seekers who have received
a positive credible fear determination
may be able to enter the labor force
sooner. According to this commenter,
enabling earlier access to employment
for asylum-eligible individuals could
reduce the public burden, reduce the
burden on the asylum support network,
and benefit those asylum seekers in
terms of equity, human dignity, and
fairness.
Response: The Departments
acknowledge these commenters’ support
for the rule and agree the rule will
benefit asylum seekers and their support
systems, including public entities.
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2. General Opposition to the Proposed
Rule
a. Immigration Policy Concerns
Comments: Many commenters
expressed general opposition to the rule
out of a belief that this Administration
is not committed to enforcing U.S.
immigration law or deterring
unauthorized migration into the United
States, or out of a belief that the
Administration intends to drive more
irregular migration for political reasons.
Several of these commenters pointed to
the high numbers of Southwest border
encounters that have occurred in 2021
as support for their beliefs.
Response: The Departments
acknowledge the commenters’
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frustration with the high rates of
unauthorized entry into the United
States between ports of entry on the
Southwest border in 2021, a
continuation of an increase that has
been observed since April 2020.50
However, the Departments disagree with
the commenters’ suggestion that the
high numbers of border encounters
imply either that the Administration
supports or is indifferent to such
unauthorized entries. To the contrary,
maintaining an orderly, secure, and
well-managed border and reducing
irregular migration are priorities for the
Departments and for the
Administration. The Fiscal Year (‘‘FY’’)
2022 President’s Budget directs
resources toward robust investments in
border security and safety measures,
including border technology and
modernization of land ports of entry.
See DHS, FY 2022 Budget in Brief 1–2,
https://www.dhs.gov/sites/default/files/
publications/dhs_bib_-_web_version_-_
final_508.pdf. Under this
Administration, the United States has
also bolstered public messaging
discouraging irregular migration and
strengthened anti-smuggling and antitrafficking operations, while at the same
time investing in Central America to
address the lack of economic
opportunity, weak governance and
corruption, and violence and insecurity
that lead people to leave their homes in
the first place and attempt the
dangerous journey to our Southwest
border. See Press Release, The White
House, FACT SHEET: The Biden
Administration Blueprint for a Fair,
Orderly and Humane Immigration
System (July 27, 2021) https://
www.whitehouse.gov/briefing-room/
statements-releases/2021/07/27/factsheet-the-biden-administrationblueprint-for-a-fair-orderly-andhumane-immigration-system/ (last
visited Mar. 14, 2022). The Departments
emphasize that the COVID–19 pandemic
and associated economic downturn,
along with two severe hurricanes that
together impacted Nicaragua, Honduras,
Guatemala, and El Salvador in
November 2020, have added to those
longstanding problems. See DHS,
Statement by Homeland Security
Secretary Alejandro N. Mayorkas
Regarding the Situation at the
Southwest Border (Mar. 16, 2021),
https://www.dhs.gov/news/2021/03/16/
statement-homeland-security-secretaryalejandro-n-mayorkas-regardingsituation; USAID, Latin American
50 See U.S. Customs and Border Protection
(‘‘CBP’’), Southwest Land Border Encounters,
https://www.cbp.gov/newsroom/stats/southwestland-border-encounters.
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Storms—Fact Sheet #1, (FY) 2021 (Nov.
19, 2020), https://www.usaid.gov/crisis/
hurricanes-iota-eta/fy21/fs1 (last visited
Mar. 14, 2022). Finally,
misinformation—including the false
message that our borders are ‘‘open’’—
has also driven irregular migration. See
DHS, Secretary Mayorkas Delivers
Remarks in Del Rio, TX (Sep. 20, 2021),
https://www.dhs.gov/news/2021/09/20/
secretary-mayorkas-delivers-remarksdel-rio-tx. The Departments reiterate
that the borders of the United States are
not open and that individuals should
not put their own lives or the lives of
their family members in the hands of
smugglers or other criminals who
represent otherwise.
Comments: Many commenters
generally opposed the rule due to
concerns that USCIS asylum officers
would be more likely than IJs to grant
asylum or other protection to
individuals who should not be eligible
for it or to otherwise ‘‘loosen’’ the
requirements for asylum eligibility.
Some commenters expressed, without
providing details, that IJs are better
trained, better qualified, or better
equipped to ‘‘vet’’ applicants or detect
fraudulent claims. Other commenters
explained that they were concerned
USCIS asylum officers would not apply
the law or would not serve as impartial
adjudicators. Commenters based this
concern on at least two different
rationales. Some commenters reasoned
that asylum officers were subject to
greater political control than IJs; other
commenters reasoned that asylum
officers are too ‘‘unaccountable’’ to the
public. Finally, a few commenters
expressed concern about USCIS being
‘‘fee-driven’’ and that having a ‘‘feedriven’’ agency control the credible fear
process removes it from congressional
oversight.
While most comments that
disapproved of authorizing asylum
officers to adjudicate defensive asylum
applications urged the Departments to
continue to require that IJs within EOIR
adjudicate all such applications, some
comments urged that ‘‘Federal judges’’
or immigration judges ‘‘appointed by
the judicial branch’’ should be hired to
quickly and impartially adjudicate
asylum claims.
Response: The Departments disagree
with the assertion that USCIS asylum
officers cannot appropriately vet or
determine eligibility for protection.
Asylum officers are career Government
employees selected based on merit, they
receive extensive training, and they
possess expertise in determining
eligibility for protection. See INA
235(b)(1)(E), 8 U.S.C. 1225(b)(1)(E); 8
CFR 208.1(b); see, e.g., USAJOBS,
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Asylum Officer, https://
www.usajobs.gov/job/632962200 (last
visited Mar. 14, 2022) (specifying that
asylum officers are members of the
competitive service); see also 22 U.S.C.
6473(b) (requisite training on religious
persecution claims). USCIS asylum
officers must undergo ‘‘special training
in international human rights law,
nonadversarial interview techniques,
and other relevant national and
international refugee laws and
principles.’’ 8 CFR 208.1(b); see also
INA 235(b)(1)(E)(i), 8 U.S.C.
1225(b)(1)(E)(i) (requiring that asylum
officers have ‘‘professional training in
country conditions, asylum law, and
interview techniques’’). While IJs
handle a broad swath of immigrationrelated matters, USCIS asylum officers
are uniquely trained to adjudicate
protection claims. Additionally, USCIS
asylum officers have dedicated
resources available to them to address
fraud concerns, including Fraud
Detection and National Security
(‘‘FDNS’’) officers embedded within the
USCIS Asylum Division.51 FDNS
employs numerous measures to detect
and deter immigration benefit fraud and
aggressively pursues benefit fraud cases
in collaboration with USCIS
adjudication officers and Federal law
enforcement agencies. Since 2004,
FDNS and ICE have collaborated in a
strategic partnership to combat
immigration fraud. FDNS officers work
closely with law enforcement and
intelligence community partners to
resolve potential fraud, national
security, and public safety concerns and
to ensure the mutual exchange of
current and comprehensive information.
They conduct administrative
investigations into suspected benefit
fraud and aid in the resolution of
national security or criminal concerns.
Administrative investigations may
include compliance reviews, interviews,
site visits, and requests for evidence,
and they may also result in a referral to
ICE for consideration of a criminal
investigation. Determining asylum
eligibility and vetting is already a
necessary part of the day-to-day work of
a USCIS asylum officer and will
continue to be so after this rule takes
effect. Regardless of whether it is an IJ
or an asylum officer who adjudicates an
application, no individual may be
granted asylum or withholding of
removal until certain vetting and
identity checks have been made. INA
208(d)(5)(A)(i), 8 U.S.C. 1158(d)(5)(A)(i);
51 See USCIS, Fraud Detection and National
Security Directorate, https://www.uscis.gov/aboutus/directorates-and-program-offices/frauddetection-and-national-security-directorate.
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8 CFR 208.14(b), 1003.47. The
Departments believe that commenters’
concerns about USCIS having a
financial incentive to ‘‘rubber-stamp’’
grant applications for asylum or lacking
congressional oversight because it is
primarily fee-funded are likewise
misplaced. USCIS adjudicates asylum
applications without charge, see 86 FR
46922, and is subject to congressional
oversight.
Moreover, EOIR is currently burdened
with a heavy case backlog, as described
in the NPRM. Notably, EOIR’s caseload
includes a wide range of immigration
and removal cases. See EOIR Policy
Manual, Part II.1.4(a) (updated Dec. 30,
2020), https://www.justice.gov/eoir/eoirpolicy-manual (‘‘EOIR Policy Manual’’).
Allowing USCIS to take on cases
originating in the credible fear process
therefore is expected to reduce delays
across all of EOIR’s dockets, as well as
reducing the time it takes to adjudicate
these protection claims. The
Departments believe that alleviating
immigration court caseloads through the
fair, efficient process articulated in this
rule is a positive step forward.
Suggestions asking for additional
Federal judges within the judicial
branch to handle the influx of asylum
and protection-related cases should be
directed to Congress.
Comments: Many commenters
generally opposed the rule on the
ground that a higher-priority or better
way to address the overwhelmed U.S.
asylum system would be to ‘‘regain
control’’ over who enters the country by
‘‘tak[ing] steps to significantly reduce
the number of people flowing across the
border’’ and by not releasing individuals
who have entered the United States
without inspection or parole.
Response: The Departments
acknowledge concerns raised by the
commenters and note that this
rulemaking is one part of a multifaceted
whole-of-government approach to
addressing irregular migration and
ensuring that the U.S. asylum system is
fair, orderly, and humane. This wholeof-government approach seeks to make
better use of existing enforcement
resources by investing in border security
measures that will facilitate greater
effectiveness in combatting human
smuggling and trafficking and
addressing the entry of undocumented
migrants. The United States also is
working with governments of nearby
countries to facilitate secure
management of borders in the region
and to investigate and prosecute
organizations involved in criminal
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smuggling.52 These and other efforts to
address irregular migration are beyond
the scope of this rule, which specifically
concerns the procedures by which
individuals who are encountered near
the border and placed into expedited
removal will receive consideration of
their claims for asylum or other
protection, as is required by law. INA
235(b)(1), 8 U.S.C. 1225(b)(1). However,
to the extent that the significant delays
in the adjudication of asylum claims
today contribute to rates of irregular
migration, the Departments believe that
the efficiencies introduced by the rule
will help to reduce any incentive to
exploit the system and enhance the
Government’s efforts to address
irregular migration. By limiting the
amount of time a noncitizen may remain
in the United States while a claim for
relief or protection is pending, the rule
stands to dramatically reduce potential
incentives for noncitizens to make false
claims for relief and protection.
Finally, the Departments emphasize
that individuals who have entered the
United States without inspection or
parole and who are subsequently
encountered and placed into expedited
removal are presumptively detained, as
the statute provides that such
individuals are subject to mandatory
detention. See INA 235(b)(1)(B)(ii),
(iii)(IV), 8 U.S.C. 1225(b)(1)(B)(ii),
(iii)(IV). Such individuals may be
released on parole only in accordance
with the statutory and regulatory
standards. See INA 212(d)(5), 8 U.S.C.
1182(d)(5); 8 CFR 212.5, 235.3(b)(2)(iii),
(b)(4)(ii).
Comments: Many commenters
generally opposed the rule on the
ground that allowing USCIS to
adjudicate the merits of asylum claims
through a nonadversarial process would
‘‘take away the rights of the American
people to be represented in court when
migrants seek benefits that would place
them on the path to citizenship’’ or
‘‘remov[e] . . . safeguards that are
meant to protect the American
population.’’ Commenters asserted that
allowing asylum claims to be
adjudicated without a DHS attorney
cross-examining the applicant and
having the opportunity to offer
impeachment evidence would give
fewer rights to the American people,
while the noncitizen applicant would
52 See Press Release, The White House, FACT
SHEET: The Biden Administration Blueprint for a
Fair, Orderly and Humane Immigration System
(July 27, 2021), https://www.whitehouse.gov/
briefing-room/statements-releases/2021/07/27/factsheet-the-biden-administration-blueprint-for-a-fairorderly-and-humane-immigration-system/ (last
visited Mar. 14, 2022).
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still have the opportunity to be
represented by counsel.
Response: The Departments do not
agree with the premise of commenters’
assertions. A nonadversarial process
does not take away the rights of the
American people, but rather it allows
for the presentation and consideration
of asylum and other protection claims in
a manner that is fair and efficient.
Asylum officers are Government
officials who are well-trained in making
credibility determinations and assessing
evidence. The asylum officer position is
a specialized position focusing on
asylum and related relief and protection
from removal; as explained in Section
III.B of this preamble, asylum officers
already adjudicate affirmative asylum
claims through a nonadversarial
process. An asylum officer can consider
evidence relevant to an applicant’s
claim, including evidence that might be
introduced as impeachment evidence in
immigration court, and an asylum
officer, where appropriate, can ask the
applicant questions similar to those that
a DHS attorney might ask in
immigration court during a crossexamination. The Departments believe
that the American public is better
served if claims for asylum or related
protection that originate through the
credible fear screening process may be
adjudicated—fairly and efficiently—not
only within section 240 proceedings
before IJs but also by asylum officers
who specialize in such claims.
Comment: Several commenters
generally opposed the rule out of a
belief that it is being promulgated solely
for the purpose of providing asylum or
other immigration benefits faster or
through an easier procedure and is
thereby putting the interests of migrants
ahead of the interests of U.S. persons or
of the public interest.
Response: The Departments disagree
with the view that the rule is not in the
public interest. Rather, providing a
process through which vulnerable
populations may seek protection is the
means by which the United States meets
its obligations under both U.S. and
international law. See Refugee Protocol,
19 U.S.T. 6223; INA 208, 241(b)(3), 8
U.S.C. 1158, 1231(b)(3); FARRA sec.
2242. Amending the existing process to
allow adjudications—both those that
end in grants and those that end in
denials—to be made more promptly,
while maintaining fundamental fairness,
is a change that is in the public interest.
For decades, U.S. law has protected
vulnerable populations from return to a
country where they would be
persecuted or tortured. See, e.g., INS v.
Cardoza-Fonseca, 480 U.S. 421, 424
(1987) (observing that the Refugee Act of
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1980 established ‘‘a broad class of
refugees who are eligible for a
discretionary grant of asylum, and a
narrower class of aliens who are given
a statutory right not to be deported to
the country where they are in danger’’);
FARRA sec. 2242 (legislation
implementing U.S. obligations under
Article 3 of the CAT not to remove
noncitizens to any country where there
are substantial grounds for believing the
person would be in danger of being
subjected to torture). Ensuring that the
Departments uphold these American
values as enshrined in U.S. law is in the
national interest. It is also in the public
interest that the procedures by which
the Departments administer the law and
uphold these values not regularly result
in years-long delays, which may be
detrimental to both the U.S. public and
those seeking protection. Efficient
processing of cases is in the public
interest, as cases that span years can
consume substantially greater
Government resources, including by
contributing to delays in immigration
court proceedings that hinder DHS’s
ability to swiftly secure the removal of
noncitizens who are high priorities for
removal. The process created by this
rule therefore advances the public
interest by authorizing the Departments
to employ a fair and efficient procedure
for individuals to seek protection as an
appropriate alternative to the exclusive
use of section 240 proceedings and by
reducing immigration court backlogs
that are detrimental to the public
interest.
Comments: Some commenters
generally opposed the rule on the
ground that it allows noncitizens to seek
review of any denial of asylum or other
protection but does not allow an
opportunity for correcting or reviewing
erroneous grants of asylum or other
protection.
Response: The Departments
acknowledge the concern regarding
error correction when asylum or other
protection is granted, but the
Departments believe this concern is
addressed by existing statutory and
regulatory provisions, as well as by
DHS’s longstanding practices regarding
the supervision of asylum officers. To
reiterate those longstanding supervision
practices, the Departments have revised
8 CFR 208.14(b) and (c) and,
correspondingly, 8 CFR 1208.14(b) and
(c), to emphasize that asylum officers’
decisions on approval, denial,
dismissal, or referral of an asylum
application remain subject to review
within USCIS.
As noted above, the Secretary of
Homeland Security is charged with the
administration and enforcement of the
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immigration laws and has the control,
direction, and supervision of all
employees and of all the files and
records of USCIS. See INA 103(a)(1), (2),
8 U.S.C. 1103(a)(1), (2). Further, the
asylum statute vests the Secretary of
Homeland Security with the authority to
grant asylum. See INA 208(b)(1)(A), 8
U.S.C. 1158(b)(1)(A). The Secretary’s
broad authority includes the authority
to review and modify immigration
benefit decisions, including grants of
asylum. Such authority has been
delegated to the Director of USCIS. See
DHS, Delegation to the Bureau of
Citizenship and Immigration Services,
No. 0150.1 (June 5, 2003); see also 8
CFR 2.1. Further, USCIS retains
authority under this delegation to
reopen or reconsider decisions
(including asylum decisions) at any
time on the agency’s own motion, based
upon any new facts or legal
determinations. See 8 CFR 103.5(a)(5).
Nothing in this IFR in any way detracts
from or diminishes the authority and
responsibility of the Secretary of
Homeland Security and the Director of
USCIS over any grant of asylum that is
issued by USCIS.
Beyond these statutory and regulatory
provisions, 100 percent of USCIS
asylum officers’ approvals, denials,
referrals, or dismissals of an asylum
application are currently subject to
supervisory review before a final
decision is made and served on the
applicant. See Memorandum from
Andrew Davidson, Chief, Asylum Div.,
USCIS, Modifications to Supervisory
Review of Affirmative Asylum Cases
(Mar. 31, 2021). The decision of the
asylum officer on whether or not to
grant asylum undergoes review by a
supervisor, and may be further reviewed
as USCIS deems appropriate, before
finalization and service on the
applicant. Id. The Departments have
revised 8 CFR 208.14(b) and (c), and
made corresponding revisions to 8 CFR
1208.14(b) and (c), to emphasize these
longstanding review practices. The
Asylum Division also as a matter of
policy determines which cases should
receive further review at the
headquarters level before being
finalized. See, e.g., USCIS Asylum
Division, Affirmative Asylum
Procedures Manual, III.Q. Quality
Assurance Review (May 2016), https://
www.uscis.gov/sites/default/files/
document/guides/AAPM-2016.pdf.
Further, the Director of USCIS, or the
Director’s delegate, ‘‘may direct that any
case or class of cases be certified’’ to
another USCIS official, including the
USCIS Director herself, for decision. See
8 CFR 103.4(a)(1). Accordingly, USCIS
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adjudicates each asylum claim, and the
individual asylum officer is only
empowered to grant asylum, as an
exercise of the Secretary’s authority. See
8 CFR 208.9(a).
If a grant of asylum or withholding of
removal is not warranted, the grant may
be terminated by USCIS or an
immigration judge, as appropriate. See
INA 208(c)(2), 8 U.S.C. 1158(c)(2); 8
CFR 208.24, 1208.24. A grant of CAT
deferral of removal may also be
terminated. See 8 CFR 208.17(d)–(f),
1208.17(d)–(f). The procedures for
termination of a grant of asylum,
withholding of removal, or deferral of
removal is not changed by the rule. Any
further judicial review may occur after
the termination of asylum or other
protection commences.
Moreover, with regard to individuals
who are found eligible for withholding
of removal but not granted asylum, the
rule generally provides an opportunity
for correcting an erroneous finding of
eligibility through the streamlined
section 240 proceeding. For example, if
the DHS attorney becomes aware of new
derogatory information indicating that
the noncitizen is ineligible for that other
protection, such information can be
submitted and accounted for in the IJ’s
removal order. Finally, to the extent this
IFR sets up a process under which,
where an asylum officer declines to
grant a noncitizen’s asylum claim, that
noncitizen can continue to pursue that
claim before an IJ, the IFR does not
break new ground. Rather, in these
respects, the IFR mirrors the
longstanding affirmative asylum
process.
Comments: Several commenters
generally opposed the rule on the
ground that it would delay or otherwise
make it harder for DHS to remove
noncitizens by giving them more
opportunities to appeal. Commenters
expressed concern that delays in
removal, coupled with more expeditious
grants of asylum, would encourage more
irregular migration and incentivize
individuals to make fraudulent claims
for asylum to obtain parole from
detention.
Response: The Departments
acknowledge the commenters’ concern
but disagree with their conclusions. The
rule intends to streamline adjudication
of protection claims, whether granted or
not. As noted in the NPRM, for claims
involving non-detained individuals in
section 240 removal proceedings,
including asylum seekers encountered
at the border and initially screened into
expedited removal who establish a
credible fear of persecution, the current
average case completion time for EOIR
is 3.75 years, and individuals who
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arrive at the border and seek protection
therefore often must wait several years
for an initial adjudication by an IJ. See
86 FR 46909, 46928 tbl. 6. Any appeal
after that adjudication adds even more
time that an individual may expect to
remain in the United States. Given the
length of the process under the status
quo and the streamlining procedures
incorporated into the new process to
promote prompt resolution of removal
proceedings, it is unlikely that the new
process allowed by the rule will result
in further ‘‘delays in removal’’ that
commenters fear may encourage further
irregular migration or incentivize the
filing of non-meritorious claims by
individuals who do not need protection.
The new process replaces a single
section 240 removal proceeding in
immigration court with a merits
interview before an asylum officer,
followed by a streamlined section 240
removal proceeding if USCIS does not
grant asylum. Comments that assume
this new two-step process will result in
greater delays overlook that the new
process is tailored specifically to
adjudicate asylum and related
protection claims, and individuals in
the process will have been determined
by an immigration officer to be
inadmissible under section
235(b)(1)(A)(i) of the INA, 8 U.S.C.
1225(b)(1)(A)(i).53 Additionally, as
detailed in Section III.D of this
preamble, the streamlined 240 removal
proceeding will be governed by special
procedural rules, including time frames
and limits on continuances, that assure
prompt completion. This streamlined
process, as provided by the rule, thus
addresses the commenters’ underlying
concern regarding delays. As explained
in the NPRM, the Departments believe
that this rule will substantially reduce
the average time to adjudicate asylum
claims—whether the final decision is a
grant or a denial—thereby reducing any
incentive for exploitation of the asylum
system.
Comments: Several commenters
generally opposed the rule based on the
view that nearly all the migrants
encountered at or near the Southwest
border are economic migrants, not
legitimate asylum seekers, and that all
such individuals should therefore be
removed without wasting resources on
adjudications and appeals.
53 To be sure, the IFR includes exceptions to these
streamlined section 240 proceedings. One of those
exceptions is for noncitizens who raise a substantial
challenge to the charges of inadmissibility or
removability. See 8 CFR 1240.17(k)(3). Certain
streamlining provisions under 8 CFR 1240.17,
including the deadlines, and the limits on
continuances and extensions of deadlines, will not
apply in cases involving such noncitizens.
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Response: The Departments
acknowledge commenters’ concern that
legitimate asylum seekers be identified
and distinguished from individuals
seeking to enter the United States for
other purposes, and the rule is indeed
designed to more expeditiously and
fairly distinguish the one group from the
other. The Departments disagree with
commenters’ characterization that
nearly all migrants encountered at the
Southwest border are only seeking
economic opportunity. Recent surveys
of individuals seeking to migrate to the
United States have found that
individuals cite a variety of factors,
often in combination, for leaving their
country of origin. While economic
concerns and a belief in American
prosperity and opportunity are common
reasons stated, violence and insecurity
have been cited as reasons for migrating
by majorities or near majorities of those
surveyed.54 And, regardless, Congress
has instructed that individuals in
expedited removal who claim a fear of
persecution or indicate an intent to
apply for asylum be given an
individualized credible fear screening.
INA 235(b)(1)(A)(ii), 8 U.S.C.
1225(b)(1)(A)(ii); see also 8 CFR 208.30.
The purpose of these individualized
screenings is to prevent the removal of
individuals in need of protection to a
country where they face persecution or
torture. Under this IFR, as under current
regulations, individuals who receive a
positive credible fear determination are
given a fair opportunity to pursue their
claim for asylum or other protection.
Individuals who receive a negative
credible fear determination and
individuals who are determined to not
warrant a discretionary grant of asylum
or to be otherwise ineligible for
protection will be subject to removal.
Moreover, by making changes to
facilitate the more frequent use of
expedited removal for broader classes of
individuals and families, the IFR will
enable the Departments to more quickly
secure removal orders in cases in which
no fear claim is asserted or no credible
fear is established than if such
individuals and families were instead
placed directly in removal proceedings,
as frequently occurs.
54 See, e.g., Randy Capps et al., Migration Policy
Institute, From Control to Crisis: Changing Trends
and Policies Reshaping U.S.-Mexico Border
Enforcement 18–19 (Aug. 2019), https://
www.migrationpolicy.org/sites/default/files/
publications/BorderSecurity-ControltoCrisis-ReportFinal.pdf (last visited Mar. 15, 2022); Medicins Sans
Frontieres, Forced to Flee Central America’s
Northern Triangle: A Neglected Humanitarian
Crisis 10–11 (May 2017), https://www.msf.org/sites/
msf.org/files/msf_forced-to-flee-central-americasnorthern-triangle_e.pdf (last visited Mar. 15, 2022).
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Comments: Multiple individual
commenters generally opposing the
proposed rule asserted that the rule,
contrary to its stated purpose, would
most likely increase the backlog of
asylum cases, either because of the
multiple levels of appeal available
whenever an individual’s claim is not
granted or because the rule would likely
encourage more people to enter the
United States and make a fear claim.
Response: The Departments agree that
high rates of asylum applications
relative to historic data are of concern
for both USCIS asylum offices and the
immigration courts. However,
commenters misapprehend the nature of
the review and appeal structure
proposed in the NPRM and finalized, in
modified form, in this IFR. The new
process replaces a single section 240
removal proceeding in immigration
court with an interview before an
asylum officer, which is followed by a
streamlined section 240 removal
proceeding if the asylum officer does
not grant asylum. Commenters assume
that any new two-step process will
increase the backlog of asylum cases,
but the process this IFR establishes is
tailored specifically to adjudicate
asylum claims. Additionally, as detailed
above in Section III.D of this preamble,
unlike an ordinary section 240 removal
proceeding, streamlined section 240
removal proceedings will be governed
by special procedural rules, including
limits on continuances, that assure
prompt completion. As a result, the
process established by this rule is
expected to take less time and assist in
stemming case backlogs relative to the
current process of initially adjudicating
all claims through an ordinary section
240 proceeding, followed by the
possibility of appeal to the BIA and
review by the U.S. Courts of Appeals.
The Departments also disagree with
commenters’ predictions that the rule
would increase the backlog of asylum
cases by encouraging more individuals
to seek asylum or related protection, as
commenters have not identified any
evident causal mechanism by which the
rule as a whole, in context, would
systematically and substantially
incentivize more individuals to seek to
enter the United States and pursue
asylum. On the contrary, the
Departments believe that, by enabling
prompt adjudication of asylum claims—
including the prompt rejection of claims
that lack merit—the rule would
discourage individuals who lack a basis
for asylum or related protection to seek
to enter the United States or claim
protection.
Comments: A few commenters
expressed opposition for each of the
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following reasons: The proposed rule
would change the substantive standard
for asylum eligibility; the proposed rule
would allow noncitizens who entered
the United States without authorization
to ‘‘cut the line’’ ahead of those who
have been awaiting legal immigration
and therefore will be unfair and harmful
to those whose cases are delayed and
will remove incentives for individuals
to pursue legal immigration; and the
proposed rule would automatically
provide for ‘‘immediate’’ U.S.
citizenship. A few commenters also
expressed opposition on the ground that
only elected officials should make
asylum decisions or, alternatively, only
voters should make asylum
determinations. In addition, one
commenter opposing the rule described
it as ‘‘giving two chances at asylum’’
and another commenter described it as
a proposal to ‘‘cut funding for the
detention of asylum seekers.’’
Response: The concerns expressed by
these commenters are based on apparent
factual misunderstandings of the asylum
standards, the asylum adjudications
system, and the effect of an asylum
grant. In that regard, the NPRM would
not have changed, and the IFR does not
change, the standards for qualifying for
asylum. Further, the NPRM would not
have provided, and the IFR does not
provide, ‘‘immediate’’ U.S. citizenship
to anyone. Rather, this rulemaking is
concerned with the system for
adjudicating asylum claims by
noncitizens found to have credible fears
of persecution or torture. While a
noncitizen granted asylum may
eventually apply for and receive
citizenship if certain conditions are met,
a grant of asylum on its own does not
entitle the recipient to citizenship. The
Departments believe that the changes
suggested by these comments either are
not within the scope of the rulemaking
or would be impermissible under
current U.S. law.
Comments: A commenter stated that
the proposed rule would negatively
affect individuals seeking asylum
through the affirmative application
process. The commenter noted that
USCIS has more than 400,000 pending
affirmative asylum cases, and most
cases take more than 180 days to
adjudicate. The commenter stated that
the proposed rule would exacerbate this
backlog by adding to the queue the
asylum claims of individuals in
expedited removal proceedings. While
the commenter acknowledged that the
Departments proposed in the NPRM to
increase staffing levels in order to
implement the new rule, the commenter
stated that these additional resources
should be used to adjudicate existing
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cases in order within the 180-day period
mandated by Congress. Other
commenters stated that the Departments
have not addressed whether the
proposed rule will increase backlogs
and wait times for affirmative cases.
Response: The Departments
acknowledge the commenter’s concern
for individuals with affirmative asylum
cases pending before USCIS but disagree
that this rule will negatively affect them.
As discussed in the NPRM, the
Departments have planned for the new
process described in this rule to be
implemented in phases, as the necessary
staffing and resources are put into place.
A phased implementation will allow the
Departments to begin employing the
proposed process in a controlled
manner for a limited number of cases,
giving USCIS the opportunity to work
through operational challenges and
ensure that each noncitizen placed into
the process is given a full and fair
opportunity to have any protection
claim presented, heard, and properly
adjudicated in full conformance with
the law. As the commenter
acknowledged, USCIS plans to hire new
employees and secure additional
funding to implement this rule so that
it will not be necessary to divert
resources from existing caseloads,
including affirmative asylum, to do so.
USCIS has estimated that it will need to
hire approximately 800 new employees
and spend approximately $180 million
to fully implement the proposed
Asylum Merits interview and
adjudication process to handle
approximately 75,000 cases annually.
While addressing the affirmative asylum
backlog is outside the scope of the
rulemaking, the Departments
acknowledge the importance of doing so
and note that USCIS has taken other
actions to address this priority. These
include expanding facilities; hiring and
training new asylum officers;
implementing operational changes to
increase interviews and case
completions and reduce backlog growth;
establishing a centralized vetting center;
and working closely with technology
partners to develop several tools that
streamline case processing and
strengthen the integrity of the asylum
process.55 In addition, on September 30,
2021, Congress passed the Extending
Government Funding and Delivering
Emergency Assistance Act, which
provides dedicated backlog elimination
funding to USCIS for ‘‘application
55 See USCIS, Backlog Reduction of Pending
Affirmative Asylum Cases: Fiscal Year 2021 Report
to Congress (Oct. 20, 2021), https://www.dhs.gov/
sites/default/files/2021-12/USCIS%20-%20Backlog
%20Reduction%20of%20Pending
%20Affirmative%20Asylum%20Cases.pdf.
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processing, the reduction of backlogs
within asylum, field, and service center
offices, and support of the refugee
program.’’ Public Law 117–43, sec. 132,
135 Stat. 344, 351.
Comments: Some commenters
generally proposed alternative ways to
reduce delays and strain on the U.S.
system for asylum adjudication and
urged the Departments to implement
these alternatives rather than the
proposed rule. Proposed alternatives
included the following actions:
• Taking unspecified actions to
significantly reduce the number of
people crossing the border;
• devoting more resources to the
current asylum process, including
hiring more IJs;
• adopting stricter substantive
standards for demonstrating asylum
eligibility;
• implementing the Migrant
Protection Protocols (‘‘MPP’’);
• criminally prosecuting anyone who
makes a fraudulent asylum claim;
• denying all asylum requests; and
• denying asylum to noncitizens who
cross the border between ports of entry.
Response: The Departments
acknowledge the commenters’
suggestions and recognize that building
an immigration system that works and
maintaining an orderly, secure, and
well-managed border requires multiple
coordinated lines of effort. High
numbers of unauthorized border
crossings, transnational criminal
organizations seeking to profit from a
range of illicit activities, and the
ongoing impact of COVID–19 on the
processing of migrants present
significant challenges along the
Southwest border. DHS has deployed
unprecedented levels of personnel,
technology, and resources and has made
critical security improvements to secure
and manage our borders. The
Departments emphasize that this rule
addresses specifically the way in which
asylum and related protection claims of
certain individuals encountered near
the border are considered, with the aim
of adjudicating those claims in a
timelier manner while ensuring
fundamental fairness. Comments
advocating for other immigration policy
changes that in theory could lead to
fewer individuals making fear claims
are outside the scope of this rulemaking.
The Departments agree that increasing
the number of IJs is part of the solution
to alleviating the current strain on the
U.S. asylum system. The Fiscal Year
2022 President’s Budget requests an
additional 100 IJs and associated
support staff to ensure the efficient and
fair processing of cases, and EOIR will
continue to request funding to add
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additional IJs. See DOJ, FY 2022 Budget
Request, https://www.justice.gov/jmd/
page/file/1398846/download. Given the
increase in the number of immigration
judges requested of and authorized by
Congress during recent budget cycles,
the Fiscal Year 2022 President’s Budget
also requests 100 additional ICE
litigators to prosecute the removal
proceedings initiated by DHS,
consistent with 6 U.S.C. 252(c). See
DHS, ICE Budget Overview Fiscal Year
2022 Congressional Justification ICE–
O&S–22, https://www.dhs.gov/sites/
default/files/publications/u.s._
immigration_and_customs_
enforcement.pdf (explaining that the
ICE Office of the Principal Legal
Advisor currently faces a staffing
budgetary shortfall of several hundred
positions).
b. Negative Impacts on Applicants and
Their Support Systems
Comments: A few commenters
opposed the proposed rule based on
generally stated concerns about negative
consequences for asylum seekers.
Commenters stated that the existing
process for adjudicating asylum claims
originating in credible fear screening is
effective and provides strong legal
protections for asylum seekers,
including the opportunity for judicial
review. Other commenters expressed
concern that any streamlining of the
existing process would result in asylum
seekers being ordered removed without
receiving full and fair consideration of
their protection claims.
Response: The Departments disagree
with the commenters’ premise that any
change from the existing procedure that
seeks to determine relief or protection
claims in a timelier manner will be
detrimental to individuals who are
seeking asylum. The procedure
established by this rule gives
individuals appropriate procedural
protections, as well as an opportunity
for those whose relief or protection
claims are denied to seek judicial
review after exhausting their
administrative remedies. Moreover, as
described above, the Departments are
finalizing the rule with certain changes
from the NPRM that are responsive to
concerns about fairness, such as
retaining USCIS’s authority to entertain
reconsideration of a negative credible
fear determination that has been upheld
by an IJ, specifying a minimum number
of days between a positive credible fear
determination and the Asylum Merits
interview, and eliminating the
restrictions on the evidence applicants
may submit before IJs.
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c. Negative Impacts on U.S. Citizens and
the Economy
Comments: Many commenters
generally opposed the rule due to
concerns that it will lead to increases in
unauthorized immigration, immigration
benefits illegally obtained by fraud, or
lawful immigration that the commenters
perceived as illegitimate. Commenters
expressed concern that such
immigration would have negative effects
on U.S. citizens and the U.S. economy,
including with respect to availability of
housing and other resources, wages and
jobs, public health, costs of schools and
healthcare, crime and safety, the deficit,
and the environment, among other
things. For the most part, commenters
did not provide details about why they
believed that the rule would result in
increased immigration or increased rates
of fraud or misrepresentation. Some
commenters, however, explained that
they believed the rule would drive
increased unauthorized or fraudulent
immigration ‘‘by promising aliens who
have made bogus asylum claims
freedom from detention.’’ Other
commenters explained that they
believed the rule would drive increased
unauthorized or fraudulent immigration
by allowing for nonadversarial merits
adjudications, without an ICE attorney
assigned to cross-examine the applicant
or present impeachment evidence.
Response: The Departments
acknowledge the comments on the
potential negative impacts of lawful
immigration, including the impacts on
wages, jobs, and the labor force.
However, because the rule does not
change the substantive standard for
asylum or related protection, the
Departments do not expect that the rule
will lead to increases in legal
immigration, although it may lead to
some eligible noncitizens receiving
asylum or related protection sooner than
they otherwise would. Section V.B of
this preamble estimates the effects, on a
per-individual, per-day basis, of
individuals receiving employment
authorization earlier as a result of
efficiencies introduced by the rule.
Contrary to commenters’ claims, as
detailed in Section V.B of this preamble,
the increased efficiencies of this IFR
could also result in fewer individuals
who are ineligible for protection
receiving employment authorization, if
their applications are not granted before
the waiting period for employment
authorization under 8 CFR 274a.12(c)(8)
has run. Furthermore, even if there were
reason to believe that the rule may lead
to increases in legal immigration, the
Departments note that commenters did
not provide any data or studies
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supporting negative net impacts of
asylees on U.S. citizens or the U.S.
economy.56
While the Departments acknowledge
the commenters’ concerns about the
negative impacts of unauthorized
immigration and unauthorized entrance
into the United States without
inspection or parole, the Departments
disagree with the commenters that there
is reason to believe that the rule will
result in an increase in the number of
individuals who enter the United States
without inspection or parole, or in an
increase in those who stay beyond their
authorized period of admission. If
anything, by more expeditiously
ordering removed those who are
ineligible for protection, this rule may
send a stronger deterrent signal relative
to the status quo. Moreover, as outlined
above, the United States is undertaking
a range of efforts to address irregular
migration and promote security at the
border. Without additional information
about the mechanism by which
commenters anticipate that this rule
will lead to more unauthorized
migration, the Departments cannot
further evaluate these comments. The
Departments note that the rule does not
‘‘promis[e] . . . freedom from
detention,’’ and the Departments
disagree with the commenters’ concern
about the nonadversarial nature of the
Asylum Merits interview, as previously
explained.
Similarly, while the Departments
appreciate commenters’ concerns about
individuals seeking to obtain asylum or
related protection by fraud or
misrepresentation, the Departments
disagree that there is any reason to
believe that the rule will result in an
increase in either the incidence or
success of such fraud or
misrepresentation. As explained earlier
in Section IV.B.2.a of this preamble, the
Departments are confident that asylum
56 Isolating immigration’s effect on labor markets
has been an ongoing task in the research. A 2017
National Academies of Sciences, Engineering, and
Medicine (‘‘NAS’’) publication synthesizes the
current peer-reviewed literature on the effects of
immigration and empirical findings from various
publications. NAS, The Economic and Fiscal
Consequences of Immigration (2017), https://
www.nap.edu/catalog/23550/the-economic-andfiscal-consequences-of-immigration (last visited
Mar. 5, 2022) (‘‘2017 NAS Report’’). Although this
report is not specific to asylees, its analysis may be
instructive. The report cautions that economic
theory alone is not capable of producing definitive
answers about the net impacts of immigration on
labor markets over specific periods or episodes.
Empirical investigation is needed. But wage and
employment impacts created by flows of foreignborn workers into labor markets are difficult to
measure. The effects of immigration have to be
isolated from many other influences that shape
local and national economies and the relative wages
of different groups of workers. Id. at 4.
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officers have the training, skills, and
experience needed to assess credibility
and appropriately determine asylum
eligibility through a nonadversarial
interview.57 With respect to comments
noting a negative impact of immigration
(whether lawful or unauthorized) on
availability of housing, public health,
costs of schools and healthcare, the
deficit, and the environment, the
comments lacked specific information
expanding on these statements and
explaining how this rule would impact
these areas. Environmental issues are
addressed in Section V.J of this
preamble.
Comments: Numerous commenters
stated that the needs, interests, and
protection of the American people
should come first, and they asserted that
the proposed rule would ‘‘elevate’’
asylum seekers and others who enter the
United States without authorization
above U.S. citizens. Many individual
commenters stated that the asylum
program should be halted, or should not
be changed, until the United States can
support and help its own citizens who
are in need.
Response: The Departments
acknowledge the commenters’ concern
for U.S. citizens, and in particular for
U.S. citizens in need. The Departments
disagree, however, with the
commenters’ assumption that the rule
either prioritizes the interests of asylum
seekers over the interests of U.S.
citizens or will be to the detriment of
the needs, interests, or protection of
U.S. citizens. An asylum system that
more expeditiously determines whether
individuals are or are not eligible for
asylum or other protection in the United
States, while providing due process, is
in the public interest. It complies with
Congress’s instruction in INA 235, 8
57 The approval rate [total cases granted/total
cases granted + total case denied + total cases
referred (USCIS affirmative asylum processing
only)] of asylum officers and IJs on the merits of
asylum claims from Fiscal Years 2017 through 2021
show approval rates for asylum claims adjudicated
by asylum officers to be in the 26–37 percent range,
while IJ approval rates on asylum claims that
started as credible fear screenings ranged from 31–
39 percent and on all asylum claims (regardless of
whether they began in the expedited removal or
credible fear process) ranged from 26–37 percent.
This information suggests that asylum officers are
just as equipped to identify individuals not meeting
asylum eligibility requirements as IJs who use the
adversarial process with the participation of ICE’s
Office of the Principal Legal Advisor to reach a
decision on asylum eligibility. USCIS, Refugee,
Asylum and Int’l Operations Directorate, Asylum
Division Workload Statistics for Affirmative
Asylum 2009 to 2021 (2022); EOIR Adjudications
Statistics: Asylum Decision and Filing Rates in
Cases Originating with a Credible Fear Claim (Jan.
19, 2022), https://www.justice.gov/eoir/page/file/
1062976/download; EOIR Adjudications Statistics:
Asylum Decision Rates (Jan. 19, 2022), https://
www.justice.gov/eoir/page/file/1248491/download.
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U.S.C. 1225, that individuals in
expedited removal be screened for
credible fear of persecution and receive
individualized consideration of their
claims; it allows individuals who are
not eligible for protection to be removed
more promptly, thereby reducing any
incentives to exploit the process; and it
allows individuals who are eligible for
asylum or other protection to sooner
receive that assurance and integrate into
their new community. Some
commenters invoked particular
categories of U.S. citizens in need,
including persons experiencing
unemployment or homelessness,
veterans, persons with disabilities, and
children in foster care, but the
commenters did not provide any
explanation or information to support
the idea that this rule will operate to the
detriment of these groups, or to support
the idea that halting the asylum
program—as some commenters
proposed—would benefit these groups.
The Departments note that the rule’s
potential and uncertain impacts on the
U.S. labor force are analyzed in Section
V.B of the preamble.
Comments: Multiple commenters
stated generally that asylees’
dependence on Government programs
for support would lead to an undue
burden on American taxpayers,
exacerbation of the U.S. deficit, or
increased costs of education and
healthcare in the communities where
asylees live.
Response: The Departments
appreciate commenters’ concern that
public costs at the Federal, State, or
local level might accompany increases
in the number of individuals granted
asylum in the United States. However,
these general comments did not provide
information or explanation to support
either (1) the premise that this rule will
lead to more individuals being granted
asylum in the United States, or (2) the
premise that increases in the number of
individuals granted asylum in the
United States would, on net, lead to
increased public costs or costs of
education or healthcare. The
Departments believe that the IFR is
unlikely to lead to significant increases
in the number of individuals granted
asylum in the United States, much less
to increased public costs or costs of
education or healthcare that outpace
asylees’ contributions in taxes and
economic activity. A more detailed
explanation of the possible impacts of
this rule is provided in Section V.B of
this preamble. Additionally, the
Departments emphasize that estimating
the fiscal impacts of immigration is a
complex calculation. The first-order net
fiscal impact of immigration is the
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difference between the various tax
contributions the immigrants in
question make to public finances and
the Government expenditures on public
benefits and services they receive. These
first-order impacts are sensitive to
immigrants’ demographic and skill
characteristics, their role in labor and
other markets, and the rules regulating
accessibility and use of Government
programs.58 In addition, second-order
effects may also occur, and analysis of
such effects presents methodological
and empirical challenges. For example,
as with the native-born population, the
age structure of an immigrant
population plays a major role in
assessing any fiscal impacts. Children
and young adults contribute less to
society in terms of taxes and draw more
in benefits by using public education,
for example. On average, as people age
and start participating in the labor
market, they become net contributors to
public finances, paying more in taxes
than they draw from public benefit
programs. Moreover, older adults could
again become net users of public benefit
programs. Compared to the native-born
population, immigrants can also differ
in their characteristics in terms of skills,
education levels, income levels, number
of dependents in the family, the places
they choose to live, etc., and any
combination of these factors could have
varying fiscal impacts. Local and State
economic conditions and laws that
govern public finances or the
availability of public benefits also vary
and can influence the fiscal impacts of
immigration.
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d. Other General Opposition to the
Proposed Rule
Comments: Many commenters stated
that asylum seekers should remain in
Mexico during the pendency of their
immigration hearings or otherwise
generally referred to the Migrant
Protection Protocols (‘‘MPP’’). Similarly,
other commenters asked the Department
to clarify how the rule may comply or
conflict with MPP. Specifically,
commenters raised concerns regarding
implementation of the program,
litigation surrounding MPP, as well as
alternative proposals for MPP.
Response: Because MPP is decidedly
separate from the expedited removal
and credible fear process, comments
concerning MPP are outside the scope of
the changes made in this rule.59 The
58 See
generally 2017 NAS Report at 323–27.
processed for expedited removal
are excluded from MPP, as that program is being
implemented in compliance with the court order in
Texas v. Biden, No. 2:21–cv–67, —F. Supp. 3d. —,
2021 WL 3603341 (N.D. Tex. Aug. 13, 2021). By its
terms, MPP applies only to noncitizens initially
59 Individuals
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Departments appreciate engagement and
concerns related to MPP, but discussion
of the program, ongoing litigation, and
DHS’s efforts to terminate the program
are outside the scope of this rulemaking.
Moreover, the Secretary of DHS has
already explained in detail his reasons
for terminating MPP and his decision
not to use the contiguous-territoryreturn authority on a programmatic
basis.60
C. Basis for the Proposed Rule
1. DOJ and DHS Statutory/Legal
Authority
Comments: Many individual
commenters generally argued that the
Departments do not have the statutory
or legal authority to issue the rule, but
the commenters did not provide a basis
for their belief. Some individual
commenters stated that the rule is
unlawful, bypasses Congress, or cannot
be issued as an executive decision.
Response: The Departments believe
that these general comments
misapprehend or misstate the legal
authorities involved in this rulemaking.
As noted above in Section II.B of this
preamble, asylum, statutory
withholding of removal, and protection
under the CAT are established or
required by statute. See INA 208, 8
U.S.C. 1158; INA 241(b)(3), 8 U.S.C.
1231(b)(3); FARRA sec. 2242. This rule
does not seek to bypass Congress or
otherwise act where Congress has not
given the Departments authority. This
placed into section 240 proceedings, not the
noncitizens at issue here, who are initially placed
into expedited removal proceedings. See
Memorandum from Robert Silvers, Under Secretary,
Office of Strategy, Policy, and Plans, Guidance
Regarding the Court-Ordered Reimplementation of
the Migrant Protection Protocols 4 (Dec. 2, 2021),
https://www.dhs.gov/sites/default/files/2022-01/21_
1202_plcy_mpp-policy-guidance_508.pdf. Nor does
MPP eliminate expedited removal as an option for
processing certain inadmissible noncitizens arriving
in the United States. Some individuals—e.g.,
Mexican nationals or nationals of countries outside
the Western Hemisphere—may be eligible for
processing through expedited removal but could
not be considered for processing under MPP, which
explicitly excludes certain categories of
noncitizens. Additionally, the permanent
injunction in Texas v. Biden specifically preserves
the Secretary of DHS’s discretion to make
individual determinations about how to process a
particular individual. See Texas v. Biden, 2021 WL
3603341, at *27. That discretion encompasses
whether to process a specific noncitizen for 240
proceedings or expedited removal. See Matter of E–
R–M– & L–R–M–, 25 I&N Dec. 520 (BIA 2011).
60 See Memorandum from Alejandro N.
Mayorkas, Secretary of Homeland Security,
Termination of Migrant Protection Protocols (Oct.
29, 2021), https://www.dhs.gov/sites/default/files/
publications/21_1029_mpp-termination-memo.pdf;
DHS, Explanation of the Decision to Terminate the
Migrant Protection Protocols (Oct. 29, 2021),
https://www.dhs.gov/sites/default/files/
publications/21_1029_mpp-terminationjustification-memo.pdf.
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rule is consistent with statutory
authority provided by Congress, and it
is intended to create efficiencies in
implementing a framework allowing for
fair, consistent adjudications.
Comments: Commenters argued that
the Homeland Security Act of 2002
expressed congressional intent that
defensive asylum claims be adjudicated
by IJs rather than asylum officers by
granting EOIR the authority to
adjudicate these claims but making no
such provision for USCIS. Moreover,
commenters noted that because the HSA
specified the date on which powers
would be vested in USCIS, Congress did
not intend that the Departments be able
to reallocate the authorities of IJs and
asylum officers through regulations and
that Congress has decided not to
reallocate authorities relevant to the
proposed rule since 2003. Another
comment argued that the Illegal
Immigration Reform and Immigrant
Responsibility Act expressed
congressional intent that asylum seekers
found to have a credible fear of
persecution have their cases adjudicated
by IJs. One comment cited IIRIRA
legislative history in arguing that the
credible fear interview’s purpose is to
‘‘weed out non-meritorious cases’’ and
that asylum proceedings should be
overseen by an IJ. One commenter
asserted that legislative proposals under
consideration in both the House and the
Senate demonstrate Congress’s interest
in asylum policy and in immigration
policy generally. The commenter argued
that gridlock in Congress does not give
executive agencies a ‘‘free pass’’ to
overstep the legislative directives given
to them by Congress.
Response: The Departments believe
that these comments misapprehend or
misstate the legal authorities involved
in this rulemaking. This rule does not
seek to bypass Congress or otherwise act
where Congress has not given the
Departments authority. If an asylum
officer determines that a noncitizen has
a credible fear of persecution, the
noncitizen ‘‘shall be detained for further
consideration of the application for
asylum.’’ INA 235(b)(1)(B)(ii), 8 U.S.C.
1225(b)(1)(B)(ii). The statute, however,
‘‘does not specify how or by whom this
further consideration should be
conducted.’’ Inspection and Expedited
Removal of Aliens; Detention and
Removal of Aliens; Conduct of Removal
Proceedings; Asylum Procedures, 62 FR
444, 447 (Jan. 3, 1997).
By not specifying what ‘‘further
consideration’’ entails, the statute leaves
it to the agency to determine. Under
Chevron, it is well-settled that such
‘‘ambiguity constitutes an implicit
delegation from Congress to the agency
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to fill in the statutory gaps.’’ FDA v.
Brown & Williamson Tobacco Corp., 529
U.S. 120, 159 (2000) (citing Chevron,
467 U.S. at 844); see also Epic Sys.
Corp., 138 S. Ct. at 1629 (noting that
Chevron rests on ‘‘the premise that a
statutory ambiguity represents an
implicit delegation to an agency to
interpret a statute which it administers’’
(quotation marks omitted)). An agency
may exercise its delegated authority to
plug the gap with any ‘‘reasonable
interpretation’’ of the statute. Chevron,
467 U.S. at 844.
By its terms, the phrase ‘‘further
consideration’’ is open-ended. The fact
that Congress did not specify the nature
of the proceedings for those found to
have a credible fear contrasts starkly
with two other provisions in the same
section that expressly require or deny
section 240 removal proceedings for
certain other classes of noncitizens. In
one provision, INA 235(b)(2)(A), 8
U.S.C. 1225(b)(2)(a), Congress provided
that an applicant for admission who ‘‘is
not clearly and beyond a doubt entitled
to be admitted’’ must be ‘‘detained for
a proceeding under section [INA 240].’’
And in another, INA 235(a)(2), 8 U.S.C.
1225(a)(2), Congress provided that ‘‘[i]n
no case may a stowaway be considered
. . . eligible for a hearing under section
[INA 240].’’ These examples show that
Congress knew how to specifically
require immediate referral to a section
240 removal proceeding when it wanted
to do so. ‘‘Where Congress includes
particular language in one section of a
statute but omits it in another section of
the same Act, it is generally presumed
that Congress acts intentionally and
purposely in the disparate inclusion or
exclusion.’’ Salinas, 141 S. Ct. at 698
(quotation marks omitted).
The D.C. Circuit has ‘‘consistently
recognized that a congressional mandate
in one section and silence in another
often suggests not a prohibition but
simply a decision not to mandate any
solution in the second context, i.e., to
leave the question to agency discretion.’’
Catawba Cnty., 571 F.3d at 36
(quotation marks omitted). The
suggestion that Congress’s silence in
section 235(b)(1) of the INA, 8 U.S.C.
1225(b)(1), permits the Departments
discretion to establish procedures for
‘‘further consideration’’ is reinforced by
the fact that the noncitizens whom DHS
has elected to process using the
expedited removal procedure are
expressly excluded from the class of
noncitizens who are statutorily
guaranteed section 240 removal
proceedings under section 235(b)(2)(A)
of the INA, 8 U.S.C. 1225(b)(2)(A). See
INA 235(b)(2)(B)(ii), 8 U.S.C.
1225(b)(2)(B)(ii).
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The Departments disagree with the
comments arguing that any statute
requires asylum cases to be adjudicated
through an adversarial process. The rule
is designed to implement the statute,
which does not specify what ‘‘further
consideration of [an] application for
asylum’’ entails and which thereby
leaves it to the agency to determine
what will occur when an individual
placed in expedited removal is found to
have demonstrated a credible fear of
persecution. INA 235(b)(1)(B)(ii), 8
U.S.C. 1225(b)(1)(B)(ii). Nothing in the
asylum statute requires the Secretary of
Homeland Security to establish an
adversarial procedure to determine
whether a noncitizen may be granted
asylum.
The Departments also disagree with
the comments that defensive asylum
applications are statutorily required to
be adjudicated by DOJ instead of by
DHS. The asylum statute provides that
specified noncitizens ‘‘may apply for
asylum,’’ including ‘‘in accordance with
. . . [INA 235(b), 8 U.S.C. 1225(b)],’’
INA 208(a)(1), 8 U.S.C. 1158(a)(1), and
that ‘‘[t]he Secretary of Homeland
Security or the Attorney General may
grant asylum to [a noncitizen] who has
applied for asylum in accordance with
the requirements and procedures
established by the Secretary of
Homeland Security or the Attorney
General under [the asylum statute] if the
Secretary of Homeland Security or the
Attorney General determines that such
[noncitizen] is a refugee,’’ INA
208(b)(1)(A), 8 U.S.C. 1158(b)(1)(A).
Section 208(b)(1)(A) of the INA does not
distinguish between affirmative and
defensive asylum applications, and its
text—‘‘may grant asylum,’’ indicating
that the Secretary of Homeland Security,
on considering an asylum application,
may determine not to grant it—confers
adjudicatory authority.
Cross-references between the asylum
statute and the expedited removal
statute provide further support for the
conclusion that the asylum statute
authorizes DHS to adjudicate defensive
asylum applications. See, e.g., INA
208(a)(1), 8 U.S.C. 1158(a)(1) (citing INA
235(b), 8 U.S.C. 1225(b)); INA
235(b)(1)(A)(i), (ii), 8 U.S.C.
1225(b)(1)(A)(i), (ii) (citing INA 208, 8
U.S.C. 1158). The legislative history of
the asylum statute supports this reading
as well. Prior to 2005, section
208(b)(1)(A) referred only to the
Attorney General. See INA 208(b)(1)
(2000), 8 U.S.C. 1158(b)(1) (2000).
Congress specifically added in certain
references to the Secretary of Homeland
Security in the REAL ID Act of 2005 and
backdated the references’ effectiveness
to the HSA’s effective date. Public Law
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109–13, div. B, 101(a)(1), (2), (h)(1), 119
Stat. 231.61 In addition, the REAL ID
Act’s conference report explains that the
Act amended INA 208(b)(1) ‘‘to clarify
that the Secretary of Homeland Security
and the Attorney General both have
authority to grant asylum,’’ ‘‘[b]ecause
both the Secretary of Homeland Security
and the Attorney General may now
exercise authority over asylum
depending on the context in which
asylum issues arise.’’ H.R. Rep. No. 109–
72, at 162 (2005).
Last, although the Departments
acknowledge that some statements in
IIRIRA’s legislative history could be
read to suggest an expectation that
noncitizens detained for ‘‘further
consideration’’ would be placed in
‘‘normal non-expedited removal
proceedings,’’ see, e.g., H.R. Rep. No.
104–828, at 209 (1996), the legislative
history is inconsistent and, in any event,
‘‘legislative history is not the law,’’ Epic
Sys., 138 S. Ct. at 1631. The
Departments decline to read a limitation
from the inconsistent legislative history
into otherwise open-ended statutory
text.
Comments: Several commenters
remarked that the proposed rule would
create a rushed adjudication process in
violation of U.S. obligations under both
domestic and international law and
contrary to United Nations High
Commissioner for Refugees (‘‘UNHCR’’)
guidance. Pursuant to such guidance,
commenters recommended that the
Departments make efforts to maximize
asylum seekers’ access to counsel and
argued that the detention of asylum
seekers poses obstacles in this regard.
Another commenter requested that no
part of the asylum process, including
the credible fear interview, should occur
in a U.S. Customs and Border Protection
facility. Similarly, another commenter
cited UNHCR guidance and argued that
accelerated procedures must, under
international law, minimize risks of
non-refoulement by giving asylum
seekers guidance on the procedure itself
and access to necessary facilities,
including a competent interpreter, for
submitting a protection claim, as well as
the right to appeal a negative fear
determination.
Response: The Departments disagree
with the commenters that the
procedures for considering protection
claims promulgated in this rule violate
U.S. or international law. As an initial
61 That is not to say that the Secretary lacks other
authorities in INA 208, 8 U.S.C. 1158, where
Congress did not expressly add the Secretary in the
REAL ID Act of 2005. Since enactment of the HSA,
Congress has inserted piecemeal references to the
Secretary in various provisions of the INA without
doing so comprehensively.
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note, while the Departments do consider
and value UNHCR guidance in
interpreting the United States’
obligations under the 1967 Refugee
Protocol, such guidance is not binding.
The Departments agree with the
commenters on the need to provide
access to counsel to individuals making
fear claims and have done so in this
rule. For example, 8 CFR 235.3(b)(4)(ii)
provides that prior to a credible fear
interview, a noncitizen shall be given
time to contact and consult with any
person or persons of their choosing. In
8 CFR 208.30(d)(4), DHS provides that
such person or persons may be present
at the credible fear interview. In 8 CFR
208.9(b), DHS provides that individuals
may have counsel or a representative
present at affirmative asylum interviews
or Asylum Merits interviews. In 8 CFR
1240.3 and 1240.10(a)(1), DOJ provides
that noncitizens may have
representation in section 240
proceedings before the IJ. The
provisions at 8 CFR 1240.3 and
1240.10(a)(1) will apply in removal
proceedings under this rule; though
these proceedings are streamlined,
noncitizens in them will have the right
to representation at no expense to the
Government. Furthermore, the
Departments plan to ensure as part of
the service of the positive credible fear
determination, where an individual is
placed in the Asylum Merits process,
that they are provided with a fact sheet
explaining the process and a contact list
of free or low-cost legal service
providers similar to what the individual
would be provided if they were issued
an NTA and placed into section 240
removal proceedings before EOIR.
The Departments agree with the
commenters that individuals subject to
an accelerated procedure, such as a
credible fear screening within expedited
removal, should be provided guidance
about the procedure, including
information about the right to review of
a negative credible fear determination.
In 8 CFR 235.3(b)(4)(i), DHS continues
to provide that individuals referred for
credible fear interviews receive a
written disclosure on Form M–444,
Information About Credible Fear
Interview, describing ‘‘[t]he purpose of
the referral and description of the
credible fear interview process’’; ‘‘[t]he
right to consult with other persons prior
to the interview and any review thereof
at no expense to the United States
Government’’; ‘‘[t]he right to request a
review by an [IJ] of the asylum officer’s
credible fear determination’’; and ‘‘[t]he
consequences of failure to establish a
credible fear of persecution or torture.’’
Additionally, for every credible fear
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interview, asylum officers are trained to
explain the purpose of the interview
and ensure the individual understands.
In addition, 8 CFR 208.30(d)(2) requires
asylum officers conducting credible fear
interviews to verify that the noncitizen
has received Form M–444, Information
About Credible Fear Interview, and to
determine that they understand the
credible fear determination process.
Under this rule, if an asylum officer
determines an individual does not have
a credible fear of persecution or torture,
the asylum officer must refer the
individual to an IJ if the individual
requests review or refuses or fails to
indicate whether he or she requests
review of the asylum officer’s credible
fear determination. 8 CFR 208.30(g)(1),
1208.30(g)(2)(i). The process for IJ
review of negative credible fear
determinations involves the creation of
a record of proceeding, the receiving of
evidence, the provision of interpreters,
and the right to consult with a person
or persons of the individual’s choosing
prior to the review. See INA
235(b)(1)(B)(iv), 8 U.S.C.
1225(b)(1)(B)(iv); 8 CFR 1003.42.
The Departments further agree with
commenters on the need to provide
competent interpretation. In 8 CFR
208.30(d)(5), DHS continues to provide
that asylum officers conducting credible
fear interviews will arrange for the
assistance of an interpreter for
noncitizens unable to proceed
effectively in English where the asylum
officer is unable to proceed competently
in a language the alien speaks and
understands. The rule provides in 8 CFR
208.9(g)(2) that asylum officers
conducting Asylum Merits interviews
will arrange for interpreter services for
applicants unable to proceed effectively
in English. Similarly, EOIR will provide
interpretation services in credible fear
determinations and hearings before an
IJ. 8 CFR 1003.42(c), 1240.5. The
Departments have mechanisms in place
to ensure the quality of interpretation,
including the absence of improper bias.
These include training adjudicators to
recognize signs of potential problems
with interpretation and taking
appropriate remedial measures;
channels to report interpretation issues
to the contracting entities providing
interpretation services; and the periodic
review of the terms and conditions of
interpretation services contracts.
Regarding the commenters’
opposition to the detention of asylum
seekers, the Departments note that INA
235(b)(1)(B)(iii)(IV), 8 U.S.C.
1225(b)(1)(B)(iii)(IV), provides that
individuals receiving credible fear
interviews ‘‘shall be detained pending a
final determination of credible fear of
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persecution and, if found not to have
such a fear, until removed.’’ INA
235(b)(1)(B)(ii), 8 U.S.C.
1225(b)(1)(B)(ii), further provides that
noncitizens who receive a positive
credible fear determination ‘‘shall be
detained for further consideration of the
application for asylum.’’ However, the
INA additionally authorizes the
Secretary to parole into the United
States temporarily, on a case-by-case
basis, such individuals ‘‘for urgent
humanitarian reasons or significant
public benefit.’’ INA 212(d)(5)(A), 8
U.S.C. 1182(d)(5)(A). And as explained
in more detail above, the Departments
have provided in this rule for the reform
of certain regulatory provisions
implementing this statutory authority
for individuals detained in the
expedited removal process and for those
pending a credible fear determination or
any review thereof.
Similarly, the Departments disagree
with commenters’ proposal of
disallowing credible fear interviews by
USCIS asylum officers in CBP facilities
during the credible fear process and
note that this proposal is outside the
scope of this rulemaking. Given the
expedited nature of credible fear
interviews and their role in initial
processing of a covered noncitizen, CBP
plays an important role in referral of
claims of fear to a USCIS asylum officer.
While the Departments have
implemented safeguards to decouple
law enforcement aims from the sensitive
nature of protection screening, DHS and
DOJ will remain flexible in how they
use DHS facilities.
2. Need for the Proposed Rule/DOJ and
DHS Rationale
Comments: A commenter stated that
the rule would create stronger ‘‘pull
factors’’ encouraging foreign nationals to
take advantage of quick release on
parole and with the expectation that
they would be able to live and work in
the United States indefinitely while
seeking asylum through an even more
extended process than now exists. Other
commenters argued that the proposed
rule would lead to granting more
asylum applications and that such an
outcome is inappropriate because most
asylum applications are not meritorious.
Another commenter similarly argued
that requiring noncitizens to prove their
worthiness for a ‘‘discretionary form of
relief’’ is required under existing laws
and consistent with congressional
intent; the commenter faulted the
proposal for, in the commenter’s view,
disregarding the requirements of the
expedited removal statute.
Conversely, a commenter stated that
the proposed rule wrongly assumes that
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asylum seekers at the border are more
likely to have fraudulent claims and
suggested imposing section 240
proceedings as the mechanism for
review of asylum officer adjudication.
The commenter cited a statistic that
found that ‘‘83 percent of [affirmative
asylum] cases that asylum officers did
not grant after interview were
subsequently granted asylum by the
immigration courts in 2016.’’ Another
commenter noted that the increase in
credible fear referrals in the past decade
more likely resulted from the
deterioration of human rights conditions
in nearby countries rather than an
increase in fraudulent claims.
Response: The Departments disagree
with the generalized belief that the
availability of parole in accordance with
INA 212(d)(5), 8 U.S.C. 1182(d)(5),
serves as a pull factor for individuals
who would be covered by this process.
As stated above in Section IV.B.2.a of
this preamble, recent surveys of
individuals seeking to migrate to the
United States have found that
individuals cite a variety of factors,
often in combination, for leaving their
country of origin. While economic
concerns and a belief in American
prosperity and opportunity are common
reasons stated, violence and insecurity
have been cited as reasons for migrating
by majorities or near majorities of those
surveyed.62 To the extent that
individuals are motivated by economic
concerns, the mere possibility of parole
out of custody marginally earlier—based
on an individualized determination—is
not expected to significantly increase or
alter the incentives that lead an
individual to journey to the United
States or remain in their country of
origin. Importantly, noncitizens in
expedited removal who are paroled
prior to a credible fear determination
(that is, the noncitizens affected by this
IFR’s amendment to the regulations
concerning parole) will not be eligible
for employment authorization based on
having been paroled.
As to the claim that the majority of
asylum applications are fraudulent, the
Departments disagree. This assertion is
not supported by fact. Moreover, denied
asylum claims are not necessarily
fraudulent. If an individual is not
granted asylum or related protection by
a USCIS asylum officer, it may be
because they are ineligible for
protection or have not shown that they
merit a discretionary grant of asylum. In
addressing commenters’ concern about
the percentage of affirmative asylum
applications that were not granted by
USCIS but subsequently granted asylum
62 See
supra note 54.
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by EOIR, the Departments note that
numerous factors may explain this
difference in outcomes, including that
the IJ may be presented with additional
evidence and testimony beyond what
was heard by the asylum officer, and
that the IJ may consider the asylum
claim in light of changed circumstances
underlying the application since the
asylum officer’s decision. INA
208(a)(2)(D), 8 U.S.C. 1158(a)(2)(D).
Comment: Many commenters
expressed concern for ensuring balance
between fairness and efficiency.
Commenters noted that addressing
immigration backlogs should be the
Departments’ priority, but the
commenters also stated that procedural
safeguards must be retained. Other
commenters supported the
implementation of a nonadversarial
hearing process but asserted that due
process concerns related to the
expedited removal process could
undermine the Departments’ goals of
improving fairness or efficiency.
Another commenter stated that
compressed timelines may harm
applicants who need time to develop
trust in their attorneys and the asylum
system.
Response: The Departments agree that
addressing the backlog of cases should
be a priority, and applicants for asylum
and related protection must be given
due process. The Departments
anticipate this rule will divert certain
cases from immigration court and will
enhance efficient processing of
noncitizens subject to the expedited
removal process, thereby stemming the
growth of EOIR’s current backlog. The
Departments also agree that ensuring
fairness while being efficient may take
time to execute on a national scale. It is
for that reason that the Departments
adopt a phased approach such that
efficiencies can be developed while
fairness is not lost due to administrative
exigencies. While asylum applications
are governed by a statutory timeline and
this rule also uses a timeline to ensure
applications stay on track, the
Departments have incorporated
safeguards to ensure that integrity is not
compromised for the sake of
administrative efficiency. Specifically,
as noted in the regulatory text, the IFR
provides for appropriate exceptions to
the timelines at various stages of the
asylum case, including submission of
late-filed evidence and the timing of
scheduled hearings.
Comments: Comments attributed the
immigration court backlog to ‘‘confusing
and rapid fluctuations in the agencies’
interpretation of the particular social
group definition,’’ changes in DHS
prosecutorial discretion policies,
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policies divesting IJs of authority to
control their dockets, BIA and Attorney
General opinions that preclude IJs from
relying on parties’ stipulations, and
office and court closures resulting from
the COVID–19 pandemic.
Response: The Departments recognize
commenters’ concerns that numerous
factors may impact the pending
caseload. Accordingly, there may be
numerous individual and combined
approaches for addressing this issue.
The Departments will not discuss at
length the potential factors identified by
commenters, as they are largely outside
of the scope of this rulemaking.
However, the Departments note that
the goal of this IFR is to implement
more efficient procedures for
adjudicating certain protection-based
claims. This will, in turn, help address
the pending caseload while also
ensuring that such cases are given
appropriate full and fair consideration.
To the extent that the IFR limits IJs’
authority to fully control their dockets,
for example by establishing a regulatory
timeline for scheduling and
adjudicating these claims, the
Departments believe that this regulatory
schedule will ensure efficient
processing of such claims while also
permitting sufficient flexibility for IJs to
deviate from the schedule by granting
continuances where appropriate.
Comments: One commenter stated
that expediting the processing of asylum
claims will not solve the current border
crisis if the Administration also expands
the categories of eligibility for asylum
and stated that an improvement to
asylum efficiency requires a
combination of tightening the screening
standards of eligibility for asylum and
faster processing, including swift
removal of those with meritless claims.
Another commenter asserted that the
Departments must not only consider
immigration through a national security
perspective, but must also pay attention
to ‘‘humanitarian protection, legal
immigration and naturalization, foreign
student education and cultural
exchange, and economic
competitiveness.’’ The commenter
expressed approval of the proposal in
light of the challenges posed by
backlogs. Conversely, at least one other
commenter stated that the Departments
should focus more on national security.
Response: The Departments agree that
fair and efficient processing of asylum
claims is in the interest of the American
people. Such a program of humanitarian
protection not only speaks to American
values of altruism, inclusiveness, and
charity but is necessarily tied to our
national security and economic
interests. See, e.g., Deborah E. Anker &
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Michael H. Posner, The Forty Year
Crisis: A Legislative History of the
Refugee Act of 1980, 19 San Diego L.
Rev. 9 (1981) (noting that humanitarian
protection speaks to American values).
National security is a critical aspect of
the asylum and refugee protection
programs, not only because the
Departments vet applicants to ensure
they are not ineligible for asylum on
national security grounds, but also
because ensuring a safe haven for
forcibly displaced persons around the
world can promote national security.
See, e.g., Elizabeth Neumann, Robust
Refugee Programs Aid National Security
(Dec. 17, 2020), https://
immigrationforum.org/wp-content/
uploads/2020/12/Robust-RefugeePrograms-Aid-National-Security12_16_
20.pdf (last visited Mar. 14, 2022). In
this rule, the Departments are not
expanding asylum eligibility, but
putting forward procedures that will use
their respective resources to more
effectively and efficiently issue
decisions on protection claims. The
Departments believe that such
efficiencies will allow meritorious
claims to be granted more promptly and
will facilitate removal of those
individuals who do not warrant
protection from removal.
3. Prior Immigration Rulemakings
Comments: Two commenters
expressed support for the immigration
rulemakings finalized during the prior
Administration, stating that they kept
borders safe and reduced the flow of
unauthorized migrants. However, one
commenter stated that the prior
Administration destroyed the
immigration system by overturning
previously accepted legal
interpretations and implementing
procedures to deny people asylum.
Another commenter expressed support
for abandoning regulatory changes
implemented under the prior
Administration that obstructed access to
asylum relief. One commenter stated
that the proposed changes to the
screening process for people in
expedited removal proceedings are an
important improvement over the
previous regulatory changes
implemented under the prior
Administration.
A commenter asserted that neither the
Global Asylum rule nor the Security
Bars rule should be implemented, as
their provisions are incompatible with
international legal standards and could
have risks for individuals seeking
protection in the United States. Another
commenter suggested that, to ensure
cases move quickly through asylum
offices and court systems without delay,
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DHS and DOJ should reverse the prior
rules and policies such as the TCT Bar
rule, Presidential Proclamation Bar IFR,
Global Asylum rule, and Security Bars
rule.
A commenter stated that two asylumrelated rules, the Global Asylum rule
and Procedures for Asylum and Bars to
Asylum Eligibility, 85 FR 67202 (Oct.
21, 2020) (‘‘Criminal Bars to Asylum
rule’’), issued by the prior
Administration were issued in violation
of the HSA and the Federal Vacancies
Reform Act (‘‘FVRA’’) and did not
provide sufficient time for public
comment on their ‘‘complicated
provisions.’’ Therefore, the commenter
said, both rules are null and void. The
commenter also asserted that the
provision of the Global Asylum rule that
forced people into asylum-andwithholding-only proceedings was
inconsistent with the INA, as Congress
created a default rule that arriving
individuals seeking asylum are to be
placed in section 240 removal
proceedings. The commenter also wrote
that DHS and DOJ acted arbitrarily and
capriciously by requiring individuals
with credible fear findings to be placed
in asylum-and-withholding-only
proceedings.
Another commenter stated that DHS
should continue to rescind employment
authorization rules issued by the prior
Administration because they were
issued by agency officials in violation of
the Administrative Procedure Act
(‘‘APA’’). With respect to employment
authorization based on a pending
asylum application, the commenter said
this Administration should immediately
restore the 150-day waiting period and
30-day processing time requirement for
asylum seekers.
Response: The Departments are
revisiting and reconsidering numerous
asylum-related rulemakings and policies
in accordance with Executive Order
14010, Creating a Comprehensive
Regional Framework to Address the
Causes of Migration, To Manage
Migration Throughout North and
Central America, and To Provide Safe
and Orderly Processing of Asylum
Seekers at the United States Border
(‘‘E.O. on Migration’’), and the E.O. on
Legal Immigration. The E.O. on
Migration provides that the ‘‘United
States will . . . restore and strengthen
our own asylum system, which has been
badly damaged by policies enacted over
the last 4 years that contravened our
values and caused needless human
suffering.’’ 86 FR 8267. The E.O. on
Migration directs the Departments to
determine whether to rescind various
rules, such as the Presidential
Proclamation Bar IFR, the TCT Bar rule,
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and other policies, which the
Departments have been reviewing and
reconsidering. See 86 FR 8269–70. In
addition, the E.O. on Legal Immigration
instructed the Secretary of State,
Attorney General, and Secretary of
Homeland Security to ‘‘identify barriers
that impede access to immigration
benefits and fair, efficient adjudications
of these benefits and make
recommendations on how to remove
these barriers.’’ 86 FR 8277. The
Departments have outlined several
rulemaking efforts in the Spring and
Fall 2021 Unified Agenda of Regulatory
and Deregulatory Actions, consistent
with the E.O. on Migration and the E.O.
on Legal Immigration.63 The
Departments plan to address the
Presidential Proclamation Bar IFR, TCT
Bar rule, Criminal Bars to Asylum rule,
and other provisions of the Global
Asylum rule in separate rulemakings.
The Departments acknowledge the
commenter’s concerns about the
regulatory changes made in the Global
Asylum rule, which are enjoined,
related to placing noncitizens with
positive credible fear determinations in
asylum-and-withholding-only
proceedings. As explained earlier in this
IFR, the Departments are amending
regulations to allow for USCIS to retain
such noncitizens’ asylum applications
for a nonadversarial Asylum Merits
interview before an asylum officer,
rather than initially refer them to an IJ
for asylum-and-withholding-only
proceedings, as provided in the
presently enjoined regulation. See 8
CFR 208.30(f). Meanwhile, DHS
maintains the discretion to place a
covered noncitizen in, or to withdraw a
covered noncitizen from, expedited
removal proceedings and issue an NTA
to place the noncitizen in section 240
removal proceedings at any time after
they are referred to USCIS for a credible
fear determination. See 8 CFR 208.30(b),
(f); Matter of J–A–B– & I–J–V–A–, 27 I&N
Dec. at 171; Matter of E–R–M– & L–R–
M–, 25 I&N Dec. 520, 523–24 (BIA
2011).
On December 23, 2020, the
Departments published the Security
Bars rule, which was scheduled to
become effective on January 22, 2021.
The effective date of the Security Bars
rule has been delayed several times,
63 See Executive Office of the President, OMB,
OIRA, Spring 2021 Unified Agenda of Regulatory
and Deregulatory Actions, https://www.reginfo.gov/
public/do/eAgendaHistory (last visited Mar. 14,
2022) (select ‘‘Spring 2021 Unified Agenda of
Regulatory and Deregulatory Actions,’’ then select
DHS or DOJ); Executive Office of the President,
OMB, OIRA, Fall 2021 Unified Agenda of
Regulatory and Deregulatory Actions, https://
www.reginfo.gov/public/do/eAgendaMain (last
visited Mar. 14, 2022) (select DHS or DOJ).
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most recently until December 31,
2022.64 Thus, the Security Bars rule is
not currently in effect. The Departments
are reviewing and reconsidering the
Security Bars rule and plan to publish
a separate NPRM to solicit public
comments on whether to modify or
rescind the Security Bars rule.65 The
commenters’ claims related to these
rules, the rules related to employment
authorization for noncitizens with
pending asylum applications,66 and the
HSA, APA, and FVRA fall outside of the
scope of this rulemaking, and thus are
not being addressed.
Comments: A commenter expressed
support for this Administration’s
decision to vacate an Attorney General
ruling issued under the prior
Administration that prohibited IJs from
managing their own dockets through
administrative closure. The commenter
suggested that the Administration
should promulgate clear rules on
administrative closure, which can
improve inefficiencies and backlogs.
Response: This comment is beyond
the scope of this rule because the rule
does not involve or impact
administrative closure. DOJ plans,
however, to initiate a rulemaking that
provides general administrative closure
authority to IJs and the BIA.67
64 The Security Bars rule’s effective date was first
delayed by the rule, Security Bars and Processing;
Delay of Effective Date, 86 FR 6847 (Jan. 25, 2021),
until March 22, 2021. The effective date of the
Security Bars rule was again delayed until
December 31, 2021, Security Bars and Processing;
Delay of Effective Date, 86 FR 15069 (Mar. 22,
2021), and further delayed until December 31, 2022,
Security Bars and Processing; Delay of Effective
Date, 86 FR 73615 (Dec. 28, 2021).
65 See Executive Office of the President, OMB,
OIRA, Spring 2021 Unified Agenda of Regulatory
and Deregulatory Actions, Bars to Asylum
Eligibility and Procedures, https://www.reginfo.gov/
public/do/eAgendaViewRule?pubId=202104&
RIN=1615-AC69 (last visited Mar. 14, 2022);
Executive Office of the President, OMB, OIRA, Fall
2021 Unified Agenda of Regulatory and
Deregulatory Actions, Bars to Asylum Eligibility
and Procedures, https://www.reginfo.gov/public/do/
eAgendaViewRule?pubId=202110&RIN=1615-AC69
(last visited Mar. 14, 2022).
66 On February 7, 2022, in AsylumWorks v.
Mayorkas, No. 20–cv–3815, 2022 WL 355213, at *12
(D.D.C. Feb. 7, 2022), the United States District
Court for the District of Columbia vacated two DHS
employment authorization-related rules entitled
‘‘Asylum Application, Interview, and Employment
Authorization for Applicants,’’ 85 FR 38532 (June
26, 2020) (‘‘2020 Asylum EAD Rule’’), and
‘‘Removal of 30-Day Processing Provision for
Asylum Applicant-Related Form I–765 Employment
Authorization Applications,’’ 85 FR 37502 (June 22,
2020).
67 Executive Office of the President, OMB, OIRA,
Fall 2021 Unified Agenda of Regulatory and
Deregulatory Actions, Appellate Procedures and
Decisional Finality in Immigration Proceedings;
Administrative Closure, https://www.reginfo.gov/
public/do/eAgendaViewRule?pubId=202110&
RIN=1125-AB18 (last visited Mar. 14, 2022).
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D. Proposed Changes
1. Applicability
Comments: A commenter asserted
that it would be unfair for asylum
seekers who have been issued an NTA
to be unable to have a nonadversarial
interview before an asylum officer or a
review before an IJ. The commenter
stated that if the Administration has
determined that the USCIS interview
process is the most efficient and fair,
then it should also be accessible to
noncitizens ICE places in section 240
proceedings, such as pregnant women
and families.
A commenter asserted that the rule
does not remedy the unequal treatment
of affirmative and defensive cases,
remarking that it instead goes halfway,
by saying that some noncitizens in
expedited removal—those referred for
hearings before asylum officers—could
seek a ‘‘partial review’’ with an IJ
instead of the ‘‘full case review’’ that
those in the affirmative asylum process
would have if they were not granted
asylum by USCIS. Additionally, a
commenter remarked that it is unclear
why the rule differentiates between
‘‘normal’’ cases and those of stowaways
and asylum seekers physically present
in or arriving in the Commonwealth of
the Northern Mariana Islands.
Response: The Departments disagree
that it is unfair for noncitizens who are
placed in section 240 removal
proceedings to continue to have their
claims heard before IJs rather than in
nonadversarial interviews before USCIS
in the first instance. It is well
established that DHS officials have
broad discretion to decide who should
be subject to arrest, detainers, removal
proceedings, and the execution of
removal orders. See Arizona v. United
States, 567 U.S. 387, 396 (2012) (‘‘A
principal feature of the removal system
is the broad discretion exercised by
immigration officials. Federal officials,
as an initial matter, must decide
whether it makes sense to pursue
removal at all.’’ (citation omitted)).
USCIS, in particular, has the
prosecutorial discretion, as appropriate,
to place a covered noncitizen in, or to
withdraw a covered noncitizen from,
expedited removal proceedings and
issue an NTA to place the noncitizen in
section 240 removal proceedings at any
time after they are referred to USCIS for
a credible fear determination. See, e.g.,
Matter of E–R–M–& L–R–M–, 25 I&N
Dec. at 523–24. Such discretion is
needed because there may be
circumstances in which it may be more
appropriate for a noncitizen’s protection
claims to be heard and considered in the
adversarial process before an IJ in the
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first instance (for example, in cases
where a noncitizen may have committed
significant criminal activity, have
engaged in past acts of harm to others,
or pose a public safety or national
security threat). In addition, the
Departments anticipate that DHS will
also need to continue to place many
noncitizens receiving a positive credible
fear determination into ordinary section
240 removal proceedings while USCIS
takes steps needed to allow for full
implementation of the new process for
all cases. This rule establishes an
appropriate alternative to the exclusive
use of ordinary section 240 removal
proceedings. Nevertheless, noncitizens
who are placed into streamlined section
240 removal proceedings will continue
to have access to the same procedural
protections that have been in place for
asylum adjudications for many years.
This rule authorizes the Departments to
employ a fair and efficient procedure for
individuals to seek protection, which
includes opportunities for applicants to
present their claims fully and fairly
before asylum officers in a
nonadversarial setting and, if not
granted asylum, before IJs in
streamlined section 240 removal
proceedings. The comment related to
the processing of claims of stowaways
and noncitizens arriving from the
Commonwealth of the Northern Mariana
Islands falls outside of the scope of this
rulemaking and, therefore, is not being
addressed. As noted in the NPRM, this
IFR would not apply to (1) stowaways
or (2) noncitizens who are physically
present in or arriving in the
Commonwealth of the Northern Mariana
Islands who are determined to have a
credible fear. Such individuals would
continue to be referred to asylum-andwithholding-only proceedings before an
IJ under 8 CFR 208.2(c).
2. Parole
a. General Comments on Parole
Comments: Several commenters
provided general comments on parole or
the rule’s proposed change to the
regulations governing the circumstances
in which individuals in expedited
removal proceedings may be paroled.
Many of these commenters expressed
opposition to DHS loosening the parole
requirements or paroling noncitizens
‘‘simply because they lack resources to
detain them.’’ Some of these
commenters expressed doubt about the
legality of paroling noncitizens simply
because detention is unavailable or
impractical.
Response: The Departments
acknowledge and take seriously the
concerns expressed. The Departments
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note, however, that the comments
suggesting that the Departments had
proposed for parole to be automatically
granted upon a determination that
detention is ‘‘unavailable or
impracticable’’ are mistaken; as
proposed, parole would be ‘‘in
accordance with section 212(d)(5) of the
Act and § 212.5 of this chapter,’’ 86 FR
46946 (8 CFR 235.3 (proposed)), which
impose additional prerequisites to the
exercise of parole authority. In this IFR,
DHS is finalizing a change to the DHS
regulations that will make even clearer
that parole of noncitizens who are being
processed under section 235(b)(1) of the
Act, 8 U.S.C. 1225(b)(1), may be granted
‘‘only on a case-by-case basis for urgent
humanitarian reasons or significant
public benefit.’’ INA 212(d)(5)(A), 8
U.S.C. 1182(d)(5)(A). Because the
regulatory text that DHS is finalizing no
longer specifies that parole may be
considered when detention is
‘‘unavailable or impracticable,’’ the
Departments decline to address in detail
commenters’ arguments respecting that
particular language. Nevertheless, the
Departments have explained the
longstanding regulatory and policy
basis, consistent with the statutory
authority, for taking detention resources
into consideration when making parole
determinations. See supra Section III.F
of this preamble.
b. Change in Circumstances Under
Which Parole May Be Considered
Comments: Many commenters either
supported the proposed expansion of
the circumstances under which parole
may be considered or urged the
adoption of what they characterize as a
broader standard, consistent with
section 212(d)(5) of the Act, 8 U.S.C.
1182(d)(5). Some commenters urged
DHS to adopt the long-standing parole
standards applicable in other
circumstances described in 8 CFR
212.5(b). Commenters stated that they
welcomed a change that would allow
families the possibility of parole—or
that would allow for greater availability
of parole in general—and help ensure
the availability of detention space for
those who pose the greatest threats to
national security and public safety. One
commenter stated that the proposed
change would be an effective step
toward a policy that, where possible,
ensures noncitizens’ compliance with
appointments and court dates and
timely departure from the United States,
if ordered removed, through supervision
and case management rather than
through detention. Numerous
commenters stated that, while they
welcomed the proposed rule’s
expansion of the circumstances in
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which parole may be considered, the
proposed provisions were too narrow
and should be amended to allow
consideration of parole in a broader
range of circumstances, consistent with
the breadth of DHS’s statutory parole
authority under section 212(d)(5) of the
Act, 8 U.S.C. 1182(d)(5). Commenters
stated that adopting the standard of 8
CFR 212.5(b), which would allow parole
consideration, among other things,
when continued detention is not in the
public interest, would give the agency
more flexibility, achieve a uniform
regulatory standard across the removal
process, and promote family stability.
A few commenters requested that
DHS establish a presumption of parole,
with DHS bearing a burden of
demonstrating by clear and convincing
evidence that there is a need for
detention based on the public interest.
Commenters also suggested that this
standard should apply to all asylum
seekers who establish a credible fear
during the credible fear interview,
regardless of their manner of entry, and
regardless of whether they are referred
for section 240 proceedings or for an
Asylum Merits interview. One
commenter urged that the regulations
should support a presumption that
detention is not in the public interest in
cases of survivors fleeing gender-based
violence, as well as for others who have
established a credible fear. Some
commenters also asked the Departments
to clarify that asylum seekers should
only be detained as a last resort.
Similarly, one commenter stated that
detention should only be used when it
is demonstrated that an individual is a
danger to the community or a flight risk
that cannot be mitigated by other
conditions. Another commenter stated
that ‘‘detailing clear and consistent
provisions for parole and detention’’
would be more efficient than case-bycase determinations. One commenter
urged that the regulations at 8 CFR
235.3(b) should be amended to
emphasize release from custody at the
earliest possible stage of proceedings
and asserted that parole eligibility
should not be contingent on the
outcome of credible fear screening.
Other commenters opposed the
proposed expansion of the
circumstances under which parole may
be considered. Some commenters
opposed the NPRM on the ground that
any policy that makes it more likely that
noncitizens encountered at the border
will be released from custody will, in
the commenters’ view, encourage illegal
immigration and harm the integrity of
the immigration system. In explanation,
one commenter discussed past policy
changes related to parole and stated that
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18123
the lesson to be learned is that as soon
as a policy is enacted that makes it more
likely that asylum seekers will be
released from DHS custody, the number
of asylum seekers who enter to exploit
that policy ‘‘balloons.’’ Other
commenters expressed concern that
noncitizens who are aware they most
likely will not be granted asylum will
have a strong incentive to abscond.
Citing the statistic that 38 percent of
people who receive a positive credible
fear determination and are released do
not file an asylum application, a
commenter expressed concern about a
more permissive approach to parole,
especially if individuals realize that
their cases will no longer take years to
resolve and thus their best chance for
remaining in the United States would be
to abscond.
Response: The Departments
acknowledge the range of views
expressed, from support for the
proposed regulatory amendment, to
support for adopting instead the
standard of 8 CFR 212.5(b), to support
for more expansive use of parole for
noncitizens subject to INA 235, 8 U.S.C.
1225, to opposition to any change that
would expand the circumstances under
which parole may be considered for
such individuals. As explained above,
having considered all comments
received, the Departments agree with
those commenters who suggested that
the standard of 8 CFR 212.5(b)—the
standard already applicable to, e.g.,
noncitizens who have received a
positive credible fear determination and
whose cases are pending—should
replace the more constrained standard
of 8 CFR 235.3(b)(2)(iii) and (b)(4)(ii),
which allow for parole only for medical
emergency or legitimate law
enforcement objective. The Departments
agree that the standard of 8 CFR
212.5(b), allowing for parole for urgent
humanitarian reasons or significant
public benefit, will give DHS more
flexibility to delineate the
circumstances in which parole may be
considered, on a case-by-case basis and
consistent with section 212(d)(5)(A) of
the Act, 8 U.S.C. 1182(d)(5)(A), for this
population. That said, the Departments
emphasize that individuals who have
not yet received a positive credible fear
determination may not be similarly
situated to individuals who have, as
those pending a credible fear interview
may shortly be subject to a final removal
order. As a result, subsequent directives
or guidance will clarify how officers and
agents may determine whether
‘‘continued detention is not in the
public interest,’’ 8 CFR 212.5(b)(5), for
noncitizens who are being processed
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under INA 235(b)(1), 8 U.S.C.
1225(b)(1), and who have not yet
received a positive credible fear
determination for purposes of deciding
whether parole for urgent humanitarian
reasons or significant public benefit
would be warranted. Thus, while the
IFR establishes a uniform regulatory
standard in the DHS regulations for
consideration of parole for individuals
described in 8 CFR 235.3(b) (i.e., those
in the expedited removal process) and 8
CFR 235.3(c) (i.e., ‘‘arriving aliens’’
placed in section 240 removal
proceedings), application of that
standard on a case-by-case basis will
appropriately account for
individualized considerations particular
to noncitizens who have not already
been determined to have a credible fear
of persecution or torture, as explained
above in Section III.F of this preamble.
The Departments disagree with the
commenters who urged that the
regulations at issue should be amended
to establish a presumption of parole, or
to provide that detention will be used
only as a last resort. These commenters
did not explain how the standards they
proposed would be permitted under
section 212(d)(5)(A) of the Act, 8 U.S.C.
1182(d)(5)(A), and the Departments
conclude that such options would be
inconsistent with DHS’s discretionary
parole authority.
The Departments also disagree with
the commenters who opposed loosening
current regulatory restrictions on the
exercise of parole authority on the
ground that doing so would encourage
illegal immigration and harm the
integrity of the immigration system.
These comments do not account for the
fact that the amended standard for
parole applies only to individuals being
processed under the Departments’
expedited removal authority under
section 235(b)(1) of the Act, 8 U.S.C.
1225(b)(1), and that the effect of the
amendment will be to allow DHS to
process more individuals through
expedited removal rather than referring
them to lengthier section 240 removal
proceedings. As a result, individuals
who express no fear of persecution or
torture or who are determined not to
have a credible fear can be ordered
removed more promptly, which should
discourage such individuals from
seeking to enter the United States and
thereby improve the integrity of the
immigration system. The Departments
acknowledge commenters’ contention
that increases in the number of
noncitizens at the border have been
observed after various past policy
changes. However, considering the
many complex factors that may affect
the rates of individuals seeking to enter
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the United States and make a claim for
asylum, the Departments disagree that
this perceived correlation amounts to
evidence of causation or to a compelling
reason to depart from a policy change
that is otherwise justified. The
Departments acknowledge the concern
expressed by some commenters about
the risk that paroled individuals may
abscond but emphasize that the
regulations will continue to provide that
parole is available only to those
noncitizens who present ‘‘neither a
security risk nor a risk of absconding.’’
With regard to the commenter who
suggested that noncitizens who do not
file an asylum application after
receiving a positive credible fear
determination mean to abscond rather
than pursue an asylum claim, the
Departments note that failure to timely
submit an asylum application after
receiving a positive credible fear
determination may be due to a lack of
understanding or inability to obtain the
language or other assistance needed to
complete and file a Form I–589,
Application for Asylum and for
Withholding of Removal, or for other
reasons not indicative of an intent to
abscond. The Departments are unaware
of, and commenters did not provide,
any information showing that a
noncitizen’s intention to abscond can
reasonably be inferred from a failure to
timely submit an asylum application. In
addition, DHS officials, in their
discretion, may impose reasonable
conditions on the grant of parole
(including, e.g., periodic reporting to
ICE) to ensure that the individual will
appear at all hearings and for removal
from the United States when required to
do so. See INA 212(d)(5)(A), 8 U.S.C.
1182(d)(5)(A); 8 CFR 212.5(c)–(d).
Comments: Some commenters stated
that the NPRM would establish a
subjective, ambiguous standard for
when parole may be allowed.
Specifically, commenters stated that the
proposed rule did not address what
condition or set of conditions would be
sufficient for DHS to consider detention
‘‘impracticable’’ and recommended that
the rule utilize more definite language.
Commenters also remarked that
‘‘unavailable’’ is not clearly defined and
within DHS’s control to an extent that
the proposed standard is ‘‘ripe for
agency abuse.’’
Response: Although the Departments
disagree that the standard proposed in
the NPRM was ‘‘ripe for agency abuse,’’
the Departments acknowledge
commenters’ uncertainty about the
contours of the proposed standard. The
Departments are not finalizing the
proposed amendment that would have
allowed parole consideration if
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‘‘detention is unavailable or
impracticable’’ and, thus, need not
further address that standard. Instead,
DHS is finalizing an amendment that
would allow for consideration of parole
under the existing standards in 8 CFR
212.5(b), which, as explained in Section
III.F above, includes parole on a caseby-case basis when continued detention
is not in the public interest. The
longstanding authority for DHS to take
its detention capacity into account
when making parole determinations is
explained above, and future directives
and guidance will build upon existing
directives and guidance documents that
are well understood by DHS officers and
agents even as they are applied to the
populations affected by this rule.
Comments: At least one commenter
offered the following specific
suggestions: That 8 CFR 235.3(b)(2)(iii)
and (b)(4)(ii) be amended to clarify that
DHS should parole people if continued
detention is not in the public interest;
that 8 CFR 235.3(c) be amended to
clarify that any asylum seeker who is
placed in section 240 removal
proceedings may be released on parole
in the public interest, regardless of their
manner of entry, by deleting the phrase
‘‘arriving alien(s)’’ and replacing it with
‘‘noncitizen(s)’’; and that regulatory
language be revised to ensure that all
asylum seekers who establish a credible
fear of persecution or torture are eligible
for parole under 8 CFR 212.5(b)(5),
regardless of whether they are referred
to ordinary section 240 removal
proceedings or have their cases retained
by USCIS for an Asylum Merits
interview.
Response: DHS is amending 8 CFR
235.3(b)(2)(iii) and (b)(4)(ii) to permit
parole consideration in accordance with
the longstanding regulation at 8 CFR
212.5(b), which includes parole in
circumstances where continued
detention is not in the public interest.
The Departments emphasize that—
consistent with INA 212(d)(5)(A), 8
U.S.C. 1182(d)(5)(A), and 8 CFR
212.5(b)—parole will be granted ‘‘only
on a case-by-case basis for urgent
humanitarian reasons or significant
public benefit.’’
The Departments decline the
commenter’s other suggestions. First,
the commenter’s suggestion to amend 8
CFR 235.3(c) in the manner suggested is
outside the scope of this rule. This rule
concerns only noncitizens processed
under the expedited removal provisions
of INA 235(b)(1), 8 U.S.C. 1225(b)(1),
whereas 8 CFR 235.3(c) generally
pertains to ‘‘arriving aliens’’ who are
placed in section 240 proceedings.
Second, 8 CFR 208.30(f) already
provides that ‘‘[i]f an alien, other than
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an alien stowaway, is found to have a
credible fear of persecution or torture,’’
then ‘‘[p]arole . . . may be considered
only in accordance with section
212(d)(5) of the Act and 8 CFR 212.5’’
to cover those who are placed directly
into section 240 removal proceedings.
DHS, moreover, is amending 8 CFR
212.5 to provide that the standard of 8
CFR 212.5(b) applies to noncitizens
detained pursuant to 8 CFR 235.3(b), as
well as 8 CFR 235.3(c). Finally, the
Departments are adding language to 8
CFR 235.3(c) to allow for parole under
the standard of 8 CFR 212.5(b) for
noncitizens whose asylum cases are
retained by or referred to USCIS for an
Asylum Merits interview under this rule
after a positive credible fear
determination. Thus, regardless of
whether the noncitizen’s asylum case is
retained by USCIS for adjudication on
the merits or referred to immigration
court, noncitizens who receive a
positive credible fear determination are
generally eligible for parole
consideration under the standard of 8
CFR 212.5(b).
Comments: Some commenters stated
that the proposed rule did not clearly
indicate whether parole would be
available (and if so, under what
standard) for individuals who receive a
positive credible fear determination and
are placed into the new Asylum Merits
process. These commenters suggested
specific revisions to the text of current
8 CFR 235.3(c). A few other commenters
also expressed doubt that individuals
who receive a positive credible fear
determination and are placed into the
new Asylum Merits process would have
access to parole.
Response: In the IFR, DHS is
clarifying that parole will be available
for individuals who receive a positive
credible fear determination and are
placed into the new Asylum Merits
process under the standard of 8 CFR
212.5(b)—that is, under the same
standard as for individuals who receive
a positive credible fear hearing and are
referred to immigration court. See 8 CFR
208.30(f), 8 CFR 235.3(c).
Comments: Some commenters
asserted that the proposed rule’s
expansion of parole would be unlawful
and unauthorized by Congress. One
commenter stated that the proposed rule
is ultra vires, contending that INA
235(b)(1), 8 U.S.C. 1225(b)(1), provides
for the detention of noncitizens in
expedited removal proceedings
throughout the entire process, from
apprehension to a determination on any
subsequent asylum claim. This
commenter also discussed the statutory
history of the parole provision and
claimed that it shows a congressional
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intent that parole be used in a restrictive
manner. Other commenters urged that
authorizing DHS to parole asylum
seekers into the United States whenever
DHS determines that detention is
‘‘unavailable or impracticable’’ would
directly conflict with the INA and
congressional intent to delegate only
limited parole authority to DHS. One of
these commenters stated that the
rationale behind the proposed rule is
‘‘pretextual at best’’ and remarked that
it simply provides a convenient, albeit
ultra vires, reason to release asylum
seekers from custody. Another
commenter stated that, because current
rates of migrant encounters mean that
DHS will never have enough space to
detain every person, detention would
always be unavailable or impracticable,
and more and more noncitizens would
be released. Several commenters further
stated that detention capacity is within
DHS’s control and that it can make
space unavailable to effectively make
the detention of any noncitizen
unavailable or impractical, which
would violate the INA.
Response: The Departments disagree
that the expansion of the circumstances
in which parole may be considered for
a noncitizen in expedited removal
proceedings proposed in the NPRM
would be unlawful or ultra vires and
also disagree with the unsupported
assertion that the Departments’ rationale
is in any way ‘‘pretextual.’’ As
explained above, Congress has given
DHS discretion to ‘‘parole’’ a noncitizen
who is an applicant for admission ‘‘only
on a case-by-case basis for urgent
humanitarian reasons or significant
public benefit.’’ INA 212(d)(5)(A), 8
U.S.C. 1182(d)(5)(A). The Departments
have always understood this parole
authority to apply to individuals
detained pursuant to the detention
provisions of INA 235, 8 U.S.C. 1225,
and the Supreme Court has endorsed
this interpretation in Jennings v.
Rodriguez, 138 S. Ct. 830, 837, 844
(2018).
This rule amends DHS regulations to
replace the exceptionally narrow
standard governing the circumstances in
which parole may be allowed for
noncitizens being processed under
expedited removal, and who have not
yet received a credible fear
determination, see 8 CFR
235.3(b)(2)(iii), (b)(4)(ii), with the
broader regulatory standard that already
governs the circumstances in which
parole may be allowed after a noncitizen
has received a positive credible fear
determination, see 8 CFR 208.30(f)(2),
212.5(b). This broader regulatory
standard is fully consistent with DHS’s
statutory parole authority. While the
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agency previously drew a distinction
between the parole standard for those
pending a credible fear determination
(or whose inadmissibility is still being
considered or subject to an expedited
removal order) and those found to have
a credible fear—perhaps as a matter of
policy—there is no legal requirement for
this distinction. The parole statute does
not distinguish between the various
procedural postures of noncitizens
covered by INA 235(b), 8 U.S.C. 1225(b),
or specifically reference any of the
detention provisions at INA 235(b), 8
U.S.C. 1225(b). See INA 212(d)(5), 8
U.S.C. 1182(d)(5). There is, therefore, no
reason on the face of the statute to read
the detention provision at INA
235(b)(1)(B)(iii)(IV), 8 U.S.C.
1225(b)(1)(B)(iii)(IV), any differently
from the identically worded detention
provisions in INA 235(b)(1)(B)(ii), 8
U.S.C. 1225(b)(1)(B)(ii), and INA
235(b)(2)(A), 8 U.S.C. 1225(b)(2)(A),
which the Supreme Court has endorsed
as subject to the Secretary’s full
statutory release-on-parole authority.
See Jennings, 138 S. Ct. at 844; see also
Clark v. Martinez, 543 U.S. 371, 378
(2005) (‘‘To give these same words a
different meaning for each category [of
person it applied to] would be to invent
a statute rather than interpret one.’’).
This amendment would also allow
DHS, in making parole determinations
for individual noncitizens on a case-bycase basis, to utilize its limited
detention bed space for noncitizens
found to be a flight risk or danger to the
community, as well as permit the DHS
officers to devote more time to their
handling of assigned detained cases—
allowing for more efficient processing of
issues, including responding to
inquiries, requests for release, and
securing travel documents for
noncitizens subject to orders of removal.
DHS would also be able to reallocate
detention resources to other areas, such
as alternatives to detention, which are
not as cost prohibitive.
The Departments reject the contention
that DHS’s control over its detention
capacity is so complete that it is capable
of increasing the use of parole by
artificially reducing available bedspace.
The Department’s capacity to detain an
individual on any given day is
determined by many different factors,
including the availability of
appropriated funds, the number and
demographic characteristics of
individuals in custody as well as those
encountered at or near the border or
within the interior of the United States,
and the types of facilities with available
bedspace. Capacity restrictions at
individual facilities imposed for a
variety of reasons ranging from public
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health requirements to court-ordered
limitations also constrain the
availability of detention space.
Because the regulatory text that DHS
is finalizing no longer specifies that
parole may be considered when
detention is ‘‘unavailable or
impracticable,’’ the Departments decline
to address in detail commenters’
arguments respecting that particular
language.
Comments: A few commenters that
encouraged DHS to amend the
regulations to provide for parole when
continued detention is not in the public
interest stated that this term should be
interpreted to encompass, among other
things, the impact of continued
detention on an individual’s or their
family’s physical or mental health,
safety, well-being, family unity, and
other considerations.
Response: As explained above, DHS
intends to use further directives or
guidance to promote fair and consistent
determinations as to when ‘‘continued
detention is not in the public interest’’
for noncitizens in expedited removal
who have not yet received a credible
fear determination. The Departments
recognize that the term ‘‘public interest’’
is open to interpretation but note that
the noncitizen’s personal interests,
while potentially relevant, are not
determinative of whether continued
detention is not in the public interest.
Comments: A few commenters stated
that, although any change that increases
DHS’s ability to grant parole seems
positive on its face, the proposed rule
still leaves the decision of whether to
parole an individual up to the discretion
of a DHS officer. Commenters expressed
concern about this discretion based on
their experience with parole decisions
they described as arbitrary or biased.
Commenters recommended that the rule
create accountability mechanisms and
clear decision-making procedures to
ensure parole requests are decided
consistently, without bias or undue
political influence, or in pro forma
fashion without regard to the substance
of the requests. For example, one
commenter suggested there be a
mandate that ICE provide a timely
response in a language the applicant can
understand that includes individualized
analysis of the reasons why parole was
denied. Another commenter
recommended that DHS amend its
regulations to include a specific time
frame within which ICE officers must
review parole requests and issue parole
decisions, a mandate that parole
interviews must take place before the
issuance of a denial of a parole request,
a requirement of detailed recordkeeping
to help provide transparency and
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oversight of parole decisions, and an
independent department charged with
routinely reviewing each ICE field
office’s parole grant and denial rates. A
commenter asked that the rule specify to
whom at the agency asylum seekers
should submit their parole requests,
which officers make these decisions,
and what documentation should be
included or can be provided as
satisfactory alternatives.
Response: The NPRM proposed to
amend, and this IFR will amend, the
DHS regulations specifying the
circumstances in which parole may be
considered for noncitizens in expedited
removal proceedings. Additionally,
consistent with the INA, DHS’s exercise
of discretion will be conducted on a
case-by-case basis, given the unique
factual circumstances of each case and
to ensure the requirements for parole
have been thoroughly considered and
addressed. Comments that suggest new
regulatory provisions to establish
accountability mechanisms and
decision-making procedures are
therefore beyond the scope of the
current rulemaking.
Comments: One commenter urged
that the rule should not include
detention availability as a factor for
parole, since the determination of
whether to deprive an individual of
their liberty ‘‘should never be
contingent on or determined by the
budget or physical infrastructure of a
Federal agency.’’ Another commenter
expressed concern that the proposed
rule’s allowance for parole
consideration when detention is
unavailable or impracticable would lead
to increased calls for detention beds, an
outcome the commenter opposed. A
commenter asserted that, under the
expanded grounds for parole, detention
should only be considered ‘‘practical’’ if
asylum seekers are provided with the
ability to access medical care, legal
counsel, and language assistance.
Response: Because the regulatory text
that DHS is finalizing no longer
specifies that parole may be considered
when detention is ‘‘unavailable or
impracticable,’’ the Departments decline
to address in detail commenters’
arguments respecting that particular
language. With regard to the comment
premised on the idea that detention
‘‘should never be contingent on or
determined by the budget or physical
infrastructure of a Federal agency,’’ the
Departments disagree. By statute, a
noncitizen who is being processed
under the expedited removal provisions
of section 235(b)(1) of the Act, 8 U.S.C.
1225(b)(1), is subject to detention unless
DHS exercises its discretion to ‘‘parole’’
the noncitizen ‘‘only on a case-by-case
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basis for urgent humanitarian reasons or
significant public benefit.’’ INA
212(d)(5)(A), 8 U.S.C. 1182(d)(5)(A).
DHS’s resources may appropriately be
considered in determining whether to
exercise parole authority pursuant to
section 212(d)(5)(A) of the Act, 8 U.S.C.
1182(d)(5)(A). Indeed, the availability of
DHS detention resources is integral from
an operational standpoint. For example,
there may be a limited number of
available detention beds in a particular
facility or an insufficient number of
DHS officers available to handle the
volume of detainees, thereby hampering
DHS’s ability to promptly and
efficiently process cases. DHS can focus
its detention resources on those
noncitizens found to be a flight risk or
danger to the community, particularly
when there are a limited number of
detention beds.
Comment: A few commenters stated
that the proposed rule’s expansion of
the circumstances in which parole may
be allowed is a welcome development
but requested clarification regarding
how the changed parole standard will
be integrated into the proposed
adjudicative process. Specifically, a
commenter inquired whether a paroled
person would be subject to the new
procedure established by the rule and,
if so, when and where the credible fear
interview and Asylum Merits interview
would take place. The commenter also
asked whether a paroled person would
be forced to remain near where they
were detained and what the process
would be for changing the venue of the
asylum interview.
Response: The procedure established
by the rule is available to parolees. If the
person or family unit is paroled prior to
their credible fear interview, the
Departments anticipate that their
credible fear interview and Asylum
Merits interview, if applicable, will take
place at a USCIS Asylum Office near
their destination within the United
States and that such persons would not
be required to remain in the vicinity of
where they were detained. DHS
anticipates that the credible fear
interview will normally take place
within 30 days of referral of the
noncitizen to USCIS. DHS officials, in
their discretion, may impose reasonable
conditions on the grant of parole
(including, e.g., periodic reporting to
ICE) to ensure that the individual will
appear at all hearings and for removal
from the United States when required to
do so. See INA 212(d)(5)(A), 8 U.S.C.
1182(d)(5)(A); 8 CFR 212.5(c)–(d).
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c. Availability of Employment
Authorization for Those in Expedited
Removal Who Have Been Paroled From
Custody
Comments: Several commenters urged
that the proposed regulations should be
amended to provide for parole-based
employment authorization eligibility for
all people whom DHS paroles from
detention, to respect the dignity of
asylum seekers and ensure that they can
support themselves and their families.
Several commenters asserted that
ensuring parole-based eligibility for an
employment authorization document
(‘‘EAD’’) for asylum seekers released
from detention would help them secure
housing, food, health care, and other
necessities. Commenters discussed how
authorizing asylum seekers to work at
the earliest practicable stage would offer
a variety of benefits to both asylum
seekers and host communities,
including helping to reduce their social
and economic exclusion; reduce the risk
that they experience extreme poverty,
food insecurity, or homelessness; and
alleviate the loss of skills, low selfesteem, and mental health problems that
often accompany prolonged periods of
idleness. One commenter also stated
that barriers to employment
authorization often impede asylum
seekers’ access to counsel or other
services, such as food assistance, and
remarked that asylum seekers’ inability
to work may have long-term negative
impacts on their economic prospects
and mental health. A commenter
asserted that forcing parolees to wait for
months or years for an adjudication of
their claim without any means to find
legal employment lends itself to abusive
and harmful employment arrangements
that are marked by unscrupulous
employers taking advantage of asylum
seekers’ desperation. A commenter
stated that the denial of EADs to
parolees would have a particularly
negative impact on LGBT migrants, as
they often travel alone with no support
system.
A commenter noted that the EAD is
often the only government-issued
identification an asylum seeker may
have in their possession, and
individuals forced to wait to apply for
employment authorization would thus
likely be without a valid identification,
leading to challenges when securing
housing, opening bank and utility
accounts, or encountering law
enforcement. The commenter concluded
that limiting employment authorization
for individuals released under 8 CFR
235.3(b)(4)(ii) would endanger the lives
of asylum seekers and their families.
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On the other hand, another
commenter noted that it supports the
decision to restrict EAD eligibility
‘‘solely on the basis of receiving parole’’
and recommended that this decision be
maintained. The commenter asserted
that DHS does not have the authority to
grant EADs to asylum seekers for whom
the INA does not provide such
eligibility or for whom the INA
expressly grants the Secretary
discretionary authority. The commenter
argued that it would be unreasonable to
conclude that Congress authorized DHS
to use parole to permit an indefinite
number of asylum seekers to enter the
United States, in its discretion, and to
allow them to engage in employment.
The commenter also said providing EAD
eligibility ‘‘solely on the basis of being
paroled’’ would serve as a powerful pull
factor for illegal immigration.
Several commenters addressed the
waiting period for EAD eligibility for
asylum seekers. Some commenters
argued that the one-year waiting period
for EAD eligibility based on a pending
asylum application, pursuant to the
current DHS regulations at 8 CFR 208.7,
is excessive and inhumane. One
commenter stated that individuals
forced to wait a year to apply for
employment authorization would likely
be unable to secure necessities such as
food, shelter, and medical care.
However, another commenter
maintained that, per section 208(d)(2) of
the Act, 8 U.S.C. 1158(d)(2), the
Secretary cannot grant employment
authorization to an asylum applicant
until at least 180 days after the filing of
the application for asylum. The
commenter encouraged DHS to abide by
the INA’s 180-day restriction, arguing
that failing to do so would encourage
illegal immigration and fraud in the
asylum system.
A commenter suggested that DHS
require by regulation that parole-based
EADs be adjudicated within 30 days of
receipt, claiming that delays in USCIS
adjudication force individuals to wait
for months for parole-based
employment authorization. A
commenter, in asserting that the
proposed rule’s parole provision is an
ultra vires application, stated that the
proposed rule does not actually limit
employment authorization. The
commenter stated that, even though the
proposed rule provides that parole
would not serve as an independent basis
for employment authorization, nothing
in 8 CFR 274a.12(c)(8) prohibits
applications filed after the asylum
seeker files a completed asylum
application.
Response: The Departments
acknowledge the multiple comments
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both in support of and in opposition to
the NPRM’s provision restricting EADeligibility based on parole for this subset
of parolees. The Departments have
considered comments highlighting
potential benefits that would accrue to
asylum applicants and their support
networks if they were to receive
employment authorization earlier as
well as the potential drawbacks of
providing earlier employment
authorization and balanced those
benefits and drawbacks in light of the
broader interests served in the
rulemaking. On balance, the
Departments believe that this
rulemaking’s overall framework
promoting efficiency in the adjudication
of protection-related claims and the
overall statutory scheme with respect to
obtaining employment authorization
based on pending asylum applications
is best served by finalizing the DHS
regulatory language in the NPRM for
several reasons.
First, the Departments note that the
overall goal of the rulemaking is to
ensure that noncitizens receive final
decisions on their claims for protection
as quickly and efficiently as possible,
consistent with fundamental fairness,
and ensuring that noncitizens appear for
any interviews and hearings is key to
this process. Providing parole-based
employment authorization to
noncitizens who are in expedited
removal or in expedited removal with a
pending credible fear determination
(that is, employment authorization with
no prerequisite waiting period) risks
incentivizing more individuals to enter
the United States and seek out this
process in the hopes of obtaining parole
under this framework while
disincentivizing appearance. Moreover,
individuals for whom employment
authorization is the most salient benefit
of securing asylum, if eligible, would
have less of an incentive to appear for
subsequent interviews and hearings. See
8 CFR 235.3(b)(2)(iii), (b)(4)(ii). Second,
the Departments believe that their
approach is consistent with the
provisions in section 208(d)(2) of the
Act, 8 U.S.C. 1158(d)(2), regarding a
waiting period for employment
authorization for asylum applicants,
which states that ‘‘[a]n applicant who is
not otherwise eligible for employment
authorization shall not be granted such
authorization prior to 180 days after the
date of filing of the application for
asylum.’’ INA 208(d)(2), 8 U.S.C.
1158(d)(2). The Departments recognize
that the ‘‘otherwise eligible’’ language in
section 208(d)(2) of the Act, 8 U.S.C.
1158(d)(2), could be read to encompass
employment authorization based on
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parole. However, noncitizens paroled
with a pending credible fear
determination are all seeking asylum (or
related protection) and are being
paroled on a case-by-case basis for
urgent humanitarian reasons or
significant public benefit while they
await a screening interview on their
protection claims. The Departments
note that potential benefits associated
with more expeditious employment
authorization are expected under the
new process in that the waiting period
will begin running sooner here as an
application will be considered filed at
the time of a positive credible fear
determination. Additionally, eligible
noncitizens will likely receive a final
determination granting relief or
protection, and employment
authorization incident to status, prior to
being eligible for an employment
authorization under 8 CFR 274a.12(c)(8)
based on a pending asylum application.
With respect to waiting periods for
asylum-based EADs generally, the
Departments note that on February 7,
2022, in AsylumWorks v. Mayorkas, No.
20–cv–3815, 2022 WL 355213, at *12
(D.D.C. Feb. 7, 2022), the United States
District Court for the District of
Columbia vacated two DHS employment
authorization-related rules entitled
‘‘Asylum Application, Interview, and
Employment Authorization for
Applicants,’’ 85 FR 38532 (June 26,
2020), and ‘‘Removal of 30-Day
Processing Provision for Asylum
Applicant-Related Form I–765
Employment Authorization
Applications,’’ 85 FR 37502 (June 22,
2020). Finally, the Departments disagree
with the commenter that states that the
Secretary of Homeland Security lacks
the discretionary authority to grant
employment authorization to those
paroled. The Departments note that the
Secretary of Homeland Security, as a
matter of policy for the reasons outlined
above, is exercising his discretionary
authority narrowly as to noncitizens
who are in expedited removal or in
expedited removal with a pending
credible fear determination and who are
paroled from custody.
d. Other Comments on Proposed
Approach to Parole
Comments: A few commenters urged
that detained asylum seekers should
have access to bond determination
hearings, as well as regular
opportunities to challenge continued
detention. Another commenter stated
that regulations should ensure
meaningful access to counsel for those
in immigration detention, readily
accessible confidential attorney-client
meeting spaces, confidential free
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telephone and televideo communication
options, as well as minimum
restrictions on visitation.
Response: These comments are
beyond the scope of the current
rulemaking, given that the rule neither
addresses bond determinations nor
conditions for those held in immigration
detention.
Comments: One commenter stated
that the proposed rule would essentially
deny all individuals the right to have
their custody reviewed by a neutral
arbiter and urged that the regulations
should require a neutral decisionmaker.
The commenter suggested that IJs
should be given the power to review
and revise parole decisions made under
the proposed regulations.
Response: These comments are
beyond the scope of the current
rulemaking, which amends only the
regulatory provisions specifying the
circumstances in which parole may be
considered for noncitizens subject to
expedited removal.
Comments: A commenter stated that
the unprecedented surge in family unit
migration, which the commenter
attributed to the Flores Settlement
Agreement, is endangering children at
the border and that such migration will
continue to soar unless the dynamics
causing this trend are changed. The
commenter asserted that the
Departments should ‘‘address’’ the
Flores Settlement Agreement before
taking any steps to expand the
availability of parole for asylum seekers
and suggested that the agencies
promulgate regulations that would
enable DHS to detain adults and
children entering illegally in family
units, to comply with the detention
provisions in the INA.
Response: The Flores Settlement
Agreement requires the promulgation of
the relevant and substantive terms of the
FSA as regulations, FSA ¶ 9, and based
on a 2001 Stipulation, the Agreement
terminates ‘‘45 days following
defendants’ publication of final
regulations implementing [the]
Agreement,’’ Stipulation Extending
Settlement Agreement ¶ 40, Flores v.
Reno, No. 85–cv–4544 (C.D. Cal. Dec. 7,
2001). In August 2019, DHS and the
Department of Health and Human
Services published a Flores final rule,
Apprehension, Processing, Care, and
Custody of Alien Minors and
Unaccompanied Alien Children, 84 FR
44392 (Aug. 23, 2019); however, that
rule was partially enjoined, see Flores v.
Rosen, 984 F.3d 720 (9th Cir. 2020).
While the FSA does impose restrictions
on DHS’s ability to detain family units,
addressing the FSA by promulgating
regulations to implement such
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Agreement is outside the scope of this
rule.
Comments: Several commenters
supported expanding the circumstances
in which parole may be granted to allow
release of families from detention but
opposed any expansion of the expedited
removal system upon which the
proposed asylum process is premised. A
couple of commenters asserted that the
expedited removal process is harmful
and emphasized that DHS is not
required to use expedited removal.
These commenters recommended that
the proposed rule be amended to avoid
the use of expedited removal.
Commenters argued that the expedited
removal process does not provide due
process, fails to comply with domestic
refugee law and international
commitments, and has led to
mistreatment and the return of refugees
to persecution.
Commenters also argued that the
proposed changes to 8 CFR 235.3 to
expand the possibility of parole would
eliminate the barrier to placing families
into expedited removal and would risk
further cementing expedited removal as
a primary tool to remove noncitizens,
creating possibilities for use of the
expedited removal structure to be
expanded by future administrations.
Response: The Departments disagree
that the expedited removal process does
not comport with due process or U.S.
refugee law. See, e.g., DHS v.
Thuraissigiam, 140 S. Ct. 1959, 1963–64
(2020) (addressing the Due Process
Clause of the Fifth Amendment).
Comments expressing opposition to the
Departments’ use of expedited removal
generally are also beyond the scope of
this rulemaking, which amends certain
procedures and standards applicable to
noncitizens once they have already been
placed into expedited removal.
Comments: Several commenters
stated that detention is a harmful and
punitive practice that should be reduced
or eliminated completely and expressed
disappointment that the proposed rule
did not include systematic efforts to
limit or eliminate the detention of
asylum seekers. A couple of
commenters added that detention is not
necessary to achieve the goal of
ensuring that people seeking asylum
appear for their appointments. A few
commenters remarked that detention
makes it nearly impossible for asylum
seekers to assert their protection claims
effectively, as their ability to access
legal resources and legal representation
is often non-existent. One commenter
stated that only 30 percent of detained
immigrants receive legal representation
and argued that the remote location of
detention facilities, the inadequate
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access to counsel and interpreters, and
the frequent transfer of detainees
present nearly insurmountable barriers
to detainees seeking to obtain legal
assistance. A few commenters asserted
that detention of asylum seekers flouts
U.S. legal obligations under the Refugee
Convention and Protocol or that
presumptive detention of asylum
seekers violates international refugee
and human rights law. Some
commenters suggested that DHS invest
its resources in housing, medical
treatment, and travel expenses for
asylum seekers, rather than expediting
asylum interviews and moving people
through detention faster. They stated
that this would help ensure that those
entering the United States are welcomed
by a supportive community.
Response: Although the Departments
acknowledge the commenters’ concerns
about access to legal services, the
Departments disagree with the
commenters who urged that the
regulations at issue should be amended
to systematically limit or eliminate the
detention of anyone indicating an
intention to seek asylum. The
Departments believe that the standards
proposed by these commenters would
not be consistent with the detention
provisions of section 235(b)(1)(B)(ii) of
the Act, 8 U.S.C. 1225(b)(1)(B)(ii), or
DHS’s parole authority under section
212(d)(5)(A) of the Act, 8 U.S.C.
1182(d)(5)(A). Proposals to change those
detention provisions are properly
directed to Congress, not to the
Departments. The Departments also do
not believe that commenters’ requests
are feasible. Commenters did not
explain what budget authority DHS
would have to invest resources in nondetention housing, medical treatment,
and travel expenses for noncitizens
arriving at the border and indicating an
intention to apply for asylum in the
United States.
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3. Credible Fear Screening Process
a. General Comments on Credible Fear
Screening Process
Comments: Some commenters
indicated that the changes to the
credible fear screening process in the
NPRM are valuable and necessary and
expressed general support for the
changes. Other commenters expressed
opposition to the procedural changes
based on the belief that individuals in
the expedited removal process are
coached to lie and express fear. Several
commenters described the credible fear
process as a ‘‘loophole’’ to be exploited
by dangerous people to get into the
United States. Other commenters stated
that the majority of asylum seekers are
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not properly vetted, while another
stated that individuals claim credible
fear without any proof. Similarly,
several commenters stated that
documented proof should be submitted,
and that testimony alone or a simple
statement of credible fear is
unacceptable.
Another commenter stated that
credible fear should be established
immediately after the individual is
detained to avoid having U.S. persons
suffer at the hands of criminals.
Similarly, another commenter suggested
that individuals who are national
security threats or have ‘‘egregious
criminal histories’’ should not be
permitted to make credible fear claims.
Some commenters stated that asylum
officers should not be conducting
credible fear interviews, asserting that
the existing process lacks transparency
and oversight, and another commenter
recommended that IJs handle credible
fear claims.
Several commenters expressed
concern with conditions and due
process in expedited removal and
credible fear interviews in general,
arguing that those factors would affect
the case outcome in various stages of the
asylum process.
Response: The Departments
acknowledge the commenters’ support
for the changes to the credible fear
screening process in this rule and
acknowledge the other commenters’
concerns about the credible fear
screening process. The Departments
disagree that the credible fear screening
process is a loophole to be exploited by
dangerous individuals and that the rule
will only encourage more individuals to
come to the border and request asylum.
Expedited removal and the credible fear
screening process were established by
Congress. The credible fear process
ensures that the U.S. Government
adheres to its international obligations,
as implemented through U.S. law, to
refrain from removing a noncitizen to a
country where the noncitizen would be
persecuted or tortured. See Section II.B
and II.C of this preamble. To the extent
that commenters assert that noncitizens
seeking protection generally are liars or
criminals seeking to exploit a
‘‘loophole,’’ the Departments reject that
characterization as unfounded. This
rulemaking is one part of a multifaceted
whole-of-government approach to
addressing irregular migration and
ensuring that the U.S. asylum system is
fair, orderly, and humane, and this
rulemaking is consistent with the E.O.
on Migration, which states that
‘‘[s]ecuring our borders does not require
us to ignore the humanity of those who
seek to cross them. The opposite is
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18129
true.’’ 86 FR 8267. This whole-ofgovernment approach seeks to make
better use of existing enforcement
resources by investing in border security
measures that are proven to work and
that will facilitate greater effectiveness
in combatting human smuggling and
trafficking and the entry of
undocumented individuals. This rule
seeks to ensure that the Departments
process the protection claims of
individuals in the credible fear
screening process promptly and
efficiently, meaning that it allows
individuals who are not eligible for
protection to be removed more
promptly.
The Departments recognize that the
credible fear screening and review
process involves eliciting testimony
from individuals seeking protection and
does not require noncitizens to provide
written statements or documentation.
Both asylum officers and IJs receive
training and have experience with
assessing evidence and the credibility of
noncitizens who appear before them for
interviews or hearings. Asylum officers
and IJs have experience identifying and
raising concerns surrounding
inconsistencies and lack of detail, and
thus are equipped to make wellreasoned decisions regarding credibility,
even in the absence of written
statements or other documentation.
Moreover, requiring written statements
or other documentation would likely
limit the ability of certain asylum
seekers to obtain protection, given that
some may have fled their home
countries without the ability to secure
documentation, and obtaining
documentation once they are in the
United States may not be feasible.
Indeed, the INA explicitly provides that
‘‘testimony of the applicant may be
sufficient to sustain the applicant’s
burden without corroboration, but only
if the applicant satisfies the trier of fact
that the applicant’s testimony is
credible, is persuasive, and refers to
specific facts sufficient to demonstrate
that the applicant is a refugee.’’ INA
208(b)(1)(B)(ii), 8 U.S.C.
1158(b)(1)(B)(ii).
Moreover, the Departments
respectfully disagree with commenters’
assertions that credible fear interviews
are plagued with due process concerns.
While some issues may arise due to the
nature of credible fear interviews—
which may be the first time or one of the
first times an individual has provided
testimony related to sensitive topics and
which often occur remotely with an
interpreter and with the individual in a
detained setting—USCIS asylum officers
are trained to conduct those interviews
in a fair and sensitive manner, and
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every credible fear determination is
reviewed by a supervisory asylum
officer and subject to additional IJ
review if the applicant so chooses or,
under this IFR, fails or refuses to decline
such review. The Departments do not
agree that potential issues with the
credible fear determination, to the
extent that any may exist, would
necessarily affect case outcomes in the
new process. Applicants will have
ample opportunity to correct any
biographic or informational errors in the
Form I–870. Asylum officers will not be
limited to considering only the
testimony provided during the credible
fear interview but will conduct a full
nonadversarial interview to determine
asylum eligibility for the principal
applicant. Moreover, if the applicant
fails to establish asylum eligibility
before the asylum officer at the Asylum
Merits interview under the IFR, they
will have the opportunity to present
their claims for asylum and withholding
or deferral of removal before an IJ when
they are placed in streamlined section
240 proceedings and the IJ will review
their claims.
b. ‘‘Significant Possibility’’ Standard for
Protection Claims
Comments: Several commenters
expressed general support for restoring
the ‘‘significant possibility’’ standard.
One commenter stated that clarifications
at proposed 8 CFR 208.30(e)(2) provide
important protections to individuals in
expedited removal and comport with
section 235(b)(1)(B) of the Act, 8 U.S.C.
1225(b)(1)(B).
Other commenters expressed general
disapproval with the use of the
‘‘significant possibility’’ standard, either
advocating for a higher standard or
stating that the use of a less stringent
standard may encourage frivolous
claims or claims from individuals solely
seeking employment authorization.
Response: The Departments
acknowledge the support of
commenters. The rule adopts the
‘‘significant possibility’’ standard for
credible fear screenings for purposes of
asylum, withholding of removal, and
CAT protection. As explained above in
Section III.A of this preamble, while the
statutory text only defines ‘‘credible
fear’’ for purposes of screening asylum
claims, see INA 235(b)(1)(B)(v), 8 U.S.C.
1225(b)(1)(B)(v); see also 86 FR 46914,
the Departments believe that the
efficiency gained in screening the same
set of facts using the same standard of
law for all three forms of protection is
substantial and should not be
overlooked. Moreover, the credible fear
screening process is preliminary in
nature; its objective is to sort out,
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without undue decision costs, which
cases merit further consideration and to
act as a fail-safe to minimize the risk of
refoulement. Using one standard of law
is consistent with those objectives, even
though the ultimate adjudication of a
noncitizen’s claim for each form of
protection may require a distinct
analysis.
Comments: One commenter requested
that the Departments elaborate upon the
‘‘significant possibility’’ test to make
clear that the showing that must be
made is not a ‘‘significant possibility’’ of
persecution, but a ‘‘significant
possibility’’ that the ‘‘claimant could
make out a well-founded fear of such
persecution where there exists as little
as a one in ten chance of such serious
harm occurring.’’ The commenter
argued that the ‘‘preponderance of the
evidence’’ threshold is not applicable
during this process. The commenter also
stressed that nothing in the proposed
rule requires the asylum officer to
investigate all the possible avenues by
which an applicant for protection may
be able to access asylum. Similarly,
some commenters said that more
training and oversight is needed to
ensure that asylum officers correctly
apply the low bar standard and do not
misinterpret it.
Alternatively, a commenter suggested
that the standard ‘‘manifestly
unfounded’’ be applied during the
credible fear screening. That is, the
commenter believes that unless an
individual’s claim is assessed to be
manifestly unfounded, or unrelated to
the criteria for granting asylum, they
should have access to full proceedings.
The commenter believes this would
guard against the risk that an individual
would be returned to a country where
they face persecution. The commenter
further stated that the ‘‘significant
possibility’’ standard is a step in the
right direction but still does not match
international standards. Another
commenter expressed the concern that
the ‘‘significant possibility’’ standard
proposed in the rule is largely
impossible to meet in practice because
‘‘it virtually forces the non-citizen to
produce at once all of the evidence
necessary to gain success at trial.’’
Response: The Departments
appreciate comments regarding further
elaboration on the ‘‘significant
possibility’’ standard, alternative
standards, and the ‘‘significant
possibility’’ standard’s use in credible
fear interviews. The ‘‘significant
possibility’’ standard is a statutory
standard found at INA 235(b)(1)(B)(v), 8
U.S.C. 1225(b)(1)(B)(v), and suggested
use of the ‘‘manifestly unfounded’’ or
other international standards
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concerning refugee claims in screening
for credible fear would require
legislative change. As commenters have
recognized, appropriate application of
the ‘‘significant possibility’’ standard is
nuanced and fact-intensive. The
Departments therefore believe that
further elaboration on the appropriate
application of the standard is best
accomplished through case law,
training, and oversight, rather than
through abstract discussion or further
codification. Such training is an integral
part of ensuring the appropriate
application of this standard, but the
Departments do not believe it is
appropriate to codify such training or
oversight in the regulatory text.
Comments: Some commenters stated
that the return to the ‘‘significant
possibility’’ standard is appropriate but
observed that the proposed rule does
not specify a choice of law rule, which
is important for respecting the rights of
asylum seekers, and commenters
suggest that this language be added at 8
CFR 208.30. One commenter asked that
DHS apply the law most favorable to the
individual seeking protection when
determining whether he or she meets
the credible fear standard.
Response: The Departments agree that
USCIS should apply the law most
favorable to the individual seeking
protection at the credible fear screening
stage. DHS remains subject to the
injunction in Grace v. Whitaker, 344 F.
Supp. 3d 96, 135–40, 146 (D.D.C. 2018),
which found that a DHS policy memo
applying only the law of the circuit
where the credible fear interview occurs
rather than the circuit law most
favorable to the applicant’s claim was
unlawful. Therefore, USCIS continues to
apply the choice of law most favorable
to the applicant when screening for
credible fear.
Comment: A few commenters
generally opposed the rule on the
ground that changing the standard for
credible fear screening will delay
removal of noncitizens with meritless
claims for protection.
Response: The Departments disagree
that the rule’s changes to the credible
fear screening process will, in the
aggregate, contribute to delays in
removal. Divergent standards for asylum
and withholding of removal along with
variable standards for individuals
barred from certain types of relief were
promulgated in multiple rulemaking
efforts over the last few years.68
However, in working to create
efficiencies within this process,
adopting the standard of law that was
68 See supra note 4 (discussing recent regulations
and their current status).
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set by Congress for credible fear claims
is the logical choice. The varied legal
standards created by asynchronous
rulemaking, and often enjoined or
vacated by legal challenges, defeated
their intended purpose by complicating
and extending the initial screening
process provided for in section 235 of
the Act, 8 U.S.C. 1225. Use of different
legal standards for asylum, statutory
withholding of removal, and CAT
protection required additional time for
adjudicators to evaluate whether a
mandatory bar to asylum or to statutory
withholding of removal was present.
Additionally, adjudicators were
required to evaluate the same evidence
twice for the same factual scenario.
Notably, use of the different standards
would require asylum officers to apply
the mandatory bars to asylum in order
to consider screening for statutory
withholding of removal. In turn, this
would inevitably increase credible fear
interview and decision times, requiring
analysis of the bars and then applying
the higher evidentiary standard. For
example, when the TCT Bar IFR was in
effect, asylum officers were required to
spend additional time during any
interview where the bar potentially
applied developing the record related to
whether the bar applied and, if so,
whether an exception to the bar might
have applied. Then, if the noncitizen
appeared to be barred and did not
qualify for an exception to the bar,
asylum officers had to develop the
record sufficiently such that a
determination could be made according
to the higher reasonable possibility
standard. IJs reviewing negative credible
fear determinations where a mandatory
bar was applied would similarly be
required to review the credible fear
determination under two different
standards, undermining the efficiency of
that process as well.
In the Departments’ view, the delays
associated with complicating and
extending each and every credible fear
interview to use two different standards
outweigh any efficiency that could be
gained by potential earlier detection of
individuals who may be barred from or
ineligible for certain types of protection.
Commenters have not provided any data
or information suggesting that the
asylum caseload would be meaningfully
reduced by evaluating the existence of
bars to eligibility during the credible
fear screening or by applying a
‘‘reasonable possibility’’ standard
(rather than the ‘‘significant possibility’’
standard) in screening claims for
statutory withholding of removal or
CAT protection. In clarifying that the
‘‘significant possibility’’ standard
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applies not only to credible fear
screening for asylum, but also to
credible fear screening for statutory
withholding and CAT protection, the
Departments will continue to ensure
that the expedited removal process
remains expedited and will allow for
asylum officers and, upon credible fear
review, IJs, to adhere to a single
standard of law in fulfilling the United
States’ nonrefoulement obligations.
c. Due Process in Credible Fear
Screening
Comments: Multiple commenters
recommended that the Departments
retain the language at 8 CFR
208.30(g)(2)(i) acknowledging USCIS’s
ability to reconsider a negative credible
fear finding after it has been upheld by
an IJ. Commenters expressed their belief
that an additional option for review,
even after a Supervisory Asylum Officer
(‘‘SAO’’) has reviewed the asylum
officer’s credible fear determination and
an IJ has concurred with the
determination, is still necessary to
preserve the rights of noncitizens.
Commenters described a range of
issues that they allege render the
credible fear process systematically
‘‘unreliable,’’ making the need for
additional safeguards against
refoulement—including USCIS
reconsideration—more acute. Describing
the negative effects of trauma and
procedural limitations on credible fear
outcomes, commenters suggested that
the ability to file a request for
reconsideration with USCIS has saved
‘‘countless’’ asylum seekers from
refoulement. One commenter noted that
reconsideration provides ‘‘an important
safety net’’ and can address instances in
which the credible fear process may not
have provided a fair process, including
where appropriate interpretation for
indigenous language speakers and
adequate accommodations for
disabilities were not provided. Another
commenter suggested that the
reconsideration processes in place are
‘‘central to the American value of due
process’’ and a second commenter, for
similar reasons, expressed strong
opposition to eliminating them through
this rule.
Multiple commenters argued that
revising this provision would eliminate
a key procedural safeguard for asylum
seekers, citing a September 2021 study
by Human Rights First.69 Several
69 See Human Rights First, Biden Administration
Move to Eliminate Requests for Reconsideration
Would Endanger Asylum Seekers, Deport Them to
Persecution and Torture (Sept. 2021), https://
www.humanrightsfirst.org/sites/default/files/
RequestsforReconsideration.pdf (last visited Mar.
14, 2022).
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18131
commenters provided examples of
individuals who successfully sought
reconsideration and, as a result, won
protection. These commenters
concluded that reconsideration by
USCIS is a means to avoid unlawful
refoulement due to mishandled credible
fear interviews, errors in the initial
credible fear record, and barriers to
adequate review by an IJ.
Adding to the above arguments, a
commenter asserted that the factors
distinguishing USCIS reconsideration
from IJ review favor due process and
administrative efficiency. The
commenter said reconsideration allows
for more time to access counsel, since
asylum seekers can request
reconsideration at any time following
the credible fear determination and
prior to removal. On the other hand,
EOIR is required to schedule hearings
within 7 business days of the credible
fear determination. The commenter
added that USCIS asylum officers will
often provide asylum seekers time to
explain errors with their initial
interview, while IJ reviews move
quickly and do not consider procedural
errors in the credible fear interview.
Furthermore, the commenter suggested
that USCIS benefits from requests for
reconsideration, as they serve as checks
and balances for the agency while
informing future asylum officer training.
Given the differences between IJ review
and USCIS reconsideration, an
individual commenter argued that
‘‘[requests for reconsideration] are often
our only recourse after a negative
[credible fear interview] finding.’’
Response: The Departments
acknowledge the comments related to
whether an IJ should have sole
jurisdiction to review negative credible
fear determinations made by USCIS, or
whether USCIS should retain the
practice of entertaining requests for
reconsideration even after a negative
credible fear determination is served on
the applicant and reviewed and
affirmed by an IJ. Some context for the
regulatory language at play and the way
this practice has developed is helpful to
frame this discussion. Prior to
publication of the Global Asylum rule
on December 11, 2020, the language
related to reconsideration was located at
8 CFR 1208.30(g)(2)(iv)(A). With the
Global Asylum rule, the Departments
moved it from that section to 8 CFR
208.30(g)(2)(i).70 The regulatory
language recognizes USCIS’s inherent
discretionary authority to reconsider its
own determination, but it was never
meant to provide for a general process
70 See 85 FR 80275; supra note 4 (discussing
recent regulations and their current status).
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by which individuals could submit
requests for reconsideration of negative
credible determinations to USCIS that
had already been reviewed and upheld
by an IJ as a matter of course. In
practice, however, this regulatory
language has served as a basis for
entertaining such requests and, over the
years, they have become an ad hoc yet
increasingly significant portion of the
work of USCIS asylum offices. Because
this was never meant to be a formalized
process, there is no formal mechanism
for individuals to request
reconsideration of a negative credible
fear determination before USCIS;
instead, such requests are entertained
on an informal ad hoc basis whereby
individuals contact USCIS asylum
offices with their requests for
reconsideration after an IJ has affirmed
the negative credible fear determination,
and asylum offices have to quickly
assign officers and supervisors to review
those requests. This informal, ad hoc
allowance for such requests has proven
difficult to manage and led to the
expenditure of significant USCIS
resources to entertain such requests. Yet
USCIS has continued to entertain these
requests because, in line with what
some commenters argued, IJ review has
sometimes failed to address allegations
of error or newly available evidence that
may compel a positive credible fear
determination, and individuals would
otherwise have no other recourse.
The informal ad hoc approach of
USCIS entertaining requests for review
of negative credible fear determinations
that has developed over time requires
USCIS to devote resources to these
requests that could more efficiently be
used on initial credible fear and
reasonable fear determinations,
affirmative asylum adjudications, and
now Asylum Merits interviews under
the present rule. Because there is no
formal mechanism by which to accept
and review such requests, there can be
no uniform procedure guiding their
review. Likewise, because they are not
applications, petitions, motions, or
some other type of formal request,
USCIS does not maintain
comprehensive, official data in the
Asylum Division’s case management
system on requests for reconsideration
in a standardized manner that can be
readily queried. In any event, the
Departments agree with commenters
FY19: Total negative CF determinations by the offices that tracked
RFRs.
FY19: Total RFRs submitted to offices that tracked RFRs .....................
FY19: Total negative determinations changed to positive post-RFR by
offices that tracked RFRs.
Fiscal Year 2020 (‘‘FY20’’)
During FY20, the following USCIS
asylum offices informally tracked
credible fear RFRs received at their
Fiscal Year 2021 (‘‘FY21’’)
During FY21, the following USCIS
asylum offices informally tracked
credible fear RFRs received at their
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Although the above data do not
account for every case in which a
request for reconsideration of a negative
credible fear determination was made,
they demonstrate the significant number
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Frm 00056
Fmt 4701
Francisco, CA (ZSF). The remaining
offices (Arlington, VA (ZAR/ZAC);
Chicago, IL (ZCH); and Miami, FL
(ZMI)) did not track RFRs received.
7,698.
2,109 (27 percent of negatives from the offices that tracked RFRs).
150 (7 percent of RFR submissions and 2 percent of all negatives from
the offices that tracked RFRs).
Orleans, LA (ZOL). The remaining
offices (Chicago, IL (ZCH); Miami, FL
(ZMI); and San Francisco, CA (ZSF)) did
not track RFRs received.
11,232.
1,213 (10.7 percent of negatives from the offices that tracked RFRs).
188 (15 percent of RFR submissions and 1.6 percent of all negatives
from the offices that tracked RFRs).
of requests for reconsideration that
USCIS asylum offices have entertained.
Anecdotally, offices report that given
the sizeable number of requests
received, it is not uncommon to have
PO 00000
During FY19, the following USCIS
asylum offices informally tracked
credible fear RFRs received at their
offices: Houston, TX (ZHN); Los
Angeles, CA (ZLA); New York, NY
(ZNY); Newark, NJ (ZNK); New Orleans,
LA (ZOL); and San Francisco, CA (ZSF).
The remaining offices (Arlington, VA
(ZAR/ZAC); Chicago, IL (ZCH); and
Miami, FL (ZMI)) did not track RFRs
received.
2,086 (17 percent of negatives from the offices that tracked RFRs).
231 (11 percent of RFR submissions and 2 percent of all negatives
from the offices that tracked RFRs).
offices: Arlington, VA (ZAR/ZAC);
Boston, MA (ZBO); Houston, TX (ZHN);
Los Angeles, CA (ZLA); New York, NY
(ZNY); Newark, NJ (ZNK); and New
FY21: Total negative CF determinations by the offices that tracked
RFRs.
FY21: Total RFRs submitted to offices that tracked RFRs .....................
FY21: Total negative determinations changed to positive post-RFR by
offices that tracked RFRs.
Fiscal Year 2019 (‘‘FY19’’)
12,071.
offices: Boston, MA (ZBO); Houston, TX
(ZHN); Los Angeles, CA (ZLA); New
York, NY (ZNY); Newark, NJ (ZNK);
New Orleans, LA (ZOL); and San
FY20: Total negative CF determinations by the offices that tracked
RFRs.
FY20: Total RFRs submitted to offices that tracked RFRs .....................
FY20: Total negative determinations changed to positive post-RFR by
offices that tracked RFRs.
that some type of data related to these
requests, including how many are
received, how often the negative
credible fear determinations are
reconsidered, and how often a positive
decision is issued, would be helpful to
inform this discussion. The
Departments accordingly have
attempted to gather the best data
available related to these requests, based
on informal tracking by some offices,
which is not comprehensive or
standardized.
The available data related to requests
for reconsideration (‘‘RFRs’’) of negative
credible fear determinations already
affirmed by an IJ is as follows:
Sfmt 4700
four or five senior asylum officers
working on RFRs full-time, along with
two supervisors dedicating half of each
day to RFRs on a regular basis, with
additional oversight (approximately one
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hour per day) by upper management
(such as a Section Chief). The number
of hours required to review an RFR may
vary, as the task includes reviewing the
credible fear record in light of any
allegations of clear error or the
presentation of any newly available
evidence that may change the decision
from a negative to a positive and
determining if another interview is
necessary to make a decision. In cases
in which another interview is provided,
a single request could take upwards of
four hours to complete. Moreover, given
the time-sensitive nature of the request,
considering the individual is in the
process of being expeditiously removed,
where offices exercise their discretion to
review such requests, they have to act
quickly to ensure the review takes place
prior to removal. Where RFRs are
entertained, to ensure the review takes
place prior to removal, if an office does
not already have full-time staff
dedicated to RFR review at a given
moment, they must pull asylum officers
off their regular caseload of credible
fear, reasonable fear, or affirmative
asylum cases and require them to
quickly shift gears to review RFRs, in
addition to requiring SAOs to do the
same. Furthermore, while offices have
not tracked cases where multiple RFRs
are received, anecdotally, they report
that it is not uncommon to receive
multiple RFRs from the same applicant,
in some instances as many as two to
three or more per case.
To channel USCIS’s resources to
where they can most efficiently be used,
with the present rulemaking, the
Departments first proposed revising 8
CFR 208.30(g)(1)(i) to eliminate USCIS
reconsiderations and provide that an IJ
has sole jurisdiction to review whether
the individual has established a credible
fear of persecution or torture once the
asylum officer has made a negative
credible fear determination and the
individual is served with a Form I–863
(after the individual either requests IJ
review or declines to request review and
that declination is treated as a request
for review). Once the Form I–863 was
served, jurisdiction to review the
credible fear determination would then
have rested solely with EOIR. The
Departments based this revision on the
notion that requests to reconsider
negative credible fear determinations
where applicants have new, previously
unavailable evidence, or where a clear
procedural or substantive error in the
determination is alleged, should
properly take the form of motions to
reopen before EOIR and be decided by
an IJ.
Upon further consideration and after
reflecting on the comments received on
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this topic, however, the Departments
agree with many of the commenters that
even after a negative credible fear
determination has been reviewed by an
SAO, the individual has been served
with the decision, and an IJ has
reviewed and concurred with the
negative determination, in some rare
instances USCIS may still want to
reconsider the determination as a matter
of discretion. For example, if there is an
allegation of procedural or substantive
error in the original determination and
the IJ did not address this issue during
IJ review, it may be an appropriate
exercise of USCIS’s discretion to
reconsider the case. While the
Departments disagree with the
commenters’ characterization of
credible fear interviews as rife with
procedural errors, the Departments also
recognize that errors sometimes occur
given all the unique circumstances at
play. In some instances, errors that may
or may not have been avoidable will
occur and should be corrected. In those
instances, the Departments believe there
should be some recourse for the
noncitizens who are affected. The
Departments do not take lightly the
notion that, as referred to by
commenters and as demonstrated by the
above data, there are some cases where
the negative credible fear determination
is overturned and, absent such
individuals requesting reconsideration
and USCIS exercising its discretion to
reconsider, these individuals may have
been removed to a country where they
were in fact ultimately able to
demonstrate a credible fear of
persecution or torture. Considering the
gravity of the consequences of failing to
address a potential clear error in the
negative credible fear determination,
including potentially violating the
United States’ non-refoulement
obligations and returning the individual
to a country where there is a significant
possibility that the individual could be
persecuted or tortured, the Departments
agree that it is appropriate to allow an
option for reconsideration as a last
resort. While the NPRM framed that
option as being best exercised by EOIR
before the IJ, considering the many
comments showing how USCIS is
specially positioned to reconsider a
decision even after an IJ has concurred
with it, the Departments agree that
potential reconsideration by USCIS
should continue to be allowed. As such,
instead of adopting the revisions to 8
CFR 208.30(g)(1)(i) that were proposed
in the NPRM, in this IFR, DHS is
retaining language at 8 CFR
208.30(g)(1)(i) recognizing that DHS
may, in its discretion, reconsider a
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negative credible fear finding with
which an IJ has concurred.
At the same time, the Departments
remain concerned that requests for
reconsideration of negative credible fear
determinations not be permitted to
undermine the present rule’s purpose to
create a more efficient and streamlined
process following a credible fear
determination, while ensuring due
process. As noted in the preamble to the
NPRM, the original changes to 8 CFR
208.30(g) proposed in the NPRM were
put forth to be consistent with the
statutory scheme of INA
235(b)(1)(B)(iii), 8 U.S.C.
1225(b)(1)(B)(iii), under which IJ review
of the credible fear determination serves
as the check to ensure individuals are
not returned to a country where they
have demonstrated a credible fear. The
Departments stand by that assertion
from the NPRM’s preamble and want to
emphasize that even though they are
recognizing the possibility that USCIS
may, in its discretion, reconsider a
negative credible fear determination,
such an exercise of discretion is not the
appropriate primary mechanism for
review of a credible fear
determination—that credible fear
review, per statute, rests with the IJ once
jurisdiction is transferred to EOIR. The
recognition of USCIS’s inherent
discretionary authority to potentially
reconsider a credible fear determination
must not be used to undercut the
statutory scheme of expedited removal,
including the proper role of the IJ to
review USCIS’s negative credible fear
determination, nor will DHS permit it to
obfuscate the purpose of the present
rule. Accordingly, while DHS is
maintaining the regulatory reference to
its inherent discretionary authority to
reconsider a negative credible fear
determination in the present rule, it is
also placing a temporal and numerical
limitation on allowances for
reconsideration to ensure the exercise of
such authority is consistent with the
statutory expedited removal and
credible fear framework. The present
rule provides at 8 CFR 208.30(g)(1)(i)
that any request for reconsideration
must be received no more than 7 days
after the IJ’s concurrence with the
negative credible fear determination, or
prior to the individual’s removal,
whichever date comes first. This time
limit is necessary to ensure the avenue
of allowing USCIS reconsideration does
not undercut the whole expedited
removal process in cases where the
applicant has already had an
opportunity to present his or her claim
before an asylum officer, the asylum
officer has made a decision that was
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concurred with by an SAO, and an IJ
has reviewed the determination in
accordance with the statutory scheme.
Additionally, for the same reasons, it is
necessary to limit any request for
reconsideration of a negative credible
fear determination before USCIS to one
request only, which the Departments
have also provided for at 8 CFR
208.30(g)(1)(i). Considering, as
mentioned above, that asylum offices
report receiving multiple RFRs for a
single case and devoting significant
resources that could more efficiently be
spent adjudicating the cases of
applicants who have not yet had any
opportunity for their claims to be heard,
this numerical limitation is also
essential if USCIS is going to continue
entertaining such requests. If unlimited
requests were allowed, or if there were
no limit on the time frame during which
such requests may be lodged, the
Departments would run the risk of
endorsing an ad hoc process that would
undermine the very purpose of the
statutory scheme of expedited removal
laid out by Congress, and indeed also
the very purpose of the present rule.
The Departments, after careful
reflection, instead are providing the best
balance to promote both due process
and finality, consistent with the
statutory scheme of expedited removal,
including the statutory language that
clearly directs that the IJ is the proper
reviewer of any negative credible fear
determination made by an asylum
officer.
Comments: One commenter expressed
support for the Departments’ proposal to
eliminate the regulatory text that
describes USCIS’s authority to
reconsider negative credible fear
determinations that have already been
reviewed by a supervisory asylum
officer and upheld by an IJ. This
commenter agreed with the
Departments’ assessment that the
proposal would increase efficiency, that
it more closely aligns with the statutory
scheme of section 235 of the Act, 8
U.S.C. 1225, and that it would be
necessary to ensure that requests for
reconsideration do not frustrate the
streamlined process that Congress
intended for expedited removal. The
commenter asserted that requests for
reconsideration have become ‘‘an
overwhelmingly popular tactic’’ to delay
removal among individuals without
meritorious fear claims, diverting
resources from those with legitimate
claims.
Response: The Departments
acknowledge the comment related to
how the proposed changes align with
the statutory scheme governing
expedited removal and credible fear.
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The Departments also agree that
resources should be used efficiently and
generally should not be diverted from
those who have not yet had any
interview or determination to those who
have already had an opportunity to
present their claim and who received a
negative credible fear determination
made by an asylum officer, reviewed by
a supervisory asylum officer, and
concurred with by an IJ. For these
reasons, while the Departments are not
maintaining the exact revisions to 8 CFR
208.30(g) proposed in the NPRM, the
Departments are taking this opportunity
to clarify that the statutorily-mandated
review of any negative credible fear
determination must take place by an IJ
pursuant to INA 235(b)(1)(B)(iii)(III), 8
U.S.C. 1225(b)(1)(B)(iii)(III), and that IJ
review is the appropriate method by
which a negative credible fear
determination made by USCIS is
reviewed. Following IJ review, pursuant
to USCIS’s inherent discretionary
authority to review its own decisions,
USCIS may, as a matter of discretion,
reconsider a negative credible fear
determination that has already been
concurred with by an IJ, 8 CFR
208.30(g), but the Departments agree
with the comment that this exercise of
discretion cannot be allowed to frustrate
the underlying expedited removal
process laid out by Congress.
Accordingly, DHS is providing for
revisions to 8 CFR 208.30(g) that place
reasonable limits on when USCIS may
entertain a request for reconsideration
as a matter of discretion, including that
any reconsideration be requested by the
noncitizen or their attorney or initiated
by USCIS no more than 7 days after the
IJ concurrence with the negative
credible fear determination, or prior to
the noncitizen’s removal, whichever
date comes first, and that only one such
request may be entertained per case.
These reasonable limitations are
necessary to ensure that USCIS’s
exercise of discretion in allowing any
potential reconsideration of a negative
credible fear determination is not
inconsistent with Congress’s
instructions in establishing the
expedited removal process and to
ensure requests for reconsideration
cannot be used as a tactic to delay
removal for individuals with nonmeritorious claims, which, as the
commenter expressed, is a serious issue
that diverts resources from USCIS
hearing potentially meritorious claims.
d. Removal of Mandatory Bars From
Consideration
Comments: A commenter stated that
the NPRM did not provide a good
enough rationale for rescinding the
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regulatory change that would require
application of the ‘‘mandatory bars’’
against asylum claims during credible
fear screening. The commenter
expressed opposition to ‘‘ignoring’’
mandatory bars, such as if the applicant
is a criminal, is a danger to the United
States, or participated in the persecution
of others. A number of commenters
supported the Departments’ proposal to
not apply the mandatory bars to asylum
and withholding of removal during the
credible fear screening process. One
comment stated that application of U.S.
law relating to bars to asylum is so
complex and often fact-intensive that it
is simply not possible to make fair and
accurate legal determinations on these
issues in the context of credible fear
screenings, which do not allow
sufficient time to identify the factual
information and legal arguments that
may need to be raised on these points.
Another commenter stated that
exclusion from refugee protection is a
complex inquiry into factual and legal
questions involving not only
international refugee law, but in many
cases, international human rights,
humanitarian law, and international
criminal law. The commenter stated that
this inquiry cannot be adequately
assessed in a screening interview,
particularly given truncated timelines,
lack of legal assistance, lack of
understanding about the procedure,
challenges with translation and
interpretation, and the prevalence of
trauma.
Response: The Departments
acknowledge the commenter’s invitation
to further explain their reasons for
recodifying the historical practice of not
applying mandatory bars to asylum or
statutory withholding of removal at the
credible fear screening stage. See 8 CFR
208.30(e)(5)(i)(A). As described in
Section III.A of this preamble, requiring
asylum officers to apply mandatory bars
during credible fear screenings would
make these screenings less efficient,
undermining congressional intent that
the expedited removal process be truly
expeditious. Because of the complexity
of the inquiry required to develop a
sufficient record upon which to base a
decision to apply a mandatory bar, such
a decision is most appropriately made
in the context of a full merits hearing,
whether before an asylum officer or an
IJ, and not in a screening context.
Furthermore, due process and fairness
considerations counsel against applying
mandatory bars during the credible fear
screening process. Due to the intricacies
of fact finding and legal analysis
required to make a determination on the
applicability of any mandatory bars,
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individuals found to have a credible fear
of persecution should be afforded the
additional time, procedural protections,
and opportunity to further consult with
counsel that the Asylum Merits process
or section 240 proceedings provide. In
light of the need to preserve the
efficiency Congress intended in making
credible fear screening part of the
expedited removal process and to
ensure due process for those individuals
found to have a significant possibility of
establishing eligibility for asylum or
statutory withholding of removal but for
the potential applicability of a
mandatory bar, the Departments have
determined that these goals can be
accomplished by returning to the
historical practice of not applying
mandatory bars at the credible fear
screening stage.
The commenter’s suggestion that the
Departments intend through this
rulemaking to ignore any mandatory bar
is mistaken. On the contrary, asylum
officers are trained to gather and analyze
information to determine the
applicability of mandatory bars in
affirmative asylum adjudications, and
they are instructed to assess whether
certain bars may apply in the credible
fear screening context. The latter
assessment is designed to flag any
mandatory bar issues requiring further
exploration in Asylum Merits
interviews or section 240 removal
proceedings. Asylum officers and IJs
will continue to apply the mandatory
bars in their adjudications, when
justified by the facts and the law.
Individuals subject to a mandatory bar
will not be found eligible for any
immigration benefit foreclosed by the
bar.
The Departments agree with these
commenters that a complicated process
requiring full evidence gathering and
determinations to be made on possible
bars to eligibility is incompatible with
the function of the credible fear
interview as a screening mechanism
designed to quickly identify potentially
meritorious claims deserving of further
consideration in a full merits hearing
and to facilitate the rapid removal of
individuals determined to lack a
significant possibility of establishing
eligibility for asylum, statutory
withholding of removal, or protection
under the CAT. As detailed further
above, not applying mandatory bars at
the credible fear screening stage both
preserves the efficiency Congress
intended in making credible fear
screening part of the expedited removal
process and helps ensure a fair process
for those individuals found to have a
significant possibility of establishing
eligibility for asylum or statutory
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withholding of removal but for the
potential applicability of a mandatory
bar. The Departments have determined
that these goals can be accomplished by
returning to the historical practice of not
applying mandatory bars at the credible
fear screening stage.
Comment: One commenter praised
the Departments’ proposal to generally
not apply the statutory mandatory bars
to asylum and withholding of removal
during the credible fear screening
process but urged the Departments to
remove some of the limited exceptions
to ensure any additional bars are not
applied. The commenter stated that this
is a step in the right direction, but the
regulatory language should be expanded
to eliminate consideration of the bars to
asylum resulting from the Presidential
Proclamation Bar IFR and TCT Bar rule.
Response: The Departments
acknowledge the suggestion and note
that they plan to propose to modify or
rescind the regulatory changes
promulgated in the Presidential
Proclamation Bar IFR 71 and the TCT Bar
rule 72 in separate rulemakings. These
rulemakings contain the bars that the
commenter has urged the Departments
to remove from consideration within the
credible fear process. The Departments
note that these two rules are not
currently in effect. Federal courts have
either vacated or enjoined the
Departments from implementing both
the TCT Bar IFR and TCT Bar rule as
well as the Presidential Proclamation
Bar IFR.73
Comment: One commenter urged the
Departments to implement the Global
Asylum rule, including its requirement
that USCIS asylum officers apply the
mandatory bars to asylum and statutory
withholding of removal at the credible
71 Executive Office of the President, OMB, OIRA,
Spring 2021 Unified Agenda of Regulatory and
Deregulatory Actions, Noncitizens Subject to a Bar
on Entry Under Section 212(f); Procedures for
Protection Claims, https://www.reginfo.gov/public/
do/eAgendaViewRule?pubId=202104&RIN=1615AC34 (last visited Mar. 14, 2022); Executive Office
of the President, OMB, OIRA, Fall 2021 Unified
Agenda of Regulatory and Deregulatory Actions,
Noncitizens Subject to a Bar on Entry Under
Section 212(f); Procedures for Protection Claims,
https://www.reginfo.gov/public/do/eAgenda
ViewRule?pubId=202110&RIN=1615-AC34 (last
visited Mar. 14, 2022).
72 See Executive Office of the President, OMB,
OIRA, Spring 2021 Unified Agenda of Regulatory
and Deregulatory Actions, Bars to Asylum
Eligibility and Procedures, https://www.reginfo.gov/
public/do/eAgendaViewRule?pubId=202104&
RIN=1615-AC69 (last visited Mar. 14, 2022);
Executive Office of the President, OMB, OIRA, Fall
2021 Unified Agenda of Regulatory and
Deregulatory Actions, Bars to Asylum Eligibility
and Procedures, https://www.reginfo.gov/public/do/
eAgendaViewRule?pubId=202110&RIN=1615-AC69
(last visited Mar. 14, 2022).
73 See supra note 4 (discussing recent regulations
and their current status).
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fear stage. The commenter cited the
Departments’ justification for this
provision in the preamble to the Global
Asylum rule, arguing that it is
‘‘pointless, wasteful, and inefficient to
adjudicate claims for relief in section
240 proceedings when it can be
determined that an alien is subject to
one or more of the mandatory bars to
asylum or statutory withholding at the
screening stage.’’
Response: The Departments note that
the Global Asylum rule has been
enjoined, so it cannot be implemented
at this time.74 The Departments
acknowledge that in the preamble to the
Global Asylum rule, they justified the
departure from the historic practice of
not applying the mandatory bars at the
credible fear screening stage by arguing
that it would be an inefficient use of an
immigration court’s resources to
conduct full merits hearings on claims
of individuals determined at the
credible fear stage to be barred from
asylum or statutory withholding of
removal. However, as detailed further
above, the Departments have
subsequently determined that the stated
goal of promoting administrative
efficiency can be better accomplished
through the mechanisms established in
this rulemaking, rather than through
broadly applying mandatory bars at the
credible fear stage. The Departments
now believe that it is speculative
whether, had the Global Asylum rule
been implemented, a meaningful
portion of the EOIR caseload might have
been eliminated because some
individuals who were found at the
credible fear screening stage to be
subject to a mandatory bar would not
have been placed into section 240
proceedings. On the other hand,
requiring asylum officers to broadly
apply the mandatory bars would, in
many cases, increase credible fear
interview and decision times. While the
TCT Bar IFR was in effect, asylum
officers were required to spend
additional time during interviews
determining whether the bar potentially
applied, eliciting testimony related to
the application of the bar, exploring
whether an exception to the bar might
have applied, and, if the noncitizen
appeared to be barred and did not
qualify for an exception to the bar,
developing the record to ensure a legally
sufficient determination could be made
according to the higher reasonable fear
standard. As discussed above, these
efforts also increased the workload of
supervisory asylum officers, Asylum
Division Headquarters staff, USCIS
74 See supra note 4 (discussing recent regulations
and their current status).
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Office of Chief Counsel attorneys, and
IJs. Presently, asylum officers ask
questions related to all mandatory bars
to develop the record sufficiently to flag
potential bars but, since mandatory bars
are generally not applied in the credible
fear determination, the record does not
need to be developed to the level of
detail that would be necessary if the
issue was outcome determinative for the
credible fear determination. If a
mandatory bar were outcome
determinative, it would be necessary to
develop the record sufficiently to make
a decision about the mandatory bar such
that, in many cases, the interview would
go beyond its intended purpose of being
a screening for potential eligibility for
protection and rather become a decision
on the form of protection itself. The
level of detailed testimony necessary to
make such a decision, in many cases
and depending on the facts, would
require asylum officers to spend more
time carefully developing the record
during the interview and conducting
additional research following the
interview. IJs reviewing negative
credible fear determinations where a
mandatory bar was applied would
similarly face additional factors to
consider in their review, depending on
the facts, often undermining the
efficiency of that process as well.
e. Other Comments on the Proposed
Credible Fear Screening Process
Comments: One commenter asserted
that the NPRM does not improve
efficiencies in adjudication or lead to
cost savings when compared to having
the asylum adjudication process take
place outside of the context of expedited
removal and detention. The commenter
asserted that, rather than streamlining
the process, the NPRM creates a new
layer of USCIS adjudication with
possibly two reviews by an immigration
court. The commenter also asserted that
the NPRM fails to adopt a longsuggested solution of allowing for grants
of asylum at the credible fear interview
stage or eliminating the credible fear
screening process so that cases may
proceed directly to the merits before
USCIS.
Response: The Departments note that
the goals of this rulemaking include
ensuring that noncitizens placed into
the Asylum Merits process receive final
decisions on their claims for protection
as quickly and efficiently as possible,
while also providing ample procedural
safeguards designed to ensure due
process, respect human dignity, and
promote equity. In this rule, the
Departments have outlined a process
that continues to allow noncitizens to
seek IJ review of asylum officers’
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negative credible fear determinations, as
required by statute. See INA
235(b)(1)(B)(iii)(III), 8 U.S.C.
1225(b)(1)(B)(iii)(III). In addition,
following an Asylum Merits interview
before an asylum officer, if the asylum
officer does not grant asylum, the
noncitizen will have the opportunity to
have their protection claims considered
before an IJ in streamlined section 240
removal proceedings. The Departments
expect that this new process will allow
protection claims to be adjudicated
more quickly—whether granted or not—
than they are under the current process
(in which all individuals who receive
positive credible fear determinations are
referred for ordinary section 240
removal proceedings) and will provide
procedural safeguards to ensure that
noncitizens receive full and fair
adjudications of their protection claims.
The Departments have considered the
commenter’s proposals to eliminate
credible fear screenings and adjudicate
protection claims outside the context of
the expedited removal process, as well
as to allow for grants of asylum at the
credible fear screening stage. While the
Departments acknowledge the
proposals, at this time, the Departments
decline to adopt these proposals in favor
of the approach presented in this rule.
The Departments believe that a credible
fear screening provides a meaningful
opportunity for a noncitizen to provide
USCIS asylum officers with valuable
information pertaining to their
protection claims, and that a subsequent
Asylum Merits interview will allow
noncitizens to expand on the details and
circumstances surrounding their need
for protection. On the other hand, the
credible fear screening process allows
the Departments to assess who may not
be eligible for protection and promptly
execute removal orders. Overall, the
credible fear screening process that the
Departments implement, which is
consistent with congressional intent,
allows for the Departments to identify
noncitizens who may or may not be
eligible for protection. See INA
235(b)(1), 8 U.S.C. 1225(b)(1). As for
allowing grants of asylum at the credible
fear screening stage, the Departments
acknowledge the recommendation but
are not addressing the matter in this
rulemaking as it falls outside of the
scope of this rule.
Comments: Multiple commenters
expressed support for the ‘‘clarification’’
in the NPRM that only USCIS asylum
officers would conduct credible fear
interviews. Some of these commenters
asserted that CBP officers who had
previously performed these screenings
were hostile and confrontational and
were more likely to make negative
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credible fear determinations. Another
commenter asserted that this
‘‘specification’’ is consistent with
congressional intent because the INA
expressly requires asylum officers, who
have professional training in asylum
law and interview techniques, to
conduct credible fear interviews.
Response: The Departments
acknowledge the commenters’ support
and agree that the rule clarifies that
USCIS asylum officers will conduct
credible fear interviews, which is
consistent with the INA. See INA
235(b)(1)(B)(i), 8 U.S.C. 1225(b)(1)(B)(i);
8 CFR 208.30(d). USCIS asylum officers
receive training and possess experience
in handling asylum and related
adjudications; receive regular trainings
on asylum-related country conditions
and legal issues, as well as
nonadversarial interviewing techniques;
and have ready access to country
conditions experts. The Departments
acknowledge the concerns of the
commenters regarding the conduct of
CBP officers but note that these issues
fall outside of the scope of this
rulemaking.
Comments: One commenter suggested
that the Departments should codify the
elimination of the Prompt Asylum
Claim Review (‘‘PACR’’) and the
Humanitarian Asylum Review Process
(‘‘HARP’’) by regulation, including by
imposing enhanced procedural
protections for all credible fear
interviews, including that they not be
conducted while in CBP custody. The
commenter believes that, as the
Departments revisit their asylum
screening procedures, they should take
this opportunity to prevent
reintroduction of the programs by a
future administration.
Response: Pursuant to the E.O. on
Migration’s directive to cease
implementing PACR and HARP, and to
consider rescinding any orders, rules,
regulations, guidelines, or policies
implementing those programs, the
Departments have ceased implementing
those programs. See 86 FR 8270. The
Departments acknowledge the
recommendation that those changes be
codified by regulation, but further
consideration and discussion of these
programs fall outside of the scope of this
rulemaking.
4. Applications for Asylum
a. Written Record of the Credible Fear
Determination Created by USCIS,
Together With the Service of the
Credible Fear Determination, Treated as
an Application for Asylum
Comments: A commenter expressed
support for the provision requiring
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asylum officers to provide a summary of
material facts and interview notes to
asylum seekers during the credible fear
screening process. Various commenters
expressed concern about time
constraints for asylum seekers to amend
or supplement the asylum application.
One commenter argued that the 7-day
timeline for submitting an amended or
supplemented application—10 days if
mailed—would be infeasible due to the
remote location of many asylum offices
and the brief timeline between the
interview notice and the scheduled
interview. The commenter
recommended that the rule impose a
requirement that USCIS provide a
minimum time frame for applicants
prior to the Asylum Merits interview.
Another commenter urged that more
time be allowed for applicants and
attorneys to develop a case. Some
commenters argued that the credible
fear documentation is often unreliable
and that applicants will need adequate
time and assistance to make
modifications or to supplement the
record. Citing the procedural limitations
at proposed 8 CFR 208.9(d)(1), many
commenters recommended the
Departments develop a more robust
procedure for the asylum seeker or
counsel to make corrections or
statements at any stage of the process or
during the Asylum Merits interview,
while providing additional time to
review the hearing transcript following
the hearing.
Another commenter suggested that
the proposed rule be framed with the
expectation that the asylum application
will be supplemented, modified, or
corrected prior to the hearing. The
commenter also recommended the rule
include a provision that would require
asylum officers to encourage asylum
seekers to correct or supplement the
record.
Several commenters expressed
concern that supplementations,
modifications, or corrections to the
record would undermine the applicant’s
credibility and negatively impact the
applicant’s case outcome. One
commenter recommended that the
Departments change the rule to
explicitly protect applicant credibility
with respect to modifications,
corrections, or supplementations to the
credible fear determination.
Finally, citing proposed 8 CFR
208.3(a)(2) allowing an applicant to
amend, correct, or supplement
information collected during expedited
removal, a commenter stated it was
unclear whether this provision would
also apply to the asylum officer’s
credible fear interview notes.
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Response: The Departments
appreciate comments supporting the
treatment of a credible fear
determination as an asylum application.
In creating this efficiency, the
Departments aim as well to reduce
potential barriers to protection for
eligible applicants. The Departments
acknowledge the support for the
provision stating that a copy of the
application for asylum, including the
asylum officer’s notes from the
interview and basis for the
determination, will be provided to the
noncitizen at the time that the credible
fear determination is served. See 8 CFR
208.30(f), (g)(1). The Departments
recognize that the initial screening
determination may not necessarily
capture details that an asylum applicant
wishes to include for further
consideration of the applicant’s
eligibility for asylum, statutory
withholding of removal, or CAT
protection. Therefore, it is important
that an applicant be able to modify or
supplement the application for asylum.
However, given commenters’ concerns
about credibility, ability to modify
credible fear notes, and general
concerns with the proposed process, the
Departments want to clarify that
modifications or supplements should
not seek to modify or amend the
credible fear determination made by the
asylum officer. Under this rule,
applicants may modify, amend, or
correct the biographic or credible fear
information in the Form I–870, Record
of Determination/Credible Fear
Worksheet, or alternatively, may
supplement the information collected
during their credible fear interview. The
Departments are making this change to
allow for applicants to make corrections
or further develop their claim but are
making clear that a line-by-line
correction of the asylum officers’ notes
is not necessary or expected for
purposes of the process or an
assessment of credibility. The
Departments do not believe that added
protections are needed to protect against
potential negative impacts on credibility
assessments. Where there are
discrepancies or inconsistencies, an
applicant may explain such statements
in their supplemental materials or at the
Asylum Merits interview. As is always
the case with any credibility
determination made in the context of a
nonadversarial asylum interview before
USCIS, if a credibility concern arises,
such as potential inconsistent
testimony, the applicant will be given
the opportunity to explain the
inconsistency and the concern may be
resolved if the applicant provides a
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reasonable explanation, which in some
instances may relate to the nature of the
credible fear interview itself if that
constitutes such a reasonable
explanation in the specific case. In
creating a streamlined process, the
Departments do not expect the applicant
to do a wholesale edit of a credible fear
interview record, but rather wish to
ensure that biographic and basic
information about the fear claim is
correct, so that the applicant may
further develop the claim at the Asylum
Merits interview. The Departments
address comments relating to
constraints on timeline below in Section
IV.D.4.d of this preamble.
Comments: A few commenters
warned that the proposal to treat the
record of the credible fear determination
as an asylum application would create
a conflict of interest because the asylum
office would create the same record that
it would then adjudicate, and the
asylum office would develop the record
during the credible fear screening and
could then not grant asylum based on
that record. A commenter asserted that
the person preparing the asylum
application is not simply writing down
what the applicant says and that such
person must be a zealous advocate for
the applicant, which may include
arguing for a novel interpretation of the
law. Another commenter said that the
NPRM must be revised to promote
neutral decision-making based on
objective evidence in the record and
correct application of U.S. and
international law. Another commenter
stated that if adjudicators face
significant backlogs or certain types of
claims are viewed unfavorably, it is
possible that asylum officers responsible
for preparing and lodging asylum
applications may feel pressure or
incentivized to file fewer claims (e.g., by
issuing a greater number of negative fear
determinations) and suggested that
robust protections through checks-andbalances (referencing firewalls, where
possible, as an example) within USCIS
may help alleviate such concerns.
Response: The Departments disagree
with the commenters that the asylum
officer’s role in preparing the asylum
application through the creation of the
credible fear record represents a conflict
of interest with their role in
adjudicating the asylum application of
an individual found to have a credible
fear in the first instance. By deeming the
record of the credible fear interview to
constitute the asylum application, the
Departments ensure that the statements
made by the noncitizen, including any
arguments for a novel interpretation of
the law, become part of the asylum
application. Similarly, 8 CFR
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208.30(d)(4) provides that counsel for
the noncitizen may be present at the
credible fear interview and for the
asylum officer to permit counsel to
make a statement at the end of the
interview, which statement may include
an argument for a novel interpretation of
the law, and which would become part
of the record. Furthermore, the rule
provides at 8 CFR 208.4(c)(2) that
noncitizens who receive a positive
credible fear determination that is
treated as the asylum application may
supplement the information collected
during the process that concluded with
a positive credible fear determination. It
further provides at 8 CFR 208.9(b) that
asylum applicants may have counsel or
a representative present at an Asylum
Merits interview. Such representative
will have an opportunity to make a
statement or comment on the evidence
presented upon completion of the
hearing. See 8 CFR 208.9(d). Taken
together, these provisions ensure that
noncitizens and their representatives
have ample opportunity to engage in
zealous advocacy, including the
presentation of arguments for novel
interpretations of the law. As neutral
fact finders conducting nonadversarial
interviews in both the credible fear
screening and asylum adjudication
contexts, asylum officers are dutybound to consider the totality of
evidence in the record and issue
decisions based on the facts and the
law. Their role in creating the credible
fear record that will be treated as an
asylum application thus poses no
inherent conflict of interest.
Additionally, different asylum officers
may be making the credible fear
determination and conducting the
Asylum Merits interview, thus obviating
any perceived appearance of conflict.
Furthermore, contrary to the
commenter’s assertion, nothing in this
rule pressures or incentivizes asylum
officers to issue negative credible fear
determinations that are not warranted
by the facts and law applicable to an
individual’s case. This rule aims to
address the backlog of asylum claims
before EOIR by providing a more
efficient mechanism for processing
asylum claims originating in the
credible fear screening process while
guaranteeing due process and an
objective application of the law to the
facts in each case, not by pressuring
asylum officers toward particular
outcomes.
Comments: Some commenters
opposed treating the written record of
the credible fear interview as an asylum
application on the ground that it
‘‘demands that USCIS assume the
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burden in what should be the noncitizen’s role in the asylum application
process.’’ These commenters stated that
this feature of the rule will require the
Government to adjudicate more asylum
applications.
Response: The Departments disagree
that the IFR requires USCIS to assume
a burden by treating the written record
of the credible fear determination as an
asylum application, as USCIS is
required to produce this record as part
of the credible fear screening process.
While this change will mean that a
greater percentage of noncitizens
receiving a credible fear determination
will subsequently receive a decision on
the merits of their claims for asylum,
statutory withholding of removal, and
CAT, it will also mean that a final
decision will be made in a more timely
fashion than accomplished under the
present process. As explained above,
ensuring that all noncitizens who
receive a positive credible fear
determination quickly have an asylum
application on file allows cases
originating with a credible fear
screening to be adjudicated
substantially sooner than they otherwise
would be—regardless of whether the
noncitizen is granted asylum or ordered
removed. Under the current process,
noncitizens who receive a positive
credible fear determination may wait
months or years before attending a
Master Calendar Hearing, and the IJ may
be asked for multiple continuances to
any deadline for the noncitizen to file
an asylum application. By treating the
credible fear documentation as the
application for asylum, both the
Departments and the noncitizen avoid
the burden caused by delays,
continuances, and rescheduled hearings
sought in order for the noncitizen to file
an asylum application. See supra
Section III.B of this preamble.
b. Date Positive Credible Fear
Determination Served as Date of Filing
and Receipt
Comments: Multiple commenters
supported the general idea that a
positive credible fear determination
would serve as an asylum application
filing for purposes of the one-year filing
deadline and to start the clock on
employment authorization based on a
pending asylum application, thereby
helping asylum seekers avoid missing
the one-year filing deadline and making
it possible for asylum seekers to access
employment authorization as quickly as
possible. One commenter noted that this
provision comports with the underlying
policy goals of the one-year filing
deadline. Other commenters provided
opinions about the one-year filing
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deadline generally, suggesting that the
one-year filing deadline has become a
barrier to applicants as many miss the
filing deadline through lack of
knowledge or notice of the deadline,
confusion about the process, believing
they already filed, or due to the lack of
coordination between DHS and DOJ
leading to court proceedings not being
timely initiated. One commenter
provided examples of personal stories
showcasing how many asylum seekers
fail to meet the deadline due to trauma,
grief, or hope for the possibility of safe
return to their home country.
Several commenters further reasoned
that the proposed change would save
both asylum officers and IJs time in that
they will not have to adjudicate whether
an asylum application was filed within
a year or whether an exception to the
filing deadline was established (and, if
so, whether the application was filed
within a reasonable period of time given
the exception). Instead, the commenter
suggested that adjudicators will be able
to concentrate on the substance of the
claim. Some commenters went further,
suggesting that Congress eliminate the
one-year filing deadline entirely, as the
deadline effectively acts as a bar to
asylum and has arbitrarily blocked ‘‘tens
of thousands of refugees’’ with
meritorious claims for asylum.
Various commenters supported
expedited access to EADs for asylum
seekers deemed to have a credible fear
of persecution. Commenters expressed
strong support for any procedural
changes that would make it easier for
asylum seekers to obtain EADs as
quickly as possible. An individual
commenter supported eliminating any
delay between a positive credible fear
determination and the filing of an
application for asylum by treating the
written record of the determination by
USCIS as an application for asylum and
starting the waiting period for
employment authorization based on a
pending asylum application. The
commenter said enabling asylum
seekers earlier access to employment
could reduce the public burden, reduce
the burden on the asylum support
network, and benefit asylum seekers in
terms of equity, human dignity, and
fairness. A few commenters discussed
the importance of the employment
authorization to asylum seekers,
including the ability to build financial
security; gain housing and food; pay for
competent legal counsel; ensure their
home gets heating and electricity;
escape situations of abuse; and obtain a
form of identification that may allow the
individual to get a driver’s license,
access social benefits, open a bank
account, register their child for school,
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and enroll in health insurance. Citing
research and examples from clients,
commenters asserted that employment
authorization not only allows asylum
seekers to meet their basic daily needs
and secure their fundamental rights, but
it serves the economic interests of the
United States through entrepreneurship,
professional expertise, and tax revenue.
A commenter argued that asylum
seekers who have access to employment
authorization would be less reliant on
community resources and non-profit
services. As expressed by commenters,
individuals who experience barriers to
employment authorization as a result of
erroneous calculations in the starting
and stopping of the waiting period for
an EAD based on a pending asylum
application are forced to work in
exploitative situations and cannot
support themselves or their families.
Response: The Departments agree that
ensuring that asylum seekers promptly
have an application for asylum on file
and that claims are timely adjudicated
can help promote equity and fairness for
individuals, including by allowing for
earlier employment authorization on the
basis of the asylum application or
incident to status as an asylee, which in
turn may reduce burdens on asylum
support networks or the public. These
fairness considerations were important
factors in the Departments’ decision to
treat the record underlying the positive
credible fear determination as an
application for asylum for purposes of
meeting the one-year filing deadline and
for purposes of beginning the time
period applicants must wait before
applying for or receiving employment
authorization based on a pending
asylum application. Instead of placing
all individuals with a positive credible
fear determination into removal
proceedings before EOIR, where they
then would have to defensively file a
Form I–589, Application for Asylum
and for Withholding of Removal (that
would also require USCIS Service
Center Operations to expend resources
intaking the form and scheduling
applicants for biometrics), and have
them appear for multiple hearings
before EOIR (where ICE resources would
also be required to represent the
Government in proceedings), applicants
with a positive credible fear
determination who are placed into the
Asylum Merits process will have their
credible fear record serve as the asylum
application without having to expend
additional agency resources to perform
intake or additional applicant resources
to file a new asylum application. This
process will ensure applicants can
apply for an EAD as soon as possible
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once either the requisite time period has
passed based on the record underlying
the positive credible fear determination
that serves as the asylum application or
their asylum application is granted
(making the individual eligible for
employment authorization incident to
status). Additionally, the rule will
promote equity and due process by
ensuring that individuals who are
allowed to remain in the United States
for the express purpose of having their
asylum claim adjudicated after receiving
a positive credible fear determination do
not inadvertently miss the one-year
filing deadline.
The Departments also agree that
having the record underlying the
positive credible fear determination
serve as the asylum application will
create significant efficiencies in
immigration court for noncitizens
referred to streamlined section 240
proceedings when USCIS declines to
grant asylum. Generally, noncitizens
seeking asylum and related protections
defensively during removal proceedings
must complete and file the Form I–589,
Application for Asylum and for
Withholding of Removal. IJs must often
grant continuances and delay hearings
to allow noncitizens to complete the
application. When a noncitizen files an
asylum application defensively beyond
the one-year filing deadline, the IJ and
the parties must devote resources and
time to resolving the issue of whether
any exception to the one-year bar has
been established and whether the
application was thereafter filed within a
reasonable period of time. However, this
rule will increase efficiency during
immigration court proceedings for
certain cases originating from the
credible fear process by reducing or
eliminating the need for IJs to delay
hearings for noncitizens to prepare the
asylum applications and by obviating
the need for IJs and the parties to spend
time addressing issues related to the
one-year filing deadline.
Additionally, while the Departments
agree that the issue of the one-year filing
deadline for asylum is an important one,
the comments related generally to the
one-year filing deadline go outside the
scope of the present rulemaking. The
one-year filing deadline (including
exceptions to the deadline) is set by
Congress, INA 208(a)(2)(B), 8 U.S.C.
1158(a)(2)(B).
Comments: Some commenters offered
general opinions about EADs for asylum
seekers and expressed concern that any
waiting period for employment
authorization is too long. A commenter
stated that DHS should rescind
employment authorization rules issued
by the prior Administration because
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they were issued by agency officials in
violation of the APA. The commenter
said this Administration should
immediately restore the 150-day waiting
period and 30-day processing time
requirement for asylum seekers.
Another commenter concluded that the
proposed rule ‘‘sidesteps’’ rescinding
the timeline that leaves asylum seekers
without the basic means to provide for
themselves and urged DHS to enable
applicants to seek employment
authorization based on a grant of parole
under 8 CFR 274a.12(c)(11). This
commenter stated that paroling asylum
seekers without employment
authorization simply ensures their
exploitation and destitution.
Response: The Departments
acknowledge the comments related
generally to EADs based on a pending
asylum application, often referred to as
‘‘(c)(8)’’ EADs because of the regulatory
provision under which USCIS may grant
such EADs, 8 CFR 274a.12(c)(8). The
‘‘(c)(11)’’ EADs referred to by the
commenter relate to another subsection
of that same provision, 8 CFR
274a.12(c)(11), which authorizes USCIS
to grant an EAD to a noncitizen paroled
into the United States temporarily for
urgent humanitarian reasons or
significant public benefit. The eligibility
criteria for EADs based on a pending
asylum application are beyond the
scope of the present rule. The present
rule contains no substantive changes to
EAD eligibility based on a pending
asylum application or the requisite
waiting period for applying for an EAD
based on a pending asylum application.
In the 2020 Asylum EAD Rule,75 DHS
clarified that noncitizens who have been
paroled into the United States after
being found to have a credible fear or
reasonable fear of persecution or torture
may not apply under 8 CFR
274a.12(c)(11) (parole-related EADs),
but may apply for employment
authorization under 8 CFR 274a.12(c)(8)
if they apply for asylum in accordance
with the rules for (c)(8) EADs and are
otherwise eligible. See 85 FR 38536.
Those eligibility criteria are beyond the
scope of the present rule. DHS
welcomes comments related to these
topics in separate, future rulemaking
projects, as provided in the Spring and
Fall 2021 Unified Agenda of Regulatory
and Deregulatory Actions.
75 Asylum Application, Interview, and
Employment Authorization for Applicants, 85 FR
38532 (June 26, 2020). On February 7, 2022, in
AsylumWorks v. Mayorkas, No. 20–cv–3815, 2022
WL 355213, at *12 (D.D.C. Feb. 7, 2022), the United
States District Court for the District of Columbia
vacated the 2020 Asylum EAD rule.
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c. Inclusion of Applicant’s Spouse and
Children
Comments: Several commenters
asserted that the rule should permit
asylum applicants to add a spouse and
children or supplement family
information at any point during the
application process. A few commenters
suggested that the proposed rule’s
inflexibility with regard to changes to
family information makes it more
restrictive than the current rule,
undermines the Departments’ goal of
efficiency, and contradicts the
Administration’s promise to keep
families together. Other commenters
reasoned that applicants may fail to
discuss relevant family members during
the credible fear process due to stress,
trauma, fear, confusion regarding the
asylum process and law, or because the
asylum officer fails to inquire about
family members. One commenter added
that individuals should not be forced to
choose between their own safety and
reuniting with family members.
One commenter stated that the
proposed rule fails to consider how the
provision of a credible fear decision
automatically constituting the filing of
an asylum application would affect the
many asylum seekers who do not cross
the border with their family members
(e.g., different times and places, in
groups or alone) and are thereby unable
to join their claims. The commenter
stated that the rule may result in family
separations when some family members’
asylum cases are approved and others
are not, where they could have
otherwise been joined. One commenter
concluded that requiring spouses and
children to arrive concurrently with the
principal applicant wrongly deprives
asylum seekers of protection for their
spouse or children and is furthermore
inefficient as USCIS will have to
adjudicate a Form I–730, Refugee/
Asylee Relative Petition, for family
members who do not make it into the
credible fear case. Another commenter
described the Form I–730 process and
remarked that the adjudicatory burden
on USCIS will continue for years as
more forms come into play instead of
USCIS adjudicating the whole family’s
adjustment applications all at once. A
commenter also requested information
about what will be the filing date in
situations where multiple family
members name each other as
dependents and what will happen to
dependents if the principal applicant is
not granted asylum.
Response: The Departments
acknowledge comments related to
dependents on an asylum application
for individuals placed in the Asylum
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Merits process after receiving a positive
credible fear determination. The spouse
or child (unmarried, under 21 years old)
of a principal asylee may derive asylum
status from their spouse or parent. The
derivative asylee may be included on
the original application for asylum, or,
if not included as a dependent on the
application, the principal asylee may
petition for their relatives by filing a
Form I–730, Refugee/Asylee Relative
Petition, within two years of the grant
of asylum. Like affirmative and
defensive asylum applications, a grant
of asylum to the principal asylum
applicant following an Asylum Merits
interview will confer asylum status on
their spouse or children if they are
included as dependents in the
application and not subject to any
mandatory bars to asylum applicable to
dependents. Principal applicants will be
allowed to include dependents on their
application in the new process if the
dependents also entered the United
States concurrently with the principal
applicant and are on the same credible
fear case, or, in the alternative, if the
spouse or child already has a pending
application under this new Asylum
Merits process before USCIS.
Additionally, a principal asylee may file
a Form I–730, Refugee/Asylee Relative
Petition, on behalf of any of their
qualifying derivative family members
after they are granted asylum. The
Departments are cognizant of the
concerns expressed by commenters
about the need for flexibility in allowing
dependents to be added to an asylum
case under the new Asylum Merits
process and contend that the procedures
for dependents outlined in the IFR are
as flexible as possible, while still
ensuring the process can run smoothly
and efficiently. The Departments would
like to highlight that, in the credible fear
process, applicants are specifically
asked about all of their family members,
and this information is recorded in the
Form I–870, Record of Determination/
Credible Fear Worksheet. If the
applicant receives a positive credible
fear determination and is placed in the
new Asylum Merits process, they will
be allowed another opportunity to
review and correct the information in
their Form I–870. Accordingly,
applicants will have ample opportunity
to ensure that the information related to
their family members is accurately
reflected in their application under the
new process. And if there are any
qualifying family members that entered
with the applicant or are already in the
United States and also have an asylum
application pending with USCIS after a
positive credible fear finding, the
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principal applicant is free to include
them in his or her application. If for any
reason a principal applicant fails to add
a dependent to their initial asylum
application, the principal applicant is
not prevented from having that family
member derive asylee status because the
principal applicant is free to petition for
that family member if and when the
principal applicant is granted asylum,
either by USCIS or by EOIR. With this
IFR, the Departments are now
establishing a procedure under which
the principal applicant will receive a
decision on the principal applicant’s
case before USCIS and, if the principal
applicant is not granted asylum, the
principal applicant and any dependents
on the case who are not in lawful status
will be served with an NTA in
immigration court and placed into
streamlined section 240 removal
proceedings before an IJ. In streamlined
section 240 proceedings, the principal
applicant may still be granted asylum
and, if so, may confer that asylum status
upon all of the qualifying dependents
on the case. If the principal applicant is
not granted asylum, then the principal
applicant will be considered for
statutory withholding of removal or
withholding or deferral of removal
under the CAT, and the IJ will also
consider claims of the dependents that
were elicited by the asylum officer
during the Asylum Merits interview to
determine if they are eligible for asylum
or any other form of relief or protection.
In response to the questions presented
by commenters, the filing date will
reflect the filing of the principal
applicant. If a spouse or child is a
dependent on an application under the
new Asylum Merits process and also
files as a principal applicant
themselves, then the filing date for the
dependent spouse or child’s application
will be either (1) the date the dependent
spouse or child’s Form I–589 was filed
or (2) the date of service of the positive
credible fear determination on their
spouse or parent, whichever date is
earlier. Additionally, if the principal
applicant is not granted asylum, then
the principal applicant and any
dependents who are not in lawful status
will be issued an NTA and placed in
streamlined section 240 proceedings.
See 8 CFR 208.14(c)(1). If there is a
dependent under the new process who
also has a pending affirmative asylum
application before USCIS, then USCIS
will adjudicate that asylum application
on its own before placing that
individual in section 240 proceedings
and, if that individual is eligible for
asylum as a principal applicant, the
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individual would not be referred to
immigration court.
Additionally, under the revised 8 CFR
208.16, for cases under the jurisdiction
of USCIS following a positive credible
fear determination, if USCIS found the
principal applicant ineligible for
asylum, though USCIS cannot grant
withholding or deferral of removal, the
asylum officer is authorized to make a
determination on the principal
applicant’s eligibility for statutory
withholding of removal or withholding
or deferral of removal under the CAT if
the principal applicant shows eligibility
for such relief based on the record
before USCIS. If USCIS determines that
the principal applicant has shown
eligibility for withholding or deferral of
removal based on the record before
USCIS, that determination will be given
effect by the IJ if the IJ finds the
principal applicant ineligible for asylum
and issues a final order of removal,
unless DHS demonstrates that evidence
or testimony specifically pertaining to
the respondent and not included in the
record of proceedings for the USCIS
Asylum Merits interview establishes
that the respondent is not eligible for
such protection(s), pursuant to the new
8 CFR 1240.17(i)(2). As described in 8
CFR 1240.17(i), once in section 240
proceedings, under the new process, the
IJ will conduct a de novo review of the
principal applicant’s eligibility for
asylum, and if the principal applicant is
not granted asylum, will consider de
novo the principal applicant’s eligibility
for statutory withholding of removal
and withholding or deferral of removal
under the CAT in cases where USCIS
did not determine that the respondent
was eligible for such relief. In cases
where the principal applicant is not
granted asylum by the IJ, the IJ will also
review asylum eligibility for all other
family members and if one family
member is found eligible for asylum by
EOIR and the others can receive asylum
as derivative asylees, it will not be
necessary for the IJ to evaluate the
remaining family members’ eligibility
for asylum or withholding or deferral of
removal. If a respondent is not granted
asylum and cannot otherwise derive
asylum from a family member, then the
IJ will review each respondent’s
eligibility for statutory withholding of
removal and withholding or deferral of
removal under the CAT.
Comments: One commenter requested
the regulatory language be amended to
define ‘‘accompanying family members’’
in 8 CFR 208.30, including by
specifying what family members are
included (e.g., siblings, cousins, etc.)
and what including the family members
on the form would accomplish.
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Response: The Departments
acknowledge the comment related to
who may be included as an
accompanying family member in a
credible fear determination, but fully
specifying the details of that process is
beyond the scope of this rulemaking. In
most cases, however, the Departments
understand an ‘‘accompanying family
member[ ]’’ to include a parent or
sibling.
Comments: A commenter warned that
the proposed inclusion of an applicant’s
spouse and children in the request for
asylum conflicts with existing
regulations. The commenter described
what they called ‘‘riders,’’ or those
individuals who previously filed
affirmative applications and are already
in the country and remarked that
existing regulations require riders not
originating from a credible fear claim to
receive NTAs and be referred to
immigration court for section 240
removal proceedings (8 CFR
208.14(c)(1)). The commenter argued
that the proposed rule does not address
this or how this circumstance would
work procedurally and asserted that
riders cannot be included in grants of
statutory withholding of removal or
protection under the CAT.
Response: The Departments
acknowledge the comments related to
so-called ‘‘riders.’’ The present
rulemaking does not change the
governing law with respect to who may
derive asylum from a principal
applicant granted asylum in the United
States. INA 208(b)(3), 8 U.S.C.
1158(b)(3). Further, the present
rulemaking is not changing the status
quo governing withholding of removal
or deferral of removal with respect to an
individual—both forms of relief or
protection are individual in nature and
a dependent cannot derive any status
from a family member’s grant of
withholding or deferral of removal. The
present rulemaking is not changing
anything about the nature of
withholding or deferral of removal in
that neither confer any type of status to
a dependent. If a principal applicant is
not granted asylum by USCIS under the
new Asylum Merits process, then the
principal applicant and all dependents
included in the request for asylum who
are not in lawful status will be issued
an NTA and placed in streamlined
section 240 proceedings, as described
above. If one of the dependents does
have a pending affirmative asylum
application before USCIS, then that
application will be adjudicated as well,
but if that individual is not found
eligible for asylum on their own, then
they will also be issued an NTA and
placed in section 240 proceedings if
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they are not otherwise in lawful status.
Accordingly, the concerns expressed by
the commenter related to ‘‘riders’’
appear to be unfounded, as anyone
without legal status who is found
ineligible for asylum by USCIS, whether
in the affirmative asylum process or
under this new Asylum Merits process,
will be issued an NTA and placed in
section 240 proceedings before an IJ.
d. Due Process in Asylum Applications
Comments: Some commenters
emphasized the importance of formal
hearings and a presentation of all
available evidence in a court setting to,
in their opinion, ensure due process. A
few commenters argued that it was
important for asylum claims to be heard
before an independent, impartial
judiciary.
Response: The Departments disagree
that a court setting or independent
judiciary is necessary or otherwise
required to allow for due process. See,
e.g., 16D C.J.S., Constitutional Law sec.
2010 (2022) (‘‘Due process always
stands as a constitutionally grounded
procedural safety net in administrative
proceedings[.]’’). Moreover, transfer of
authority to the Judiciary is outside the
Departments’ authority and beyond the
scope of this rulemaking. The
Departments only have the authority to
promulgate rulemaking with respect to
the authority already delegated to them
by statute. Congress has expressly
recognized the unique and specialized
role of asylum officers in making
credible fear determinations and in
adjudicating the merits of asylum
applications. Congress explicitly
designated that ‘‘asylum officers’’ are
responsible for conducting credible fear
interviews and making credible fear
determinations. INA 235(b)(1), 8 U.S.C.
1225(b)(1). Further, an ‘‘asylum officer’’
is defined by statute at INA 235(b)(1)(E),
8 U.S.C. 1225(b)(1)(E), as an
immigration officer who: (1) ‘‘has had
professional training in country
conditions, asylum law, and interview
techniques comparable to that provided
to full-time adjudicators of applications
under’’ INA 208, 8 U.S.C. 1158, and (2)
‘‘is supervised by an officer who meets
the condition described in clause (i) and
has had substantial experience
adjudicating asylum applications.’’
Thus, Congress specifically
contemplated that asylum officers act as
full-time adjudicators of asylum
applications and have specialized
training to conduct such adjudications.
Moreover, in addition to laying out the
required background and role of asylum
officers who both conduct credible fear
determinations and adjudicate
applications for asylum under INA 208,
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8 U.S.C. 1158, Congress emphasized the
important role of asylum officers in
adjudicating asylum applications filed
by even the most vulnerable applicants.
In the William Wilberforce Trafficking
Victims Protection Reauthorization Act
of 2008, Public Law 110–457, 122 Stat.
5044, Congress provided that asylum
officers have initial jurisdiction over
any asylum application filed by an
unaccompanied child, and therefore
asylum officers are specifically
empowered to take all necessary steps to
render a decision on an affirmative
asylum case filed by a UAC. INA
208(b)(3)(C), 8 U.S.C. 1158(b)(3)(C).
Accordingly, Congress has repeatedly
recognized the vital role of asylum
officers in various contexts related to
asylum applications.
Under the INA, asylum officers are
authorized to make initial credible fear
determinations and are also the only
adjudicators authorized to conduct the
initial interview of the most vulnerable
asylum applicants, unaccompanied
children, even where those children
may have already been placed into
section 240 removal proceedings before
EOIR. In addition to these very
particular roles that Congress assigned
to asylum officers, asylum officers are
also recognized as full-time adjudicators
of asylum claims under INA 208, 8
U.S.C. 1158. Asylum officers receive
extensive training in substantive law
and procedure, nonadversarial
interview techniques and record
development, decision writing, research
skills, working with interpreters, and
interviewing vulnerable individuals,
including children; lesbian, gay,
bisexual, transgender, queer, and
intersex (‘‘LGBTQI’’) persons; survivors
of gender-based violence; and survivors
of torture and trauma. The extensive
and well-rounded training asylum
officers receive is designed to enable
them to conduct nonadversarial
interviews in a fair and sensitive
manner. Indeed, Congress recognized
the special role of asylum officers when
it vested asylum officers, not IJs, with
initial jurisdiction over asylum
applications submitted by
unaccompanied children even where
they have already been placed in section
240 removal proceedings before EOIR.
The present rulemaking builds on the
already existing role of asylum officers
in adjudicating affirmative asylum
applications to have asylum officers also
adjudicate asylum applications of
individuals retained by or referred to
USCIS for further consideration through
an Asylum Merits interview following a
positive credible fear determination.
Additionally, after considering
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comments and adjusting the present
rule such that asylum officers will no
longer issue removal orders under the
framework of this rule as described
above and below, USCIS will not be
issuing orders related to statutory
withholding of removal or withholding
or deferral of removal under the CAT. In
those cases in which the asylum officer
finds that an individual is not eligible
for asylum, the asylum officer will
determine whether the individual is
nonetheless eligible for withholding of
removal under 8 CFR 208.16(b) or (c) or
deferral of removal under 8 CFR 208.17.
As proposed in the NPRM, asylum
officers will determine applicants’
eligibility for withholding of removal,
thereby maintaining the due process
protections that already exist within
affirmative asylum interviews
conducted by USCIS asylum officers.
See 8 CFR 208.9. While the Departments
appreciate the concerns expressed by
commenters concerned with protecting
the due process rights of asylum
applicants, the Departments are
confident that those rights will be
preserved through the nonadversarial
interview process conducted by highly
trained and specialized asylum officers,
with a de novo review of the asylum
claim by an IJ if USCIS finds the
applicant ineligible for asylum. The IJ
will also review any claim to statutory
withholding of removal or withholding
or deferral of removal under the CAT
and any other potential form of relief or
protection if the applicant is not granted
asylum. Moreover, the rule does not
contemplate any change to the
noncitizen’s ability to appeal an IJ’s
decision.
Comments: Various commenters
expressed concern that the proposed
rule does not establish a minimum
amount of time between the positive
credible fear determination and the
Asylum Merits interview for asylum
seekers to obtain counsel and prepare
before the hearing. One commenter
asserted that the rule seeks to
‘‘unreasonably shorten’’ asylum seekers’
timeline for finding representation and
gathering evidence—both time
consuming processes that may require
additional steps such as translation or
mail services. Another commenter
argued that the lack of ‘‘meaningful
temporal space’’ between the credible
fear determination and the asylum
hearing would wrongly favor an
efficient administrative process over a
reasoned and fair decision of law.
Another commenter suggested that
provisions to expedite and replace the
existing application process would go
against congressional intent to identify
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and protect the rights of genuine asylum
seekers to due process. Similarly,
another commenter expressed concern
that the rule’s silence on the timeline
between the credible fear determination
and the hearing before an asylum officer
may frustrate the statutory right of
access to counsel. While the rule would
clarify the right to representation during
the hearing, some commenters
expressed the concern that asylum
seekers would not be able to secure
counsel in practice. They argued that
the time between the credible fear
determination and the hearing before an
asylum officer is short and would not
account for applicants with limited
resources and language barriers.
Several commenters expressed
concern that applicants would
encounter difficulties in meeting the
evidentiary requirements for the asylum
hearing due to trauma, time restraints,
detention, and other compounding
factors. Specifically, commenters argued
that survivors of trauma are often most
likely to have trouble gathering
sufficient evidence to support their
application due to time restraints, the
unavailability of documentary evidence
and services, intimidation, and
unawareness of available resources. One
commenter expressed concern that the
new credible fear process would not
provide enough time for survivors of
trauma or torture to recover and
adequately prepare for interviews. One
commenter claimed that any proposal to
amend the rule that overlooks the
intersection of trauma and the outcome
of an asylum application will ‘‘result in
systematic refoulement.’’ Similarly,
another commenter argued that some
individuals—including those with low
levels of literacy, those with language
access issues, and those who have
suffered from trauma—may require
additional time and assistance to
complete or amend their applications.
Many commenters recommended that
the rule ensure meaningful
opportunities for asylum seekers to find
counsel and gather evidence by
establishing an adequate timeline
between the credible fear determination
and the Asylum Merits interview before
an asylum officer. One commenter
recommended that the rule should
provide a minimum 90-day timeline to
submit evidence to USCIS between the
credible fear determination and the
Asylum Merits interview.
Response: The Departments
acknowledge concerns raised related to
the amount of time provided between
service of the positive credible fear
determination and the Asylum Merits
interview before USCIS. The
Departments understand that applicants
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will need time to review their
applications and supporting
documentation, consult with
representatives, and prepare for their
Asylum Merits interview. At the same
time, the underlying purpose of the
present rule is to make the process more
efficient by streamlining proceedings
that heretofore have been drawn out for
months or even years. To balance the
efficiency goals of the present rule with
the due process concerns raised by
commenters and shared by the
Departments, DHS is clarifying at 8 CFR
208.9(a)(1) that there will be a minimum
of 21 days between the service of the
positive credible fear determination on
the applicant and the date of the
scheduled Asylum Merits interview.
While recognizing that affirmative
asylum applicants often spend a greater
amount of time preparing their asylum
application in advance of filing and
have more time inside the United States
to procure and consult with counsel, the
Departments also must consider that
delaying the Asylum Merits interview
for any considerable length of time to
allow applicants in the Asylum Merits
process a similar amount of time would
undermine the basic purpose of this
rule: To more expeditiously determine
whether an individual is eligible or
ineligible for asylum. Accordingly, the
Departments must weigh the benefits
associated with more expeditiously
hearing and deciding claims originating
in the context of expedited removal and
the credible fear screening process with
the challenge applicants and
representatives may face in preparing
for the Asylum Merits interview during
a limited time period, including where
language barriers and other challenges
raised in the comments are present.
Thus, after careful consideration, the
Departments have determined that a 21day minimum time frame between
service of the positive credible fear
determination and the Asylum Merits
interview is the most reasonable option.
This 21-day minimum time frame will
strike an appropriate balance between
achieving operational efficiency and
still ensuring fairness by providing
applicants and their representatives
time to prepare for the Asylum Merits
interview.
Comments: Citing research,
commenters also suggested that the
location of the asylum interview, in
addition to the timeline, affects asylum
seekers’ ability to gather evidence and
find counsel, including where such
asylum seekers are survivors of trauma
with scarce resources. A commenter
suggested that the ability to access
counsel and have a legal representative
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present at the Asylum Merits interview
would only be meaningful if the hearing
takes place in an accessible location and
if the applicants have sufficient
opportunity to gather evidence and
prepare. Considering the importance of
location in assessing due process
concerns, one commenter urged the
Departments to provide more clarity on
the location of the nonadversarial
Asylum Merits interviews to ensure
meaningful access to legal
representation and adequate
opportunities to meet evidentiary
requirements. A commenter also
suggested the rule include a two-hour
limit on the distance between the
location of the scheduled interview and
the applicant’s location and provide an
automatic mechanism for changing the
location if a person moves within the
United States. Another commenter
recommended that this rulemaking
provide a right to seek a change of
venue to avoid the risk of an ‘‘unfair
burden’’ on asylum seekers who move
after being released from detention. A
commenter suggested that the Asylum
Merits interview occur with USCIS at
the asylum seeker’s initial destination
outside of the expedited removal
process.
Response: The Departments
acknowledge the comments related to
location of the Asylum Merits interview
and potential changes in the location of
the interview. Under the present rule,
following the positive credible fear
determination where the applicant is
placed into the Asylum Merits process,
the applicant’s interview will be
scheduled with the asylum office with
jurisdiction over their case. Just like
affirmative asylum cases, sometimes the
asylum office with jurisdiction over the
case may be distant from the applicant’s
residence. Unfortunately, because
USCIS has limited asylum offices and
office space, it would be impossible to
always ensure an applicant only has to
travel two hours or less to appear at an
interview, but USCIS makes every
reasonable effort to schedule applicants
in a convenient location, including by
orchestrating asylum interviews at
circuit ride locations (i.e., locations
other than an asylum office, such as a
USCIS field office, where USCIS
conducts asylum interviews) throughout
the United States when possible and
practicable. As for the comments
recommending that the hearing should
take place at the asylum applicant’s
initial destination outside of the
expedited removal process, USCIS
agrees that this is the appropriate venue
when the applicant has been paroled,
and that is why the asylum office with
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jurisdiction over the applicant’s place of
residence following the positive
credible fear determination will be the
office with jurisdiction over the
applicant’s case. Additionally, if an
applicant changes residence prior to an
Asylum Merits interview and notifies
USCIS of the change, just as with an
affirmative asylum interview, USCIS
will attempt to reschedule the
applicant’s interview to occur at the
office with jurisdiction over the
applicant’s new residence location.
USCIS also appreciates the comments
related to applicants securing access to
counsel for their Asylum Merits
interview. Just as with affirmative
asylum interviews, USCIS will make
reasonable efforts to ensure applicants
are scheduled for their Asylum Merits
interview in a time and place that
ensures their representatives of record
can attend and meaningfully participate
in the interview.
Comments: Some commenters
suggested that requests for adjournment
or continuances should be assessed
more liberally where the delay sought is
to find an attorney or gather supporting
evidence. One commenter
recommended that the rule decouple the
proposed definition of ‘‘filing’’ a claim
from the time periods specified in the
INA, including the 45 days required for
initial consideration and 180 days for
completion.
Response: The Departments
acknowledge the comments related to
the timeline for applications and
potential continuances. The
Departments cannot change the
statutory procedures governing asylum
under INA 208, 8 U.S.C. 1158, including
the procedures set out in INA
208(d)(5)(A), 8 U.S.C. 1158(d)(5)(A),
related to security checks and the
general framework indicating that in the
absence of exceptional circumstances,
the initial interview or hearing on the
asylum application shall commence no
later than 45 days after the date an
application is filed, and in the absence
of exceptional circumstances, the
administrative adjudication of the
application, not including
administrative appeal, shall be
completed within 180 days of the filing
date. Accordingly, it is not within the
Departments’ authority to decouple the
filing date from the timeline for
adjudicating the asylum application.
Regarding requests to reschedule,
applicants should follow the
instructions on the USCIS website and
their appointment notices, just as they
do with affirmative asylum interviews.
Comments: Various commenters
expressed concern about time
constraints for asylum seekers to amend
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or supplement the asylum application.
One commenter argued that the 7-day
timeline for submitting an amended or
supplemented application—10 days if
mailed—would be infeasible due to the
remote location of many asylum offices
and the brief timeline between the
interview notice and the scheduled
interview. The commenter
recommended that the rule impose a
requirement that USCIS provide at least
six weeks’ notice to applicants prior to
the asylum hearing.
Response: As mentioned in the
response to comments related to what
form the application for asylum will
take under the new rule and how it may
be supplemented or modified, the
Departments recognize that the initial
credible fear screening determination
may potentially include errors or
misunderstandings and may not
necessarily capture every detail an
applicant would like to provide. The
Departments agree with commenters
that it is important for applicants to be
able to modify or supplement their
applications for asylum to account for
such misunderstandings or errors or to
add nuance. However, also as
mentioned in the earlier response, the
Departments note that modifications or
supplements should only take the form
of correcting the biographic or credible
fear information in the Form I–870,
Record of Determination/Credible Fear
Worksheet, or providing additional
evidence beyond that collected during
the credible fear interview. The credible
fear determination and the notes
collected by the asylum officer are part
of the record of determination and form
the basis for establishing a credible fear
of persecution or torture, but it would
not be practical or possible to expect the
applicant to review the entirety of the
asylum officer’s notes or the asylum
officer’s own work product in making
the credible fear determination and
make modifications to those items.
As further explained in the response
to previous comments on the topic of
what form amendments may take, in
creating a streamlined process, the
Departments do not expect the applicant
to do a wholesale edit of a credible fear
interview, but rather wish to ensure that
biographic and basic information about
the fear claim is correct, so that the
applicant may further develop the claim
at the Asylum Merits interview.
Accordingly, while the Departments
appreciate commenters’ concerns about
the time frame under which applicants
may be expected to make corrections or
provide supplemental evidence, the
Departments believe that the provided
time frame achieves the best possible
balance between allowing applicants
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sufficient time to present their evidence
and achieving a streamlined process.
The six-week notice time frame
suggested by one commenter would be
twice as long as the notice provided to
affirmative asylum applicants for their
interviews. While the commenter might
consider six weeks an ideal time frame
to prepare for an asylum interview, it
would not be practical or achieve the
goals of operational efficiency to wait
six weeks for the interview to take place
in every case. As mentioned above,
however, there will be a minimum time
frame between the positive credible fear
determination and the Asylum Merits
interview of 21 days. Also, as described
above, USCIS believes this time frame
best reaches the goals of providing
applicants in this new process with
adequate time to prepare for their
Asylum Merits interviews and allowing
expeditious adjudications. As for the
time frame for submitting additional
evidence, USCIS is providing applicants
in the Asylum Merits process with
evidentiary submission requirements
that also reflect that careful balance. It
would be impractical for USCIS to
require all evidence to be submitted at
the credible fear stage, and USCIS
recognizes that applicants may need
time to collect some additional
evidence. Moreover, while the burden of
proof is on the applicant to establish
eligibility for asylum, as always with
any asylum case, documentary evidence
is not required to sustain the applicant’s
burden of proof in establishing asylum
eligibility; testimony alone may be
sufficient where it is credible,
persuasive, and refers to specific facts
sufficient to demonstrate that the
applicant is a refugee. INA
208(b)(1)(B)(i), (ii), 8 U.S.C.
1158(b)(1)(B)(i), (ii). When applicants
seek to provide documentary evidence
to sustain their burden of proof, USCIS
welcomes that evidence but also must
place some limit on the time for
submission to allow asylum officers to
meaningfully engage with the evidence.
Asylum officers must review each case
file, including the evidence the
applicant has submitted in support of
the applicant’s claim, sufficiently in
advance of the Asylum Merits interview
to begin to assess its probative value,
conduct additional research if needed,
and prepare to elicit testimony from the
applicant about such evidence. The
Departments agree with commenters
that applicants need time to locate and
submit such evidence, but asylum
officers also need time to review and
examine such evidence in advance of
the interview if the evidence is to be
meaningfully explored. Accordingly, the
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Departments consider that requiring
additional evidence be submitted at
least 7 days in advance of the interview
if submitted in person, or postmarked
10 days in advance if mailed, is a
reasonable time given the various
interests at play in setting up such a
time frame. While DHS appreciates the
specific comment related to the
challenge of submitting evidence in
person, that is precisely why DHS is
allowing an additional 3 days for
mailing if evidence is submitted via
mail. This time frame allows for asylum
offices to receive and properly file the
evidence and for asylum officers to
review submissions as they prepare for
Asylum Merits interviews. This time
frame also preserves the time available
during the Asylum Merits interview to
meaningfully elicit testimony from an
applicant and allow representatives
time to ask follow-up questions or
provide additional statements if needed,
instead of taking up that time with the
asylum officer’s review of justsubmitted evidence. Notably, this time
frame for the Asylum Merits interview
is more generous to applicants than the
time frame provided at current 8 CFR
208.9, which requires evidence to be
submitted at least 14 days in advance of
the interview. Given the realities of the
COVID–19 pandemic, current
operational practice is to require
evidence to be submitted 7 days in
advance of an affirmative asylum
interview if submitted in person, and 10
days if submitted via mail. Moreover, if
there is evidence that the applicant was
unable to procure during the required
time frame and that the applicant
believes is highly material or essential
to the applicant’s case, the asylum
officer has discretion to allow the
applicant a brief extension to provide
such evidence. Likewise, if an asylum
officer identifies a piece of evidence that
is essential, such as evidence necessary
to establish a derivative relationship for
a member of the case, the asylum officer
will issue a request for evidence to the
applicant and provide a reasonable time
to respond. And as mentioned above,
documentary evidence is not required to
sustain the applicant’s burden of proof
in establishing asylum eligibility—
testimony alone may be sufficient where
it is credible, persuasive, and refers to
specific facts sufficient to demonstrate
that the applicant is a refugee. INA
208(b)(1)(B)(i), (ii), 8 U.S.C.
1158(b)(1)(B)(i), (ii). Furthermore, even
in cases where the asylum officer
determines that the applicant should
provide evidence that corroborates
otherwise credible testimony, if the
applicant does not have the evidence
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and cannot reasonably obtain the
evidence, it is not required to be
provided. Id. Thus, even where the
applicant may wish to provide
additional documentary evidence, but it
is not reasonably available in the time
frame provided, the applicant may still
meet the burden of establishing asylum
eligibility.
Comments: Several commenters
asserted that applicants must be allowed
adequate representation when preparing
an asylum application; one commenter
explained that such representation is
necessary to ‘‘make an effective
submission’’ while ‘‘meet[ing] the
standards of modern corroboration
requirements’’ in adjudication.
Commenters argued that asylum seekers
may not understand what nuances in
the record could affect their case due to
the complex, politicized, and evolving
nature of asylum standards. Therefore,
as one commenter asserted, the
opportunity to amend or correct the
credible fear interview record would
only be meaningful if applicants have
access to adequate interpretation and
legal services. Similarly, another
commenter stated that correcting or
supplementing a credible fear interview
record could be ‘‘difficult or
impossible’’ without legal counsel. A
commenter added that a lack of
resources, poor knowledge of systems,
and obstacles associated with detention
intensify the need for counsel in the
asylum application process. Considering
these challenges, the commenter
recommended that agencies inform
asylum seekers—in their own
language—of their right to counsel, to
present additional evidence, and to
expand the grounds of the asylum
claim. Additionally, the commenter
recommended that agencies clarify the
higher standards at the asylum
interview compared with the credible
fear interview and provide a contact list
of local legal services providers.
Response: The Departments
acknowledge the comments related to
the role of counsel for applicants who
are placed in the Asylum Merits
interview process. As mentioned above
in response to comments about
amending or supplementing the
application, the Departments do not
expect the applicant to conduct a wordby-word, line-by-line review of the
asylum officer’s credible fear interview
and make corrections to the notes or the
asylum officer’s work product. Instead,
the Departments would welcome any
corrections to the applicant’s biographic
information, clarifications the applicant
would like to make to the Form I–870,
or any additional evidence the applicant
would like to provide in support of the
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application. In any event, the
Departments agree with commenters
that information related to the process
in which the applicant is placed and
access to counsel are of utmost
importance. That is why the
Departments plan to ensure that when
an individual is placed in the Asylum
Merits process, the individual is
provided with a fact sheet explaining
the process, including the relevant
standards, and a contact list of free or
low-cost legal service providers similar
to that which applicants would receive
in section 240 removal proceedings
before EOIR.
Comments: Many commenters
reiterated the challenges asylum seekers
experience in obtaining access to
adequate counsel and developing their
asylum claims, particularly while in
detention or during expedited
processes. One commenter argued that
noncitizens must be given an
opportunity to amend their credible-fear
interview record with representation
because, in the context of detention,
DHS is ‘‘not currently capable of
carrying out a proper fact-finding
proceeding.’’ Another commenter
additionally claimed that adequate
interpretation and legal services are
‘‘nearly impossible’’ to find when the
applicant is detained. A commenter
added that the proposed rule only
allows for legal representation at no
expense to the Government in the
application process, compounding
difficulties for asylum seekers who are
ineligible to apply for employment
authorization. Several commenters
proposed that the Government fund
legal representation programs for
asylum seekers in the credible fear and
Asylum Merits stages. Additionally, a
commenter suggested the rule provide
more information on access to counsel,
legal orientation programs, and
education for pro se applicants and
applicants with cognitive, mental, or
physical impairments.
Response: The Departments
acknowledge the comments related to
access to counsel while in expedited
removal; however, such comments are
outside the scope of the present
rulemaking, as they relate to the
expedited removal process generally.
This rulemaking is not altering the
expedited removal process itself but
rather introducing an alternative
procedure for ‘‘further consideration’’ of
the asylum claims of individuals who
receive a positive credible fear
determination. The rule preserves
applicants’ ability to retain and access
counsel within the new Asylum Merits
process before USCIS. Further, while
the Departments appreciate comments
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suggesting the possibility of
Government-funded attorneys in the
credible fear process and for the asylum
application, those comments are also
outside the purview of this rulemaking.
The Departments agree that it is
important to, whenever feasible, provide
applicants with information on access to
counsel and provide education for pro
se applicants. That is why such
information, including an advisal of the
right to be represented during the
interview and of information related to
the nature of the interview, is provided
to applicants at various stages during
the credible fear interview, including
during the interview itself. Further, the
Departments plan to provide
information about the Asylum Merits
process, as well as information related
to free or low-cost legal service
providers, along with service of the
positive credible fear determination.
The Departments take commenters’
concerns about applicants with
cognitive, mental, or physical
impairments very seriously. DHS
already has a practice of placing
individuals in section 240 removal
proceedings when they are unable to
testify on their own behalf due to
possible cognitive or mental
impairments, physical disability, or
other factors that impede them from
effectively testifying in the context of a
credible fear interview. In section 240
proceedings, IJs consider whether
applicants demonstrate indicia of
incompetency and, if so, which
safeguards are appropriate. See, e.g.,
Matter of M–A–M–, 25 I&N Dec. 474
(BIA 2011). Accordingly, applicants
with indicia of incompetency will
continue to have their claims
considered in ordinary section 240
proceedings.
Comments: Commenters asserted that
the NPRM’s estimated 90-day case
completion timeline would be
‘‘unrealistic,’’ ‘‘troubling,’’ and ‘‘could
prejudice the rights of asylum seekers.’’
One of these commenters argued that
the expedited timeline would affect due
process, in part because asylum seekers
often have limited resources, physical
and emotional needs, and barriers to
preparing their cases, including
difficulty finding counsel. Similarly, a
commenter expressed concern that the
proposed rule at 8 CFR 208.3(a)(2)
would maintain the 45-day timeline for
consideration and 180-day requirement
for completion. Another commenter
argued that the 45-day timeline for
completing adjudications for new
arrivals would ‘‘require extraordinary
resources,’’ contribute to the USCIS
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backlog, and exacerbate due process
concerns.
Response: The Departments
acknowledge commenters’ concerns
regarding the timeline of case
processing. As mentioned above with
respect to the comments related to the
processing timeline from positive
credible fear determination to Asylum
Merits interview, it is not within the
Departments’ authority to change the
45-day timeline for interviews and the
180-day timeline for adjudications set
by Congress in INA 208(d)(5)(A), 8
U.S.C. 1158(d)(5)(A), absent exceptional
circumstances. In this IFR, the
Departments changed the rule language
from that proposed in the NPRM to
acknowledge that Asylum Merits
decisions would generally be issued
within 60 days of service of the positive
credible fear determination absent
exigent circumstances. See 8 CFR
208.9(e)(2).
Comments: A commenter argued that
the proposal to remove the application
requirement for noncitizens
apprehended at the border gives such
noncitizens procedural protections not
afforded to asylum seekers who already
reside in the United States. The
commenter opposed the possibility that,
under the proposed provisions, asylum
seekers with strong ties to the United
States would still be required to
complete and submit Form I–589 in a
timely fashion, while individuals
seeking admission at the border would
have rights beyond what existing
statutes provide. The commenter added
that the lack of an asylum application
requirement would complicate the
review of cases.
Response: The Departments
acknowledge the comments related to
the form of application created by this
rule, but the present rule is not
eliminating the requirement that there
be an application for asylum from the
principal applicants in the new process.
Instead of affirmatively filing a Form I–
589, as is required for individuals in the
United States who have not been placed
into section 240 removal proceedings
and seek to file for asylum affirmatively
before USCIS, or defensively filing a
Form I–589, as is required for
individuals in the United States who
have already been placed into section
240 removal proceedings (either
following a positive credible fear
determination or otherwise), applicants
in the process established by this IFR
will be considered to have filed their
asylum application in the form of the
documented testimony provided under
oath to an asylum officer during the
credible fear interview and included as
part of their positive credible fear
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determination. 8 CFR 208.3(a). The
Departments are streamlining the
requirement for individuals who are
already in the credible fear process such
that the information collected in the
credible fear determination itself
becomes the basis of an application for
asylum. To require such individuals to
subsequently submit a paper I–589
asylum application in order to seek
asylum would be unnecessarily
repetitive. Treating the credible fear
determination as the asylum application
eliminates duplicative collection of
information for individuals who have
already been found to have a credible
fear of persecution or torture. These
individuals are still subject to the oneyear filing deadline and the other
statutory bars to filing for asylum, the
same requirements to appear for an
interview, the same consequences for a
failure to appear before USCIS, and the
same requirements for EAD eligibility as
other applicants. Moreover, the
underlying procedures related to
attorney participation remain the same
as those for affirmative asylum
applicants before USCIS. Most
fundamentally, the eligibility standards
governing adjudication of asylum
applications are identical for applicants
in the new process as they are for
affirmative asylum applicants.
In addition, the Departments will
provide ample procedural safeguards to
noncitizens throughout the new process
established in this rule, including in the
Asylum Merits interview itself, such as
the following: (1) A verbatim transcript
of the interview will be included in any
referral package to the immigration
judge, 8 CFR 208.9(f)(2); (2) an asylum
officer will arrange for the assistance of
an interpreter if the applicant is unable
to proceed effectively in English, and if
an interpreter is unavailable, USCIS will
attribute any resulting delay to USCIS
for the purpose of eligibility for
employment authorization, 8 CFR
208.9(g)(2); and (3) an asylum officer
will, when not granting asylum, also
consider an applicant’s eligibility for
statutory withholding of removal or
CAT protection within the context of
the Asylum Merits interview. Thus, if
the asylum application is not approved,
the asylum officer will determine
whether the noncitizen is eligible for
statutory withholding or CAT protection
under 8 CFR 208.16(b) or (c). See 8 CFR
208.16(a), 208.17(a). Even if the asylum
officer determines that the applicant has
established eligibility for statutory
withholding of removal or CAT
protection, the asylum officer shall
proceed with referring the asylum
application to the IJ for a hearing
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pursuant to 8 CFR 208.14(c)(1). See 8
CFR 208.16(a).
The Departments acknowledge the
commenter’s concern about appellate
review. As indicated above, this
rulemaking does not eliminate the
application requirement for principal
asylum applicants. Rather, it changes
the form of application for those
individuals who receive a positive
credible fear determination. As is the
case for BIA review of asylum claims
originating in the affirmative asylum
process before USCIS, where an
applicant has filed a Form I–589, the
records created and evidence
considered by asylum officers and IJs
under the new process will go well
beyond the application itself to include
the testimony of the principal and
derivative applicants, the results of
background, identity, and security
checks, and identity documents. They
may also include affidavits and
testimony from witnesses, country of
origin information, civil documents, law
enforcement records, medical records,
court documents, and numerous other
forms of evidence. By the time a case
reaches the BIA, a robust record is
available for the Board’s consideration,
only a small portion of which is the
asylum application itself. Therefore, the
Departments are confident that the
records created before USCIS and IJs
will enable the BIA to conduct a proper
review under the appropriate legal
standards of any cases on appeal arising
out of the new processes created by this
rulemaking.
e. Other Comments on Proposed
Provisions on Applications for Asylum
Comments: A commenter supported
the proposed change to allow the
Asylum Office to rely on biometric
information collected during the
expedited removal process rather than
requiring covered noncitizens to report
to an Application Support Center
(‘‘ASC’’) for new fingerprinting. The
commenter reasoned that elimination of
duplicative biometric collection
prevents asylum seekers from having to
take time off from work or find
childcare, and eliminates the risk for
adverse consequences (e.g., stopping the
asylum EAD clock or failure to appear
at an ASC appointment). The
commenter went on to state that the
Government would also save time and
money by not requiring the capture of
biometric data that DHS has already
collected previously.
Response: The Departments
acknowledge the commenter’s support
for using the biometrics already
captured during the expedited removal
process for the asylum application, for
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the reasons outlined by the commenter.
It is these very concerns expressed by
the commenter that weighed in favor of
allowing DHS to use the biometrics
already captured in the expedited
removal process for purposes of the
asylum application as well. USCIS may
still have to require applicants to attend
an ASC appointment or otherwise
obtain their biometrics in support of the
asylum application following a positive
credible fear determination but is
working to obtain the ability to reuse the
biometrics already captured by other
DHS entities for the asylum application
before USCIS.
Comments: One commenter believed
that, because the asylum applicant has
the right to seek review of an asylum
officer’s decision not to grant asylum
before an IJ, all denied claims will end
up in our judicial system. Moreover, the
commenter stated, because the rule
seeks to reduce the immigration court
backlog, adjudicators will be instructed
to approve or grant asylum claims of
individuals arriving at the border.
Response: The Departments disagree
that the rule’s aim to reduce the
immigration court backlog sends signals
to adjudicators that they must grant
non-meritorious cases. Each
adjudication is based on specific,
individualized facts, and, in the case of
asylum, the grant of asylum status
further requires not only a finding of
substantive eligibility, but also a
favorable exercise of discretion. If an
asylum officer does not grant asylum,
the noncitizen will be placed into
streamlined section 240 removal
proceedings. After being placed in
streamlined removal proceedings and
having the asylum claim reviewed de
novo by the IJ, if the IJ denies asylum,
the noncitizen may (as now in ordinary
section 240 proceedings) appeal the IJ’s
decision to the BIA. And, as with BIA
decisions in ordinary section 240
proceedings, the noncitizen may then
seek judicial review before the
appropriate U.S. Court of Appeals. See
INA 242(a), 8 U.S.C. 1252(a). Judicial
review serves as an important
mechanism to ensure fairness and due
process. Further, this rule leaves in
place the statutory process by which the
cases of noncitizens determined to have
no credible fear of persecution or torture
are resolved quickly, and creates a
framework that also allows clearly
grantable asylum cases to also be
resolved quickly. Nevertheless, nothing
in the rule suggests or requires that
complex cases will be rushed or
essential parts of the analysis or
required vetting and security checks
will be ignored, as there are no changes
to substantive asylum eligibility. The
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Departments recognize that some cases
may take longer to complete due to, for
instance, particularly complex issues.
5. Adjudication of Applications for
Asylum for Noncitizens With Credible
Fear
a. DHS Interpretation of Statute in
Creating a New Adjudication Process
Comments: A commenter expressed
concern with the NPRM’s proposal to
authorize asylum officers to issue
removal orders, including in cases
where an asylum-seeker fails to appear
for a merits hearing before USCIS. The
commenter contends that this new
authority would put asylum officers in
an enforcement-oriented or adversarial
role, which could undermine the
nonadversarial proceeding. The
commenter asked that ICE or IJs instead
be tasked with issuing removal orders.
Furthermore, the commenter stated that
an applicant who may have missed a
hearing inadvertently should have an
opportunity to remedy the situation
before a removal order is issued. The
commenter urged the Government to
consider nonadversarial first-instance
asylum hearings in a context that
corresponds with international
standards on detention and affords
asylum-seekers sufficient time and
opportunity to recover from trauma,
gather information about their cases,
and have access to legal advice,
assistance, and representation.
Response: The Departments have
carefully considered the comments
received in response to the NPRM
regarding an asylum officer’s authority
to issue a removal order. As discussed
elsewhere, the Departments have
decided not to adopt that proposal.
Instead, under the IFR, an asylum
officer will issue an NTA when not
granting an application for asylum and
refer the case for streamlined section
240 proceedings before an IJ. Given this
choice of process in the IFR, the
Departments find it is unnecessary to
further respond to the comments
regarding an asylum officer’s authority
to issue a removal order, as the
Departments believe the concerns of
those comments are now addressed.
b. Review of Asylum Claim by an
Asylum Officer, Rather Than by an
Immigration Judge, in Section 240
Removal Proceedings
Comments: Several commenters
expressed support for the proposal to
have asylum officers adjudicate asylum
applications in the first instance, noting
that asylum officers are trained in
assessing country conditions,
conducting interviews, and handling
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sensitive information. One commenter
stated that having USCIS adjudicate
asylum applications would allow for a
fast yet equitable process. One
commenter noted that the proposed
process would encourage asylum
seekers to speak openly about their
fears, and stated that asylum officers are
better equipped than IJs to adjudicate
protection-related claims. Another
commenter asked DHS to clarify what
types of trainings will be offered to
asylum officers and suggested such
training should emphasize cultural
competence.
Response: The Departments agree that
a nonadversarial process is well-suited
to adjudicating claims for asylum and
related protection. The Departments
concur with commenters who make
specific reference to the trainings that
all asylum officers undergo before they
may work with vulnerable populations.
The Departments note that asylum
officers are trained in asylum and
refugee law, interviewing techniques,
country of origin information, decisionmaking, interviewing survivors of
torture, fraud identification and
evaluation techniques, and addressing
national security concerns. See e.g.,
USCIS, Asylum Division Training
Programs, https://www.uscis.gov/
humanitarian/refugees-and-asylum/
asylum/asylum-division-trainingprograms. Cultural competence is an
integral part of many of these trainings,
and the Departments acknowledge the
commenter’s suggestion that trainings
should emphasize this skill.
Comments: Many commenters
opposed the proposal to have asylum
officers adjudicate asylum applications
in the first instance, generally stating
that only IJs should grant asylum. Other
commenters argued that only IJs have
the requisite training or that claims
should not be adjudicated by
‘‘bureaucrats.’’ One commenter
remarked that the proposal to have
asylum officers adjudicate asylum
claims would introduce the potential of
‘‘political abuse,’’ and some commenters
argued that asylum claim adjudication
must be conducted by IJs to prevent
undue bias or corruption. A few form
letter campaigns expressed concern that
the proposal would make asylum
officers ‘‘the most powerful immigration
officials in the country.’’ One
commenter expressed concern that the
proposal would circumvent the careful
analysis asylum applications demand
and recommended increasing funding
and hiring additional IJs to process the
immigration backlog. Another
commenter opposed allowing asylum
officers to adjudicate asylum claims and
suggested Federal judges should be
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placed in courts near the border to
handle asylum claims expediently. A
commenter asked how DHS will ensure
that only qualified asylum officers will
adjudicate asylum claims and remarked
that such qualifications are part of the
legal definition of an IJ.
Response: The Departments strongly
disagree with statements asserting or
suggesting that asylum officers, who are
career Government employees selected
based on merit as explained earlier in
Section IV.B.2.a of this preamble, are
biased or otherwise politically
motivated. As noted above in Section
III.C of this preamble, USCIS asylum
officers already must undergo ‘‘special
training in international human rights
law, nonadversarial interview
techniques, and other relevant national
and international refugee laws and
principles.’’ 8 CFR 208.1(b). USCIS
asylum officers already adjudicate
asylum applications as part of their
duties, and this fact will not be affected
by the rule. Also, as noted above in
Section IV.B.2.a of this preamble, no
individual may be granted asylum or
withholding of removal until certain
vetting and identity checks have been
conducted. INA 208(d)(5)(A)(i), 8 U.S.C.
1158(d)(5)(A)(i). Additionally, while the
Departments believe that commenters’
statements are grounded in
misinformation, the Departments also
note that Government officials are
entitled to the presumption of official
regularity in the manner in which they
conduct their duties. United States v.
Chem. Found., Inc., 272 U.S. 1, 14–15
(1926). Commenters failed to provide
any examples of what they incorrectly
posit to be concerns with bureaucratic
‘‘power[ ]’’ or bias on part of asylum
officers. The Departments believe that
such concerns stem from a fundamental
misunderstanding of the United States’
immigration system as well as the
respective roles of IJs and asylum
officers. Additionally, the comments
lack any meaningful explanation or
evidentiary basis; such baseless
accusations against public officials are
‘‘easy to allege and hard to disprove.’’
Crawford-El v. Britton, 523 U.S. 574,
585 (1998) (quotation marks omitted);
see also Nat’l Archives & Records
Admin. v. Favish, 541 U.S. 157, 174
(2004) (requiring the production of
evidence rather than ‘‘bare suspicion’’
that ‘‘responsible officials acted
negligently or otherwise improperly in
the performance of their duties’’).
Comments: Referencing the NPRM’s
preamble, several commenters stated
that the prior Administration’s border
strategy has led to a significant increase
in the number of backlogged asylum
cases. These commenters stated that
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authorizing border cases to be handled
not only by immigration courts but also
by the USCIS Asylum Division will
increase efficiency by eliminating
redundancy. These commenters stated
that permitting asylum officers to
maintain jurisdiction throughout the life
of a case capitalizes on the work and
time already invested in each case
during credible fear screenings, which
will alleviate pressure on the
immigration courts and eventually lead
to a much more efficient immigration
system. Other commenters likewise
supported the proposed rule and stated
that, while the number of IJs has
doubled, the number of pending cases
has tripled and outstripped the hiring of
IJs. These commenters also stated that
the immigration procedures
contemplated in IIRIRA are inadequate
for the number of applicants now
seeking asylum in the United States.
Two commenters stated that IJs can
adjudicate asylum cases efficiently but
that they must be provided more
resources.
A commenter indicated that there is
no evidence that asylum officer
interviews are more efficient than IJ
adjudications. The commenter added
that backlogs may in fact expand as a
result of reallocating funding to cases
under the proposed system, stating that
the asylum offices do not have room for
the proposed additional hires and that
asylum officers may leave their jobs.
The commenter stated that asylum
officers typically conduct only two
interviews a day while IJs conduct
multiple hearings and that the latter are
more efficient because IJs and counsel
are more competent in immigration law.
A commenter agreed that the proposed
rule would extend the backlog by
extending the appeals process for
asylum seekers. Another commenter
stated that the proposed rule could not
seriously address backlogs because
credible fear determinations and asylum
applications only make up a small
portion of immigration court dockets. A
commenter also expressed doubt that
the new process would alleviate
backlogs because of startup costs for the
new process.
However, two commenters stated that,
under the current system, outcomes of
an asylum case can depend almost as
much on luck as on the merits of an
asylum application. The commenters
cited a source indicating that approval
rates by individual IJs can vary from 0.9
percent of all cases to 96.7 percent. One
of the commenters stated that such
disparity causes unnecessary stress for
individuals and also indicates the
absence of clear, uniform standards
used by IJs to adjudicate cases. The
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commenter stated that, conversely, the
Asylum Division uses rigorous quality
assurance processes and requires
supervisory review of all cases and
similar statutory definitions and policy
guidance used by refugee officers in
USCIS will also be applied to the work
of asylum officers. The commenter
concluded by stating that, under the
new rule, the unpredictability and
variance that characterize the current
immigration court system will be
replaced by greater consistency and
clarity in the decision-making process
across all asylum offices.
Other commenters asserted that the
rule would not create a more
expeditious process and that limiting
the rights of asylum seekers in
expedited removal would better
streamline immigration. Commenters
also stated that it would be problematic
for asylum seekers to have the right to
an attorney but not to grant ‘‘the
American people’’ the ‘‘right to be
represented by an ICE attorney.’’
Response: The Departments agree that
allowing USCIS to adjudicate these
cases will alleviate pressure on the
immigration courts and eventually lead
to a much more efficient immigration
system. Further, the Departments
understand comments relating to
reallocation of resources affecting the
backlog of cases, the hiring, potential
loss, and retention of asylum officers,
and concerns for delay as the USCIS
Asylum Division takes on this new
caseload. It is on this basis that the
Departments are phasing in
implementation of this rule. The
graduated steps involved will allow for
the Departments to address concerns
that arise and learn how
implementation can be better
operationalized. In comparing
adjudications between USCIS and IJs,
the specialized role of asylum officers
coupled with ownership of a case from
screening to adjudication allows for
efficiency gains. Further, the USCIS
Asylum Division has steps in place to
ensure consistency in adjudications,
and safeguards will continue as USCIS
adjudicates applications pursuant to
this rule. The Departments disagree that
an adversarial process is required to
adjudicate the merits of an asylum
application. However, as noted above in
Section III.D of this preamble, this IFR
will provide for a streamlined section
240 removal proceeding in the event
that an asylum officer does not grant
asylum. The United States Government
will be represented by ICE in those
adversarial proceedings in accordance
with 6 U.S.C. 252(c).
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c. Requirements for USCIS Asylum
Merits Adjudication
Comments: A commenter expressed
concern that the procedural safeguards
for hearings before asylum officers will
fall short of due process requirements.
The commenter suggested that all
procedural safeguards available in
immigration court proceedings be
included in hearings before an asylum
officer to ensure fairness. Meanwhile,
another commenter stated that the
provisions of 8 CFR 208.9(d) alone
would not violate the due process rights
of noncitizens, citing the right to a de
novo hearing in immigration courts
under proposed § 1003.48(e)(1). The
commenter cautioned, however, that the
combination of 8 CFR 208.9(d) and
1003.48(e)(1) will deny noncitizens the
chance to explain the circumstances of
their persecution or well-founded fear of
persecution in a complete and orderly
way, and that the rule is inconsistent
with 8 U.S.C. 1229(a)(4)(b) and due
process guaranteed by the Fifth
Amendment.
Another commenter recommended
asylum officers be required to introduce
relevant country-conditions evidence—
including evidence on gender-based
violence, gang violence, and any
recognized efforts to combat the
aforementioned—when the applicant
has not presented such evidence during
the hearing before an asylum officer.
Similarly, another commenter explained
that having more complete knowledge
of a country’s conditions would allow
asylum officers to properly elicit full
testimony from asylum seekers. One
commenter suggested additional
procedural safeguards to promote ‘‘a
less traumatic procedure,’’ such as
trauma survivors being given an
opportunity to request interviewers of a
specific gender.
Response: The Departments
acknowledge the concerns of the
commenters regarding the procedural
safeguards in Asylum Merits interviews
before USCIS asylum officers and
disagree that such safeguards will fall
short of due process requirements. As
explained earlier in this IFR, the
Departments are making several
modifications to the process proposed
in the NPRM in response to comments,
including referring noncitizens who are
not granted asylum by an asylum officer
to an IJ for streamlined section 240
removal proceedings. DHS will provide
ample procedural safeguards to
noncitizens throughout the Asylum
Merits process, including in the Asylum
Merits interview itself, such as the
following: (1) The applicant may have
counsel or a representative present, may
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present witnesses, and may submit
affidavits of witnesses and other
evidence, 8 CFR 208.9(b); (2) the
applicant or applicant’s representative
will have an opportunity to make a
statement or comment on the evidence
presented, and the representative will
also have the opportunity to ask followup questions, 8 CFR 208.9(d)(1); (3) a
verbatim transcript of the interview will
be included in any referral package to
the IJ, 8 CFR 208.9(f)(2); (4) an asylum
officer will arrange for the assistance of
an interpreter if the applicant is unable
to proceed effectively in English, and if
an interpreter is unavailable, USCIS will
attribute any resulting delay to USCIS
for the purposes of eligibility for
employment authorization, 8 CFR
208.9(g)(2); and (5) the failure of a
noncitizen to appear for an interview
may result in the referral of the
noncitizen to ordinary section 240
removal proceedings before an IJ, unless
USCIS, in its own discretion, excuses
the failure to appear, see 8 CFR
208.10(b)(1). Furthermore, as explained
earlier, if an asylum officer does not
grant asylum to an applicant, the
asylum officer will determine whether
the applicant is eligible for statutory
withholding and CAT protection before
referring the case to streamlined section
240 removal proceedings before an IJ.
The Departments believe that these
procedures will give applicants a fair
opportunity to present their claims, as
well as have their claims heard and
properly decided in an efficient manner.
As for requiring asylum officers to
introduce country conditions evidence,
the Departments decline to impose such
a requirement. Asylum officers receive
extensive country conditions training,
have ready access to country conditions
experts, and regularly consider country
conditions when making decisions as a
matter of course. In addition, current
affirmative asylum interview procedures
allow for applicants to request
interviewers of a specific gender. These
same procedures will apply in the
context of Asylum Merits interviews.
Comments: Several commenters
requested clarifications and
modifications to procedures for merits
hearings before asylum officers,
including opportunities to present
details and evidence pertaining to the
case. A commenter explained that
communication plays a crucial role in
the interview process and asserted that
the rule does not provide sufficient
opportunity for legal advocates to call
witnesses, present additional
information, or prompt their clients to
speak on their own behalf. Some
commenters argued that the NPRM
empowers asylum officers to present
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evidence, but does not allow applicants
or their counsels to frame and present
their cases, or to examine or challenge
any evidence introduced. Likewise, one
commenter remarked that the structure
of the hearing before asylum officers
reverses the ‘‘normal order of
adjudication,’’ thus giving minimal
opportunity to asylum seekers, who
have the ‘‘burden of proof,’’ to make
statements and be directly examined.
Several commenters asserted that
asylum officers provide limited to no
opportunity for counsel to crossexamine applicants and present witness
testimonies during interviews, which
causes stress to applicants and limits
the protections otherwise provided to
them in section 240 removal
proceedings. A few commenters
asserted that limiting counsel’s ability to
make a statement or ask questions
would jeopardize due process rights and
reduce counsel’s ability to properly
advocate for the asylum seeker. Several
commenters stated that more robust and
meaningful participation by counsel
during the hearing would help address
the due process concerns arising from
the revised provisions in 8 CFR 208.9,
while reducing confusion or the need
for appeals. Some commenters proposed
that the rule include at least one
continuance for the purpose of seeking
counsel to advance equity within the
adjudication process. Several
commenters asserted that without
access to counsel, asylum seekers would
lack meaningful representation
necessary for a successful hearing.
Some commenters recommended that
8 CFR 208.9 be revised to allow
representatives to make an opening
statement, elicit testimony from the
applicant during the hearing, and
provide a closing statement. Similarly,
from an efficiency and due process
standpoint, a commenter recommended
that the asylum seeker’s counsel—rather
than an asylum officer with limited time
to review ‘‘the often voluminous case
file’’—ask questions during the hearing.
The commenter suggested that 8 CFR
208.9(d) be further amended to provide
that the representative will also have the
opportunity to ask follow-up questions
during the interview or hearing. One
commenter urged USCIS to consider
consulting with lawyers who appear in
immigration courts to receive feedback
on the effects of the rule.
Response: The Departments
acknowledge the concerns of the
commenters regarding procedures for
USCIS Asylum Merits adjudication,
including the role of counsel in Asylum
Merits interviews. As provided in 8 CFR
208.9(b), the purpose of the Asylum
Merits interview will be to elicit all
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relevant and useful information bearing
on the applicant’s eligibility for asylum.
USCIS asylum officers have experience
with (and receive extensive training on)
eliciting testimony from applicants and
witnesses, engaging with counsel, and
providing applicants the opportunity to
present, in their own words,
information bearing on eligibility for
asylum. Asylum officers also are trained
to give applicants the opportunity to
provide additional information that may
not already be in the record so that the
asylum officer has a complete
understanding of the events that form
the basis for the application.
Noncitizens who are placed in the
Asylum Merits process will have
multiple opportunities to provide
information relevant to their claims
before USCIS asylum officers in
nonadversarial settings, as well as the
opportunity for an IJ to review or
consider their claims. If an IJ ultimately
denies protection to an applicant, BIA
review will be available.
Within the context of Asylum Merits
interviews, noncitizens retain the ability
to access and secure counsel. See 8 CFR
208.9(b). As in the affirmative asylum
interview context, USCIS will make
every reasonable effort to ensure
applicants are scheduled for their
hearing in a time and place that ensures
their representatives of record can
attend and meaningfully participate in
their interview. Applicants may request
rescheduling of Asylum Merits
interviews by following the instructions
set forth on the USCIS website and in
appointment notices. At the Asylum
Merits interview, the applicant may
present witnesses and may submit
affidavits and other evidence. See id. At
the completion of the Asylum Merits
interview, the applicant or the
applicant’s representative will have an
opportunity to make a statement or
comment on the evidence presented.
The representative will also have the
opportunity to ask follow-up questions.
See 8 CFR 208.9(d)(1). The Departments
recognize the importance of the role of
counsel in advising and assisting
noncitizens with presenting their claims
and believe that this rule provides
counsel the opportunity to do so within
the context of Asylum Merits
interviews. As a result, the Departments
decline to make further changes in
response to these comments. As for the
suggestion to consult with legal
practitioners appearing before the
immigrant courts, the Departments note
that the NPRM provided the
opportunity for any and all members of
the public, including legal practitioners,
to offer feedback on the rule, and in this
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IFR the Departments are including
another request for public comments.
Comments: Citing the impact of legal
representation on asylum case
outcomes, a commenter indicated that
the NPRM increases access to legal
representation. The commenter noted
that the NPRM allows representatives
with DOJ EOIR accreditation, including
individuals with partial accreditation, to
represent clients seeking statutory
withholding of removal and CAT
protection before USCIS. The
commenter noted that by allowing
statutory withholding of removal and
CAT protection claims to proceed before
USCIS, applicants would have greater
access to free or low-cost legal
representation from DOJ-accredited
representatives. Another commenter
recommended that the rule permit
USCIS to appoint counsel in cases
where counsel is needed, allow asylum
seekers and their counsel to record
objections and request the record reflect
nonverbal activity, and create a
procedure to report misconduct
following hearings before asylum
officers in the event that asylum officers
mishandle such hearings.
Response: The Departments
acknowledge the feedback on the impact
that the rule may have on access to legal
representation. Given the Departments’
decision to have asylum officers issue
final decisions solely as to the asylum
claims, rather than also issuing final
decisions regarding statutory
withholding and CAT protection claims
as proposed in the NPRM or otherwise
issuing removal orders, the commenter’s
note about individuals with partial
accreditation is no longer relevant.
While the Departments appreciate
comments suggesting that USCIS
appoint counsel to noncitizens in
certain instances, those comments are
outside the purview of this rulemaking.
The Departments note that asylum
seekers and counsel will have the
opportunity to make a statement or
comment on the evidence presented at
Asylum Merits interviews, which may
include raising objections and
requesting that the record reflect
nonverbal activity. As for reporting
asylum officer misconduct, USCIS will
follow existing agency-wide procedures
on receiving and responding to
complaints and misconduct, which are
available on the USCIS website.
Comments: Several commenters
expressed support for the provision in
the NPRM requiring asylum officers to
record and transcribe hearings. A
commenter noted that the provision
allows noncitizens to receive a
recording and transcript of their hearing
before an asylum officer, which they
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believe would place the noncitizen on
equal footing with the DHS attorney.
Some commenters added that the
recordings and transcriptions of
hearings would allow for accurate
documentation of the proceedings and
align with transparency and
accessibility priorities. One commenter
requested that DHS also clarify how
asylum seekers will be able to access
their hearing transcripts because it
would allow noncitizens to determine
whether they require help from counsel.
The commenter also asked that the
Departments address the possibility of
widening the scope of the provision so
that asylum seekers may access
transcripts from IJ proceedings. Another
commenter expressed concern about the
inability of records to capture nonverbal cues and reactions during the
hearing. This commenter suggested that
a human communications specialist be
consulted to determine how to
incorporate non-verbal cues into hearing
records.
One commenter noted that the
requirement to record or transcribe the
hearing may not be feasible and argued
that this requirement would pose
challenges for IJs conducting de novo
reviews of hearings before asylum
officers. Another commenter similarly
urged USCIS to clarify how the review
of hearing records would be conducted
and the impact on the due process rights
of asylum seekers. The commenter
stated that full recordings of hearings
would be hours long and claimed that
generating transcripts would lengthen
the time needed to issue decisions.
Considering these issues, the
commenter recommended that USCIS
identify who would be reviewing the
records and determine whether asylum
officers would take notes in conjunction
with the hearing recordings.
Another commenter suggested that all
interviews, regardless of their nature, be
recorded. They specified that all
questions and answers be documented
in the language they were initially
spoken in and later interpreted. The
commenter also recommended that the
Departments provide adjudication
documents in the asylum seeker’s
language, and that, in the case of
literacy limitations, an interpreter read
the records to an asylum seeker. Finally,
in cases where the asylum seeker is
detained, the commenter recommended
the agencies ensure privacy to review
the records.
Response: The Departments
acknowledge the support for recording
and transcribing Asylum Merits
interviews. The Asylum Merits
interview will be recorded so that a
transcript of the interview can be
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created. A verbatim transcript of the
interview will be included in the
referral package to the IJ. See 8 CFR
208.9(f)(2). A copy of that transcript will
also be provided to the noncitizen. In
addition, asylum officers will take notes
during Asylum Merits interviews. As for
nonverbal cues or reactions, asylum
officers may make note of such matters
as appropriate.76 The Departments do
not anticipate that these procedures will
lead to significant delays in the
adjudication of the noncitizen’s asylum
claim before USCIS. The Departments
recognize one commenter’s concern that
there may be logistical challenges
associated with implementing recording
or transcription of interviews before
asylum officers. However, the
Departments are taking a phased
approach to implementation in part to
address this concern. The rule does
make changes to long-standing
practices, and as implementation
progresses, the Departments will work
to ameliorate any challenges that arise
as the process is put into practice. Also,
allowing for robust independent review
of asylum officers’ decisions to not grant
asylum is an important feature that
ensures administrative fairness over and
above due process minimums.
In addition, USCIS will arrange for an
interpreter when an applicant is unable
to proceed with an Asylum Merits
interview in English, and if an
interpreter is unavailable, USCIS will
attribute any resulting delay to USCIS
for the purposes of eligibility for
employment authorization. See 8 CFR
208.9(g)(2). At the Asylum Merits
interview, the asylum officer will
provide information about the hearing
to the applicant, which will be
interpreted for the applicant. While the
Departments acknowledge the
recommendation that questions and
answers be documented in the language
in which they were initially spoken and
that adjudication documents be
provided in the language spoken by the
applicant, the Departments note that
Asylum Merits interviews will be
recorded and transcribed, and that
notice of decisions will be provided to
applicants in writing. The Departments
believe that these various procedural
safeguards sufficiently allow for
applicants to access their Asylum Merits
interview records and remain informed
of the reasons for any decisions not to
grant asylum. Thus, further
76 Asylum officers conducting Asylum Merits
interviews will continue to follow the guidance on
note-taking they receive during their basic training.
See USCIS, RAIO Combined Training Program:
Note-Taking Training Module (Dec. 20, 2019),
https://www.uscis.gov/sites/default/files/document/
foia/Interviewing_-_Note_Taking_LP_RAIO.pdf.
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documentation or explanation
requirements are not warranted in this
IFR.
The comments recommending that
DHS arrange a private setting for
detained individuals to review their
records fall outside of the scope of this
rulemaking, and thus are not being
addressed. The Departments believe that
receipt of the transcript from the asylum
officer’s Asylum Merits interview will
benefit the IJ and the noncitizen by
providing a clear, precise, and accurate
record of the basis for the adjudication.
The Departments acknowledge the
suggestion related to widening the scope
of availability of transcripts from
proceedings before IJs; however, this
suggestion is beyond the scope of this
IFR. Upon appeal of a decision by an IJ
to the BIA, the hearing, where
appropriate, is transcribed by the BIA
and sent to both parties. See EOIR Policy
Manual, Part II, Ch. 4.10(b), Part III, Ch.
4.2(f). Further, immigration hearings
before the IJ are recorded. See 8 CFR
1240.9. If either party would like a
recording of the proceedings before the
IJ, an audio recording is available by
making arrangements with the
immigration court staff. See EOIR Policy
Manual, Part II, Ch. 4.10(a).
Comments: Several commenters
expressed support for the provision in
the NPRM at 8 CFR 208.9(g) that would
require USCIS to provide an interpreter
for the hearing before an asylum officer,
reasoning that such a requirement
would promote fairness and accuracy in
adjudication. Conversely, one
commenter expressed concern that the
provision in the NPRM, paired with
other provisions in the NPRM, would
‘‘disproportionately harm vulnerable,
minority populations’’ in the event that
an Asylum Office cannot find an
interpreter. Some commenters asserted
that language barriers would result in
mistakes in the record and complicate
the appeal process. To address language
access concerns, two commenters
suggested this provision be extended to
all asylum officer interviews, with some
changes. The commenters suggested the
agency provide specifications of the
interpreter’s qualifications and make
Government-provided interpretation
non-obligatory, asserting that these
modifications would enhance asylum
applicants’ access to competent
interpretation during the hearing.
One commenter, in support of the use
of interpreters during hearings before
asylum officers, urged USCIS to
implement additional safeguards to
combat the systemic problems
associated with language access. The
commenter suggested that the
safeguards include a mandate for
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interpretation throughout the full
hearing in the asylum seeker’s native
language and incorporate specifications
on the use of telephonic and video
interpretations, and suggested that
telephonic and video interpretation be
used in cases where no qualified inperson interpreter is available. A
commenter also suggested that the rule
require everything said in any language
during the interview process be part of
the record to curtail the possibility of
error and omission. Lastly, the
commenter recommended a routine
screening of interpreters to ensure
consistency and accuracy in hearing
records.
Response: As explained earlier,
USCIS will provide an interpreter for
Asylum Merits interviews when an
applicant is unable to proceed with the
hearing in English, and if an interpreter
is unavailable, USCIS will attribute any
resulting delay to USCIS for the
purposes of eligibility for employment
authorization. See 8 CFR 208.9(g)(2).
The Departments acknowledge the
commenters’ support for the provision
and disagree with the commenters who
assert that this requirement will
disproportionately harm vulnerable,
minority populations. USCIS has
existing contracts with telephonic
interpreters to provide interpretation for
credible fear screening and affirmative
asylum interviews, and thus has
extensive experience providing contract
interpreter services.
Per contractual requirements, the
USCIS contract interpreters are carefully
vetted and tested. They must pass
rigorous background checks as well as
demonstrate fluency in reading and
speaking English as well as the language
of interpretation. The USCIS contractor
must test and certify the proficiency of
each interpreter as part of their quality
control plan. The USCIS contractor also
must provide interpreters capable of
accurately interpreting the intended
meaning of statements made by the
asylum officer, applicant,
representative, and witnesses during
interviews or hearings. The USCIS
contractor will provide interpreters who
are fluent in reading and speaking
English and one or more other
languages. The one exception to the
English fluency requirement involves
the use of relay interpreters in limited
circumstances at USCIS’s discretion. A
relay interpreter is used when an
interpreter does not speak both English
and the language the applicant speaks,
such as a rare language or dialect.
In addition, USCIS contractorprovided telephonic interpreters must
be at least 18 years of age and pass a
security and background investigation
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by the USCIS Office of Security and
Integrity. They cannot be the applicant’s
attorney or representative of record; a
witness testifying on the applicant’s
behalf; a representative or employee of
the applicant’s country of nationality or,
if stateless, the applicant’s country of
last habitual residence; a person who
prepares an Application for Asylum and
for Withholding of Removal or Refugee/
Asylee Petition for a fee, or who works
for such a preparer or attorney; or a
person with a close relationship to the
applicant, as deemed by the Asylum
Office, such as a family member. All
contract interpreters must be located
within the United States and its
territories (i.e., Puerto Rico, Guam, etc.).
Additionally, under the International
Religious Freedom Act of 1998, USCIS
must ensure that ‘‘persons with
potential biases against individuals on
the grounds of religion, race,
nationality, membership in a particular
social group, or political opinion . . .
shall not in any manner be used to
interpret conversations between aliens
and inspection or asylum officers.’’ 22
U.S.C. 6473(a). In light of these
requirements, the Departments are
confident that USCIS will be able to
ensure that communication among all
parties is clear and accurate.
The Departments acknowledge that
current interpreter contracts cannot
absorb the expected increase in the need
for interpretation services. DHS
anticipates that it will need to both
increase funding on existing contracts
and procure new contracts for
interpretation services. As a result of
this IFR, the need for interpretation
services will increase as the number of
Asylum Merits interviews USCIS
performs rises, which is further
discussed in Section VI of this
preamble. DHS declines to make
modifications in this rule related to the
commenters’ recommendation to extend
the USCIS-provided interpreter
provision to all asylum interviews
before USCIS as changes to USCIS’s
affirmative asylum process are outside
the scope of this rulemaking.77
77 On September 17, 2021, DHS published a
temporary final rule that extends and modifies the
requirement for certain asylum applicants to use a
USCIS-provided telephonic contract interpreter to
keep the USCIS workforce and applicants safe
during the COVID–19 public health emergency. See
Asylum Interview Interpreter Requirement
Modification Due to COVID–19, 86 FR 51781 (Sept.
17, 2021). The rule is effective until March 16,
2023. See 87 FR 14757 (Mar. 16, 2022) (extending
temporary final rule); see also 85 FR 59655 (Sept.
23, 2020) (original temporary final rule); 86 FR
15072 (Mar. 22, 2021) (first extension of temporary
final rule).
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d. Failure To Appear
Comments: Various commenters
opposed the proposed revisions that
would allow an asylum officer to issue
an order of removal when a noncitizen
fails to appear for a scheduled hearing.
Some of these commenters asserted that
there are many reasons an asylum
seeker might miss an interview that are
not reasonably attributable to the
applicant. Other commenters opposed
this aspect of the proposal, arguing that
the proposed rule offers fewer
protections for asylum seekers than
provided by the regulations governing
in-absentia removal hearings before an
IJ. Commenters argued that, unlike in
section 240 removal proceedings, the
proposed regulation does not
contemplate safeguards to ensure that
the asylum officer has provided the
required evidence of inadmissibility and
correctly issued the removal order.
Because DHS is required to establish
‘‘by clear, unequivocal, and convincing
evidence’’ that the noncitizen is
removable and received written notice
of the time and place of proceedings
before a judge will issue an in-absentia
removal order, these commenters
asserted that the proposed rule requires
the asylum officer to act as both the
adjudicator and the prosecutor when it
comes to issuing the removal order.
These commenters opposed this aspect
of the proposal because the proposed
regulations do not include a process
through which the noncitizen would
seek rescission and reopening after
receiving an in-absentia removal order
from an asylum officer. Finally, other
commenters opposed this part of the
proposal because it does not include a
provision that requires heightened
notice of asylum hearings for children
under 14, as exists in the regulations
governing section 240 removal
proceedings. Some commenters
expressed concern about this aspect of
the proposal because it would permit an
asylum officer to issue a removal order
without previously issuing a notice of
failure to appear, which one of these
commenters stated would provide an
important safeguard preventing the
issuance of a removal order against an
individual who did not attend their
hearing through no fault of their own.
Commenters asserted that the agencies
did not provide any rationale for the
decision not to provide notice to asylum
seekers of their failure to appear and
that this lack of notice of failure to
appear offends due process.
Also expressing due process concerns,
a commenter suggested that the final
rule must establish clear and fair notice
procedures before any removal order is
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allowed. For example, the commenter
expressed concern that the proposed
rule does not have a requirement that
the asylum officer issue a notice of
further consideration hearing that
would be comparable to the procedure
under current 8 CFR 208.30(f), under
which the officer issues an NTA for full
consideration of the asylum and
withholding of removal claims in
section 240 removal proceedings.
Asserting that due process requires
notice and an opportunity to be heard,
commenters argued that the proposed
regulation would violate due process by
not providing an effective remedy for
lack of notice and providing only a
discretionary opportunity to be heard.
While acknowledging that the proposed
rule would provide that USCIS may
excuse the failure to appear if the
applicant demonstrated ‘‘exceptional
circumstances,’’ the commenter argued
that it is unclear whether this language
would permit USCIS to rescind a
removal order that had already been
issued. Moreover, the commenter stated
that this language keeps the decision to
excuse the failure to appear entirely
discretionary, unlike the statutory right
to petition the immigration court to
reopen in section 240 proceedings. Nor
would this language, according to the
commenter, provide applicants with a
right to petition for reopening their
cases due to lack of notice, a right they
would have in section 240 removal
proceedings.
One commenter argued that granting
asylum officers authority to issue inabsentia removal orders as proposed
would violate asylum seekers’ due
process rights, citing uncertainties
surrounding reasonable access to legal
representation in the proposed rule and
the extreme consequences of an
inabsentia removal order. Citing due
process concerns, another commenter
objected to this aspect of the proposed
rule because it would not provide a
mechanism for requesting
postponement, aside from the
discretionary ‘‘brief extension of time’’
or for requesting a change of venue. A
commenter expressed concern that the
proposed rule provides authority to
issue a removal order for failing to
appear for biometrics appointments
without incorporating the limited
safeguards required for in-absentia
orders of removal by IJs.
Commenters recommended that the
final rule include, either directly or by
reference, the same or higher
protections as an individual would
receive in immigration court
proceedings. A commenter suggested
that, if the final rule adopts the NPRM’s
proposal, it should include provisions
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that allow applicants to ask USCIS to
rescind the removal order and reopen
their cases where the applicant can
show a due process violation or
exceptional circumstances that excuse a
failure to appear. Instead of allowing
asylum officers to issue in-absentia
removal orders, a commenter urged the
Departments to require that cases be
referred to immigration court when
asylum seekers fail to appear for their
interviews. Another commenter asserted
that authorizing asylum officers to issue
in-absentia removal orders would have
a disproportionate and unfair impact on
applicants with disabilities as well as
asylum seekers who speak languages of
lesser diffusion, who are less likely to
receive notice of such appointments in
a language they can understand.
Response: The Departments have
considered the comments related to the
possibility of asylum officers issuing inabsentia removal orders as outlined in
the NPRM and, after careful
consideration, have opted not to include
that proposal in this IFR. Under the
present rule as revised, asylum officers
will not be issuing removal orders
following the Asylum Merits interview.
Consistent with the Departments’
determination that final orders of
removal for individuals whose asylum
claims are being adjudicated under the
framework of this IFR will only be
issued by IJs, asylum officers also will
not issue removal orders if an applicant
fails to comply with biometrics
requirements or fails to appear for the
hearing. Instead, failure to appear for
hearings or to comply with biometrics
requirements will result in applicants
not having their asylum claims
considered through the process
established by this IFR. In those
circumstances, noncitizens will be
issued an NTA and placed in ordinary
section 240 proceedings before EOIR. In
those ordinary section 240 proceedings,
noncitizens would not be considered to
have asylum applications pending but
would have the opportunity to file a
Form I–589.
e. Process for USCIS To Deny an
Application for Asylum or Other
Protection and Issue a Removal Order
Comments: A commenter provided a
lengthy background analysis of the CAT,
its implementation in the FARRA, and
the authority of asylum officers to order
the removal of asylum seekers. The
commenter stated that the proposed
rulemaking correctly does not amend
the provision in 8 CFR 1208.16(f) for
statutory withholding and CAT
protection. Furthermore, the commenter
asserted that the only statutory authority
asylum officers have to order that
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asylum seekers be removed is expedited
removal under section 235(b)(1)(B)(iii)(I)
of the INA. The commenter argued that
asylum officers therefore lack authority
to issue an order of removal after not
granting a noncitizen’s asylum claim
and therefore also lack authority to
adjudicate claims for statutory
withholding of removal or CAT
protection. Citing text from the NPRM’s
preamble, the commenter reasoned that
the Departments incorrectly relied on a
‘‘vestigial’’ provision of INA regarding
‘‘orders of deportation’’ that were
replaced by IIRIRA ‘‘orders of removal.’’
The commenter also argued that the
Departments cannot rely on Mitondo v.
Mukasey, 523 F.3d 784 (7th Cir. 2008),
reasoning that that case cannot be
applied in the context of expedited
removals because it turned on vague
statutory language related to the Visa
Waiver Program whereas, the
commenter argued, the statutory
language on asylum officers’ powers of
removal in section 235(b)(1) is more
explicit.
Response: The Departments have
carefully considered the comments
received in response to the NPRM
regarding an asylum officer’s authority
to issue a removal order. As discussed
elsewhere, under this IFR, asylum
officers will not issue removal orders.
The Departments agree that an asylum
officer should issue an NTA when not
granting an application for asylum and
refer the case for streamlined 240
proceedings before an IJ. Given this
process, the Departments find it is
unnecessary to further respond to the
comments regarding an asylum officer’s
authority to issue a removal order.
f. Other Comments on Proposed
Adjudication of Applications for
Asylum
Comments: One commenter
recommended several actions to address
delays in the USCIS affirmative asylum
adjudication process, including to
reduce or eliminate the diversion of
asylum office staff to conduct credible
fear screenings and instead refer asylum
seekers for full asylum interviews,
create a new streamlined process to
refer new requests for asylum
originating at the U.S. border to USCIS
asylum offices, ramp up hiring of
asylum office staff, modernize the
interview scheduling and filing systems,
create an application route for
cancellation of removal cases, and
resolve more cases at the USCIS asylum
offices in lieu of actions that typically
occur in immigration courts, such as
termination of immigration court
proceedings for individuals who have
filed an asylum application. The
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commenter also urged USCIS to address
the occurrence of asylum granted by an
immigration court but not initially
granted by USCIS.
Response: The Departments
acknowledge the recommendations to
address delays in the affirmative asylum
adjudication process, but further
consideration and discussion of the
affirmative asylum adjudication process
and different outcomes between
affirmative asylum office adjudications
and immigration court decisions fall
outside of the scope of this rulemaking.
The provisions of this rule respond to
the problem of delay and backlogs for
individuals encountered at the border
who seek asylum or related protection
by establishing a streamlined and
simplified adjudication process. As
discussed, the principal purpose of this
IFR is to simultaneously increase the
promptness, efficiency, and procedural
fairness of the expedited removal
process for individuals who have been
found to have a credible fear of
persecution or torture.
Comments: A commenter requested
that the Departments further clarify
adjudicatory timelines and processes so
that stakeholders can fully evaluate the
fairness, feasibility, and potential
efficiencies of the rule. For example, the
commenter stated that the proposed rule
does not establish a timeline for the
submission of evidence and does not
provide for continuances but, rather,
only extensions of undefined length and
purpose. This commenter also requested
that the Departments address the
anticipated timeline and process for the
adjudication of asylum claims for
individuals who are released from
detention following a positive credible
fear determination but prior to the
adjudication of their claim by an asylum
officer, stating the proposed rule seemed
to focus on asylum claim adjudication
for detained noncitizens.
Response: The Departments
acknowledge the request to clarify
adjudicatory timelines and processes.
DHS is clarifying at 8 CFR 208.9(a)(1)
that there will be a minimum of 21 days
between the service of the positive
credible fear determination on the
applicant and the date of the scheduled
Asylum Merits interview, unless the
applicant requests in writing that an
interview be scheduled sooner.
DOJ is also clarifying the timeline for
adjudications before the immigration
court should the proceedings be referred
to EOIR pursuant to new 8 CFR
1240.17(a) and (b). Notably, applicants
will not appear for a master calendar
hearing until at least 30 days after DHS
serves the NTA, as set forth at new 8
CFR 1240.17(b). Applicants will then be
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provided the opportunity to elect to
testify and submit additional
documentary evidence, as well as to
identify errors in the record of
proceedings before the asylum officer,
including the asylum officer’s decision.
8 CFR 1240.17(e). At this stage, parties
may elect to proceed on the
documentary record or may request a
final merits hearing. 8 CFR
1240.17(f)(1). Based on an independent
evaluation of the record, the IJ will then
determine whether to decide the
application on the documentary record
or to hold a merits hearing. 8 CFR
1240.17(f)(2). If deemed necessary, the
merits hearing generally will be
scheduled 60 to 70 days after the initial
master calendar hearing. Proceedings
may be continued and filing deadlines
may be extended, subject to certain
requirements previously discussed in
Section III.D of this preamble. In
general, the Departments expect that the
initial merits proceedings will be
completed within 135 days from the
first master calendar hearing before an
IJ, and often substantially sooner.
Having provided additional clarity
regarding adjudicating timelines in the
IFR, the Departments invite further
comments.
Comments: A commenter
recommended that the Departments
allow asylum seekers with a positive
credible fear determination to proceed
as affirmative asylum applicants before
USCIS, with referral to an immigration
court occurring after the asylum
interview, as necessary. The commenter
stated that this approach would reduce
the burden on immigration courts and
allow for efficient processing of
meritorious claims in a nonadversarial
system.
Response: The Departments
acknowledge the recommendation. The
IFR provides for a nonadversarial
asylum officer interview and
adjudication with referral to an
immigration court if the applicant is not
granted asylum, through a streamlined
section 240 proceeding with special
procedures that will appropriately
introduce efficiencies made possible by
the asylum officer’s record and
determinations.
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6. Application Review Proceedings
Before an Immigration Judge
Comments: A majority of commenters
who discussed the proposed IJ review
proceedings expressed due process,
procedural, constitutional, and other
concerns about the creation of new IJ
review proceedings and argued that
applicants not granted asylum by the
asylum officer should instead be
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referred to section 240 removal
proceedings.
Commenters stated that many asylum
seekers with strong and straightforward
claims would benefit from the chance to
be granted asylum after an interview
with an asylum officer. Oner commenter
stated that the initial interview with an
asylum officer is ‘‘theoretically a good
idea’’ but would ultimately depend on
implementation. However, commenters
were concerned that the NPRM’s IJ
review proceedings would
disproportionately affect applicants
with more complex cases. Thus,
commenters supported referral to an IJ
for a full evidentiary hearing if an
applicant’s case was initially not
granted by an asylum officer.
Commenters expressed significant
concern about the possibility of a
noncitizen being returned to a country
where he or she fears persecution or
torture without receiving a full
adversarial hearing.
Several commenters remarked that
they would be more supportive of the
NPRM’s provisions regarding initial
asylum officer adjudication if the NPRM
retained all asylum seekers’ rights to full
merits hearings in immigration court.
On the other hand, some commenters
were supportive of the NPRM’s
provisions that would have allowed a
noncitizen whose application was not
granted to submit additional evidence
for IJ review.
Response: Upon careful
consideration, the Departments have
revised the process set forth in the
NPRM so that individuals will be placed
in streamlined section 240 proceedings
rather than the NPRM’s proposal for
non-section 240 proceedings, as
described in new 8 CFR 1240.17, if an
asylum officer does not grant asylum
after an initial adjudication. As a
general matter, the Departments agree
with commenters that section 240
proceedings provide a better alternative
than the proceedings proposed in the
NPRM. IJs, DHS attorneys, and
immigration counsel are familiar and
experienced with the rules and
procedures that apply to section 240
proceedings because those proceedings
are the most common type conducted by
IJs. The statute and regulations provide
detailed standards and consistent rules
for the conduct of section 240 hearings
and noncitizens’ rights during such
proceedings, see 8 U.S.C. 1229a et seq.,
8 CFR 1240.1 through 1240.19.
Currently, asylum and protection
applications filed by noncitizens whose
cases originate from the credible fear
process are adjudicated in section 240
proceedings. In contrast, the NPRM
would have created a new process and
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would have imposed new evidentiary
standards and limitations. See 86 FR
46946. The Departments believe that the
NPRM process could have resulted in
efficiencies while still ensuring a fair
process, see, e.g., id. at 46906; however,
as commenters claim, the NPRM process
may also have resulted in increased
immigration court and appellate
litigation surrounding the interpretation
and application of the new standards
and evidentiary limitations. To avoid
those complications, the Departments
have decided not to adopt the NPRM’s
approach at this time and have instead
decided to place noncitizens in
streamlined section 240 proceedings if
an asylum officer does not approve the
noncitizen’s application. This process
will not employ the novel evidentiary
restrictions proposed in the NPRM, but
will instead apply largely the same longstanding rules and standards governing
the submission of evidence that apply in
ordinary section 240 proceedings.
However, in keeping with the NPRM’s
purpose to increase efficiency and
procedural fairness of the expedited
removal process for individuals who
have been found to have a credible fear
of persecution or torture, 86 FR 46909,
and in light of the efficiencies gained by
initial adjudication before and creation
of a record by the asylum officer, these
streamlined section 240 proceedings
will be subject to particular procedural
requirements that ensure they are
completed in an expeditious manner
while still preserving fairness to
noncitizens.78
The Departments agree with the
commenters’ assertions that noncitizens
and the overall immigration
adjudication system will benefit from
this rulemaking in part by authorizing
asylum officers to grant asylum to
noncitizens determined to have a
credible fear of persecution or torture. 8
CFR 208.2(a)(1)(ii). Asylum officers
receive extensive training and possess
expertise, see supra Section III.C of this
preamble; INA 235(b)(1)(E), 8 U.S.C.
1225(b)(1)(E); 8 CFR 208.1(b), and the
Departments are confident in asylum
officers’ ability to carry out their duties
in accordance with all applicable
78 Streamlined section 240 proceedings are
conducted in accordance with section 240 of the
INA, 8 U.S.C. 1229a, but with particular procedural
requirements laid out in new 8 CFR 1240.17, as
described above in Section III of this preamble.
EOIR has made other such procedural changes,
including the recent procedural requirements
imposed on cases subject to case flow processing
under Policy Memorandum (‘‘PM’’) 21–18, Revised
Case Flow Processing before the Immigration Courts
(Apr. 2, 2021). Generally, that PM eliminates the
master calendar hearing for represented nondetained cases, but those cases are still conducted
pursuant to section 240 of the INA, 8 U.S.C. 1229a.
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statutes and regulations and in an
efficient, fair manner.
The Departments have amended their
respective regulations in this IFR to
provide certain procedural protections
that address commenters’ concerns
about the process that applies if an
asylum officer does not grant asylum
after an initial adjudication. For
example, all noncitizens not granted
asylum by asylum officers after an
initial adjudication will be issued an
NTA and referred to streamlined section
240 proceedings, as described in new 8
CFR 1240.17. Because, under this IFR,
such noncitizens will be referred for
streamlined section 240 proceedings, 8
U.S.C. 1229a, the applicable evidentiary
standard is consistent with the
longstanding evidentiary standard for
section 240 proceedings—evidence is
admissible unless the IJ determines it is
untimely, not relevant or probative, or
that its use is fundamentally unfair. 8
CFR 1240.17(g); 8 CFR 1240.7(a);
Nyama, 357 F.3d at 816 (‘‘The
traditional rules of evidence do not
apply to immigration proceedings. . . .
‘The sole test for admission of evidence
is whether the evidence is probative and
its admission is fundamentally fair.’ ’’
(quoting Espinoza, 45 F.3d at 310));
Matter of Ramirez-Sanchez, 17 I&N Dec.
503, 505 (1980) (holding that evidence
must be ‘‘relevant and probative and its
use must not be fundamentally unfair’’).
As part of the streamlined section 240
proceedings adopted by DOJ in this IFR
at new 8 CFR 1240.17, noncitizens may
elect to testify or present additional
evidence that meets this evidentiary
standard. 8 CFR 1240.17(g). If the
noncitizen timely requests to testify, the
IJ must schedule a hearing unless the IJ
determines that the application can be
granted without live testimony and DHS
has not requested to present testimony
or cross-examine the noncitizen, as
described at new 8 CFR 1240.17(f)(4)(ii).
Given these protections, among others,
the Departments are confident that the
procedures are sufficient to ensure that
noncitizens will not be removed to a
country where they fear persecution or
torture without the opportunity for a
hearing before an IJ.
The Departments acknowledge those
commenters who expressed support for
the NPRM’s evidentiary procedures, but
the new process established by this IFR
at new 8 CFR 1240.17(g), and as
described above in Section III of this
preamble, maintains the noncitizen’s
ability to submit evidence to asylum
officers and IJs, albeit in accordance
with a broadened evidentiary standard
consistent with section 240 proceedings.
The new process further includes rules
governing continuances, procedures for
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prehearing conferences, and the
requirement of submissions by the
parties. The Departments believe that
the revisions, including (1) transmission
of the asylum office record, (2)
requirements that the IJ not hold a
hearing unless requested by a party or
if necessary, and (3) the deadlines
imposed, will prevent time-consuming
evidentiary hearings and increase the
overall efficiencies and effectiveness in
all cases.
a. Creation of New Limited Proceedings
in Lieu of Section 240 Removal
Proceedings and Limitation on Relief to
Asylum, Statutory Withholding of
Removal, and Convention Against
Torture Review Only
Comments: Several commenters
expressed opposition to the NPRM’s
procedures proposing that applicants
who are not granted asylum or are found
ineligible for statutory withholding of
removal or CAT protection by an
asylum officer must affirmatively
request further review by an IJ. Overall,
these commenters suggested that, if the
Departments move forward with the
NPRM’s new hearing process, these
applicants should be automatically
referred to the IJ for a hearing, ideally
in section 240 proceedings.
Multiple commenters compared this
process to the procedures for credible
fear review in which applicants who
neither affirmatively request IJ review
nor waive review are referred to the IJ.
See 8 CFR 208.30(g)(1).79 Commenters
stated that it was unclear why the
Departments would not apply the same
presumption to the NPRM’s process for
people who are not granted asylum by
asylum officers since, commenters
explained, the new hearing process is
essentially an extension of the credible
fear interview process at issue in 8 CFR
208.30(g)(1). In other words,
commenters urged the Departments to
automatically refer asylum officers’
decisions to not grant asylum to the IJ
for section 240 proceedings unless the
asylum seeker affirmatively states or
files a notice waiving IJ review (i.e.,
‘‘opts out’’).
Commenters expressed concern that
requiring an applicant to affirmatively
seek further review may result in some
applicants not receiving further IJ
review due to the applicant’s confusion
or the complexity of the process, and
not due to a lack of desire for further
review. For example, commenters noted
79 This citation refers to 8 CFR 208.30(g)(1) prior
to publication of the Global Asylum rule, which
amended 8 CFR 208.30(g), see 85 FR 80392, but
which has since been enjoined, see supra note 4
(discussing recent regulations and their current
status).
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that many asylum seekers who receive
a negative credible fear finding may not
know that they can seek a ‘‘de novo
review’’ or may not understand the
consequences of failing to seek review.
In addition, there may be problems for
applicants with the translation of
documents informing them about the
appeal process into a language they can
read, or with applicants understanding
the gravity of the process. Finally,
commenters explained that automatic
referral to an IJ is preferable to requiring
an affirmative election because the
applicant may receive an asylum
officer’s decision not to grant asylum
through the mail, which triggers a short
time to respond and other mail
difficulties.
Commenters expressed concern that
the 30-day period to request review by
the IJ is too short and recommended
extending the time period in which a
noncitizen must respond after receiving
a denial in the mail from 30 to 60 days.
Some commenters compared the IJ
referral procedures in the NPRM to
those for applicants who have
affirmatively applied before USCIS. See
8 CFR 208.14(c)(1) (instructing the
asylum officer to refer the application of
an applicant who is inadmissible or
deportable for adjudication in section
240 proceedings). Commenters were
concerned that the difference in the
procedures would create confusion in
immigrant communities and lead many
asylum seekers in the NPRM process to
mistakenly believe that their cases
would be automatically referred to the
immigration court. Similarly,
commenters were concerned that having
two different paths may also create
confusion potentially for the asylum
office itself.
Some commenters said that
substituting an ‘‘appeal’’ for a ‘‘referral’’
for IJ review is confusing and
potentially deceptive, especially for
applicants who appear pro se at an
asylum officer interview. Commenters
said that such applicants will likely
have difficulty understanding
paperwork that explains the contours of
these IJ review hearings, as well as the
obligation to file a notice of appeal,
thereby potentially foreclosing further
administrative and judicial review.
Commenters further expressed concern
that additional categories of applicants
would be particularly affected by the
requirement to affirmatively request IJ
review, including non-English speakers,
individuals with mental health
disabilities, trauma victims, and
individuals in detention.
Commenters noted that language
barriers, effects of trauma, and the
detrimental effects of detention all
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negatively impact an asylum seeker’s
ability to affirmatively request review.
In addition, commenters noted that the
noncitizens who would be placed in
proceedings before EOIR will have
already had an asylum officer determine
that the claim is credible and, therefore,
not frivolous. Thus, commenters
explained, such asylum seekers would
be unlikely to request review, resulting
in the waiver of meritorious claims.
Response: This IFR does not
implement the NPRM’s proposal for IJ
review proceedings, and instead adopts
streamlined section 240 proceedings, as
described above in Section III of this
preamble. Specifically, as described in
new 8 CFR 1240.17, DHS will file an
NTA and place the noncitizen in these
streamlined section 240 proceedings in
all cases where the noncitizen was
found to have a credible fear of
persecution or torture, but the asylum
officer subsequently did not grant the
asylum application.
The Departments believe that
providing streamlined section 240
proceedings addresses nearly all of the
commenters’ concerns and requests on
this topic. Applicants will not be
required to affirmatively request review
by an IJ, and applicants will not be
referred to the limited IJ proceedings
proposed in the NPRM. Instead,
applicants will be referred to
streamlined section 240 proceedings
that incorporate various procedural
measures to enhance efficiency,
consistent with the streamlined nature
of these proceedings, while still
ensuring fairness to noncitizens.
Proceedings under this IFR are
conducted under section 240 of the Act,
8 U.S.C. 1229a, and the streamlined
proceedings will advance more
expeditiously than ordinary section 240
proceedings generally proceed because
the IJ will have the benefit of the full
asylum officer record and the IJ and the
parties will be subject to timelines that
ensure the proceedings are adjudicated
promptly. The streamlined 240
proceedings will also ensure that the
intent of the NPRM to streamline IJ
review is preserved.
Nevertheless, the Departments believe
that these additional procedural
measures will not create confusion for
noncitizens, as section 240 proceedings
are the most common type of
immigration proceeding, and these new,
straightforward procedural requirements
will be directly communicated to
noncitizens. Moreover, the new
procedural timelines in the IFR are
responsive to commenters’ concerns
that noncitizens need longer than 30
days to identify errors in the asylum
officer’s decision. Notably, under the
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IFR, as set forth at new 8 CFR
1240.17(b), the master calendar hearing
will be held 30 days after the NTA is
served, or, if a hearing cannot be held
on that date, on the next available date
no later than 35 days after the date of
service. At the conclusion of the initial
master calendar hearing, the IJ will
schedule a status conference 30 days
after the master calendar hearing or, if
a status conference cannot be held on
that date, on the next available date no
later than 35 days after the master
calendar hearing, as described at new 8
CFR 1240.17(f)(1). At status conferences
provided for at new 8 CFR 1240.17(f)(2),
noncitizens will indicate orally or in
writing whether they intend to contest
removal or seek any protections for
which an asylum officer did not
determine a noncitizen eligible, and if
seeking protections, noncitizens will
indicate whether they intend to testify
before the immigration court, identify
any witnesses they intend to call, and
provide any additional documentation.
8 CFR 1240.17(f)(2)(i). Where a
noncitizen is represented by counsel,
the noncitizen shall further describe any
alleged errors or omissions in the
asylum officer’s decision or the record
of proceedings, articulate any additional
bases for asylum and related
protections, and state any additional
requested forms of relief. Id. The IFR
also provides specifically for
continuances and filing extensions in
streamlined section 240 proceedings,
which allows appropriate flexibility
with regard to the established timelines.
See 8 CFR 1240.17(h). If a noncitizen
needs additional time beyond these
timelines, as commenters suggested,
new 8 CFR 1240.17(h)(2) provides for
respondent-requested continuances and
filing extensions. Thus, these timelines
are clear, streamlined, and reasonable,
allowing noncitizens the opportunity to
reasonably present their cases while
maintaining the overall efficiencies of
the NPRM.
In addition to established evidentiary
standards, section 240 proceedings—
including the streamlined section 240
proceedings addressed in this IFR—
provide a number of procedural
protections established by statute and
regulation, such as the right to
representation, ‘‘a reasonable
opportunity to examine the evidence
against the [noncitizen], to present
evidence on the [noncitizen’s] own
behalf, and to cross-examine witnesses,’’
and the creation of a complete record of
the proceedings. INA 240(b)(4), 8 U.S.C.
1229a(b)(4). Additionally, the Act and
the regulations establish that the IJ
should play a robust role in
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proceedings. See INA 240(b)(1), 8 U.S.C.
1229a(b)(1) (requiring IJs to ‘‘administer
oaths, receive evidence, and interrogate,
examine, and cross-examine the alien
and any witnesses’’); 8 CFR 1003.10(b)
(same and requiring IJs to take other
actions that are ‘‘appropriate and
necessary for the disposition of’’ each
case); 8 CFR 1240.10(a) (requiring IJs to,
inter alia, advise noncitizens of certain
rights in section 240 proceedings and to
explain factual allegations and legal
charges in the NTA in non-technical
language); 8 CFR 1240.11(a)(2)
(requiring IJs to inform noncitizens of
‘‘apparent eligibility to apply for any of
the benefits enumerated in this
chapter’’); 8 CFR 1240.1(a)(1)(iv)
(authorizing IJs to ‘‘take any other action
consistent with applicable law and
regulations as may be appropriate’’ in a
section 240 proceeding). Additionally,
section 240 proceedings provide for
special consideration for noncitizens
who may present with competency
issues. See INA 240(b)(3), 8 U.S.C.
1229a(b)(3); Matter of M–A–M–, 25 I&N
Dec. at 479–84 (stating that where a
noncitizen shows indicia of
incompetency, the IJ must inquire
further and establish safeguards where
appropriate). In addition, the IFR carves
out a specific exception to the general
timeline and procedures in the
streamlined 240 proceedings for a
noncitizen who has exhibited indicia of
incompetency at new 8 CFR
1240.17(k)(6).
The Departments note that the IFR
does not permit noncitizens to ‘‘optout’’ of or decline further proceedings
before an IJ because section 240 of the
Act, 8 U.S.C. 1229a, requires an IJ, as
opposed to the asylum officer, to issue
the order of removal in cases where
asylum is denied. The IFR does,
however, allow a noncitizen to indicate
that the noncitizen does not wish to
contest removal or seek any protections
for which the asylum officer did not
find the noncitizen eligible, as set forth
in new 8 CFR 1240.17(f)(2)(i)(B). In such
a case, if the asylum officer determined
the noncitizen eligible for withholding
of removal or protection under the CAT,
the IJ will give effect to that protection
as determined by the asylum officer
unless DHS makes a prima facie
showing through new evidence or
testimony that specifically pertains to
the respondent and that was not
included in the record of proceeding for
the USCIS Asylum Merits interview that
the respondent is not eligible for such
protection. In addition, if a noncitizen
fails to appear for the IJ proceedings, the
IJ will generally be required to issue an
in-absentia removal order pursuant to
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existing regulations, but will similarly
give effect to the asylum officer’s
determination, if any, that the
noncitizen is eligible for withholding of
removal or protection under the CAT,
unless DHS demonstrates that the
respondent is not eligible for such
protection, as provided in new 8 CFR
1240.17(d).
Comments: Commenters expressed
concerns that the NPRM’s proposed IJ
review proceedings lacked procedural
protections and due process safeguards.
Commenters stated that placing
applicants whose cases are not granted
by the asylum officer in these limited,
asylum-only-type proceedings limits
critical and well-established due
process protections for applicants. In
other words, commenters generally
supported placing applicants in section
240 proceedings, to include the broader
evidentiary standard applied in 240
proceedings, rather than a new limited
proceeding tethered to the asylum
interview record, and imposing a
narrow evidentiary standard.
Commenters stated that the NPRM’s
proposed IJ review proceedings would
erase the procedural guarantees and
protections of full removal hearings and
inappropriately limit immigration court
consideration of asylum officer
decisions. For instance, under the
NPRM, an applicant would be unable to
submit applications for other forms of
relief without submitting additional
motions, and would be unable to submit
additional evidence unless an IJ deems
it ‘‘necessary’’ and ‘‘not duplicative.’’
Commenters stated that IJs would be
expected to rule in these ‘‘reviews’’
without holding evidentiary hearings.
Similarly, commenters expressed
concern that the proceedings would
effectively be limited to review of only
the asylum officer’s notes, which would
deprive the applicant of the right to
present testimonial and documentary
evidence, cross-examine adverse
witnesses, and review and rebut all
evidence considered by the adjudicator.
Commenters expressed concern that the
procedures in the NPRM’s proposed IJ
review, as compared to section 240
proceedings, could deprive applicants
of a true opportunity to be heard.
Commenters stated that the evidentiary
provisions of the IJ review process could
not cure the absence of these procedural
protections. Commenters said the
evidentiary procedures proposed by the
NPRM during IJ review are vague and
inadequate, and the NPRM’s articulated
rationales for a truncated hearing rather
than full section 240 proceedings are
arbitrary and capricious.
Commenters expressed concern about
the nature of the record before the IJ in
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the review proceedings proposed by the
NPRM—more specifically, that the
NPRM gives a disproportionate amount
of deference to asylum officer decisions
while simultaneously limiting IJ
adjudication to a mere review of the
asylum officer-created record, rather
than providing for a full de novo merits
hearing. Commenters believed the
NPRM would allow credible fear
interview notes to be the sole basis of
the asylum application, and that
proposed 8 CFR 208.14(c) would allow
asylum applications to be the sole piece
of evidence reviewed by the IJ.
Commenters also believed that relying
on the asylum officer to adequately
develop the record falls far short of due
process standards. Commenters
expressed concern that the asylum
officer’s notes may not explain why
certain types of evidence were not
allowed to be presented. Given these
concerns, commenters said that this
would create a chain of reliance on
limited and often incomplete credible
fear interview notes, would limit the
ability of counsel to effectively
supplement the record where necessary,
and would prejudice clients who were
not able to fully present their claims
during the credible fear interview
because of incapacity, trauma, or an
improper setting for the interview.
Commenters stated that the NPRM
does not explicitly guarantee the
applicant a right to receive a decision
from the IJ that lays out the reasons for
their decision. Commenters reasoned
that these decisions are critical for BIA
and judicial review and thus, at a
minimum, the NPRM should include
the same standard of requiring an IJ to
explain the reasoning underlying the
court’s decision as in section 240
proceedings.
Commenters expressed concern that
the proposed IJ review procedure would
provide insufficient review in light of
the nature of the asylum officers’
adjudications and decisions.
Commenters stated that, in the context
of asylum officers’ adjudications of
affirmative asylum applications or those
filed by unaccompanied children,
applicants receive a one-page notice
explaining the decision with limited
legal explanation. Assuming the
decisions by asylum officers in the new
procedures under the NPRM would be
similar, commenters expressed concern
that the NPRM does not provide the
same safeguard of section 240
proceedings that is provided to these
other applicants. Commenters stated
that asylum officers do not always
adequately review the entire record and
make referrals to the immigration court
for complex cases. Commenters stated
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that the NPRM’s proposed IJ review
proceedings would not ensure that any
errors or omissions by the asylum
officer are uncovered, particularly
where the IJ rejected additional
evidence or testimony that might
support the protection claim.
Commenters stated that full section
240 proceedings are necessary because
many applicants who currently are
referred to removal hearings by asylum
officers are granted asylum by an IJ.
Commenters stated that reasons for the
high number of cases granted after
referral to EOIR, in the current section
240 referral process, include
insufficiency or inaccuracy of credible
fear interview notes as a sole measure of
credibility, the structure of the asylum
officer’s interview, access to counsel,
and access to evidentiary material and
witness testimony. In contrast,
commenters said the standard for
considering admissible evidence in
section 240 proceedings is relevance
and fundamental fairness, and that
immigration proceedings favor broad
evidentiary admissibility. Commenters
said the reason for the large disparity in
outcomes was the right to a full de novo
court hearing, where attorneys were free
to offer documents, briefs, and
testimony.
Commenters also took issue with the
NPRM’s statement that a noncitizen
would have a ‘‘full opportunity to
challenge’’ an asylum officer’s decision
to not grant asylum through an IJ’s
review of the asylum interview record.
Commenters stated that, statistically, a
large number of asylum applicants are
unsuccessful in making a strong case for
themselves at their hearings before
asylum officers, citing impacts of
trauma on presenting claims and
difficulties with providing documentary
evidence on short notice. Thus,
commenters asserted, it is not realistic
or fair to expect that the record of the
hearing before an asylum officer, on
which the IJ would rely during their
review, would be sufficient to ensure
that applicants have the opportunity to
adequately make their case.
Commenters stated that the
availability of section 240 proceedings
for some applicants and only limited
proceedings under the NPRM for other
asylum applicants is not rationally
connected to (1) whether a noncitizen
has been or may be persecuted or
tortured in the country the noncitizen
left behind, and (2) the noncitizen’s
ability to articulate the claim or timely
obtain evidence. Therefore, commenters
urged that any final rule preserve the
right to full adversarial proceedings
before an IJ for those applicants who
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have not had their applications granted
by an asylum officer.
Commenters stated that the NPRM is
not clear as to what extent applicants
who do not receive a grant of asylum by
the asylum officer will be negatively
impacted if placed in affirmative
proceedings without a guarantee of full
section 240 proceedings. Commenters
stated that if the NPRM decreased due
process protections of applicants by
denying the benefit of full section 240
proceedings, it may reduce access to the
asylum process. Commenters said the
NPRM raises transparency concerns
regarding how the Departments will
handle cases after review by an asylum
officer.
Commenters said the Departments
must not enact a faster process at the
expense of due process protections and
one commenter expressed concern that
the NPRM’s limited review proceedings
would result in the creation of a de facto
‘‘rocket docket’’ that would place
asylum seekers at risk of summary
deportations. Absent clarification on the
potential impact of these provisions, the
commenters said they had been denied
an opportunity to meaningfully
comment on the NPRM.
Response: As described above in
Section III of this preamble, the
Departments have determined that a
noncitizen whose asylum claim is not
granted by an asylum officer after an
initial adjudication will be issued an
NTA and referred to an IJ for
streamlined section 240 removal
proceedings, and the Departments have
decided not to implement the IJ review
proceedings originally proposed in the
NPRM. Section 240 proceedings follow
issuance of a notice of charges of
inadmissibility or removability against a
noncitizen, INA 239(a)(1), 8 U.S.C.
1229(a)(1); INA 240(a), 8 U.S.C.
1229a(a), and provide an opportunity
for the noncitizen to make a case to an
IJ, INA 240(a), (b), 8 U.S.C. 1229a(a), (b).
Accordingly, the use of section 240
proceedings provides notice and an
opportunity to be heard, which satisfies
due process. See, e.g., LaChance v.
Erickson, 522 U.S. 262, 266 (1998)
(‘‘The core of due process is the right to
notice and a meaningful opportunity to
be heard.’’).
The Departments’ decision not to
implement the NPRM’s proposal for
limited review proceedings for
applications not granted by the asylum
officer and instead to refer noncitizens
to streamlined section 240 removal
proceedings addresses commenters’
concerns that the NPRM’s proposed
proceedings were overly restrictive. In
response to commenters’ concerns
regarding the nature of the record
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created by the asylum officer, the
Departments note that while the written
record of the positive credible fear
determination will be considered a
complete asylum application, applicants
may subsequently amend or correct the
biographic or credible fear information
in the Form I–870, Record of
Determination/Credible Fear Worksheet,
or supplement the information collected
during the process that concluded with
a positive credible fear determination. 8
CFR 208.4(b)(2). Also, because the IFR
is consistent with the evidentiary
standard for section 240 proceedings,
noncitizens may review and present
evidence that is relevant and probative,
which eliminates the NPRM’s limited
evidentiary standard of ‘‘necessary’’ and
‘‘not duplicative’’ and ensures
noncitizens have the opportunity to
supplement the record for IJ review. 8
CFR 1240.17(g). Upon conclusion of the
streamlined section 240 proceedings,
the DOJ regulations provide that an IJ
will issue a decision considering the full
record before the IJ, as set forth at new
8 CFR 1240.17(f)(5), and noncitizens
will have an opportunity for appeal. 8
CFR 1240.13, 1240.15. The IJ has a duty
to provide a decision orally or in
writing. See Matter of Kelly, 24 I&N Dec.
446, 447 (BIA 2008) (holding that the IJ
has a responsibility ‘‘to insure [sic] that
the decision in the record is complete’’);
8 CFR 1003.37. Specifically, the IJ ‘‘shall
decide whether an alien is removable
from the United States. The
determination of the [IJ] shall be based
only on the evidence produced at the
hearing.’’ INA 240(c)(1)(A), 8 U.S.C.
1229a(c)(1)(A). These provisions ensure
that noncitizens receive a meaningful
opportunity to be heard and afford
procedural protections and due process
safeguards. Moreover, under the IFR,
noncitizens will not need to engage in
additional motions practice—as they
would have under the NPRM—should
they wish to seek other forms of relief
beyond the applications previously
considered by the asylum officer.
Further, IJs will conduct hearings for
noncitizens who request to present live
testimony, unless the application can be
granted without a hearing, as indicated
at new 8 CFR 1240.17(f)(4). The
Departments find that the process set
forth in this IFR addresses commenters’
concerns that the NPRM provided
undue deference to asylum officers
while limiting the IJ’s role in the
proposed application review
proceedings. While the Departments
recognize that commenters stated they
prefer ‘‘full’’ section 240 proceedings
over those proposed in the NPRM, the
Departments believe that the
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streamlined procedures set forth in this
rule are necessary and appropriate for
furthering efficiency interests while still
ensuring fair adjudication of claims. In
addition, the transcription of the
hearing before an asylum officer, along
with the additional timelines for
completing cases that are included in
this IFR, address commenters’ concerns
about transparency as to how the
Departments will handle cases.
Comments: Commenters similarly
stated that the NPRM does not permit
procedures provided in section 240
proceedings, specifically in regard to
continuances. Commenters explained
that in section 240 proceedings,
noncitizens are first scheduled for
master calendar hearings where, among
other things, IJs ask if they need a
continuance to secure representation.
Commenters stated that continuances
are routine throughout the course of a
case in immigration court. However, if
proceedings are transferred to the
asylum office, commenters were
concerned that noncitizens will have
less freedom to request their interview
be rescheduled because DHS only
allows for continuances of asylum
officer proceedings in ‘‘exceptional
circumstances.’’
Commenters also pointed out that 8
CFR 1003.48(e) as proposed in the
NPRM did not adequately contemplate
the legitimate needs for which an
extension may be necessary (e.g., to
obtain representation by counsel).
Commenters reasoned that applications
for continuances should be fully
documented, setting forth the steps
already taken to secure an attorney or to
obtain supporting evidence.
Commenters believed that requests
should be granted to allow for
additional time, within reasonable
limits, if applicants establish that they
have been diligent and thorough with
their search.
Response: At new 8 CFR 1240.17(h),
the IFR explicitly provides for
continuances in the context of
streamlined section 240 proceedings. As
specifically relevant to commenters’
concerns, the IJ may grant initial
continuances, including continuances to
allow the noncitizen time to secure
representation. These initial
continuance standards will be governed
by the long-standing, traditional ‘‘good
cause’’ standard, as described at new 8
CFR 1240.17(h)(2)(i). See 8 CFR
1003.29.
As discussed above in Section III of
this preamble, and as found at new 8
CFR 1240.17(h)(2)(ii) and (iii), the IFR
also allows additional continuances
beyond the initial 30-day ‘‘good cause’’
period, but the standards for additional
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continuances beyond the initial 30-day
‘‘good cause’’ period will be
increasingly restrictive as the
noncitizen’s requested continuances
increase the aggregate delay of the
proceedings. The IFR provides
heightened standards for consideration
when the merits hearing has been
delayed for more than 90 days past the
initial master calendar hearing due to
continuances granted to the noncitizen.
Nevertheless, the IFR preserves the
opportunity for continuances as
necessary to ensure a fair proceeding or
to prevent a violation of statutory or
constitutional rights, including the
statutory right to counsel, as set forth at
new 8 CFR 1240.17(h)(2)(ii)–(iii).
Comments: Commenters explained
that the NPRM’s proposed ‘‘prohibition’’
on immigration court consideration on
the issue of removability may violate
due process and result in wrongful
removals. For example, commenters
described a situation in which an IJ
properly probed for facts and discovered
that the noncitizen facing removal was
in fact a U.S. citizen. However,
commenters explained, if IJs are not
permitted to make a ruling on
admissibility or removability, there is
no incentive for them to inquire to
determine if the applicant before them
has undiscovered legal status. To ensure
that noncitizens are not removed by
mistake and to avoid unnecessary
hearings for those who are not
removable, the commenters said that IJs
should be permitted to inquire and
make determinations regarding
removability.
Response: The IFR resolves
commenters’ concerns with issues of
removability and admissibility. In the
streamlined section 240 removal
proceedings introduced by this IFR, as
in all section 240 proceedings, the IJ
must make a determination regarding
whether the noncitizen is subject to
removal as charged. 8 CFR
1240.17(f)(2)(i), (k)(3); 8 CFR 1240.10(c),
(d). The IFR includes an exception to
the timelines in the streamlined
proceedings for cases in which the
noncitizen makes a prima facie showing
that the noncitizen is not subject to
removability and the IJ determines that
the challenge cannot be resolved
simultaneously with the adjudication of
the noncitizen’s applications for
asylum, statutory withholding of
removal, or withholding or deferral of
removal under the CAT. Instead, these
noncitizens will be subject to ordinary
section 240 proceedings, as described at
new 8 CFR 1240.17(k)(3).
Comments: Commenters disagreed
with the NPRM’s statement that
‘‘requiring a full evidentiary hearing
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before an IJ after an asylum officer’s
denial would lead to inefficiencies
without adding additional value or
procedural protections.’’ 86 FR 46918.
Commenters argued that this ignores the
reality of the asylum process by
assuming that applicants will be able to
develop a full evidentiary record before
the asylum officer, demonstrates a
misunderstanding of how difficult it is
to be granted asylum, and could hinder
due process. Commenters said that
nonadversarial hearings with asylum
officers are not faster and fairer than
immigration court hearings with
represented applicants, especially if
attorneys on both sides agree to narrow
issues in dispute before the IJ. At least
one commenter believed that, under the
NPRM, an IJ’s decision regarding
rejecting or admitting evidence would
not be reviewable by the BIA or a U.S.
Court of Appeals because the NPRM did
not require the judge to provide a
reasoned decision. Therefore,
commenters explained, the NPRM’s
proposed IJ review could deny a
noncitizen the opportunity to relate
clearly and completely the
circumstances of persecution or a wellfounded fear of persecution to either an
asylum officer or IJ. Commenters
anticipated that the NPRM, if it had
been promulgated in that form, would
be vacated because it is inconsistent
with due process guaranteed by the
Fifth Amendment as well as INA
240(b)(4)(B), 8 U.S.C. 1229a(b)(4)(B),
which provides that noncitizens shall
have a reasonable opportunity to
examine the evidence against them, to
present evidence on their own behalf,
and to cross-examine witnesses
presented by the Government.
Response: The Departments disagree
with commenters’ concerns that the
initial asylum officer adjudication of
claims would not provide further
efficiencies over the current expedited
removal credible fear screening process.
Although this IFR revises the process as
proposed by the NPRM for reviewing
applications that an asylum officer does
not grant, the Departments maintain that
having an Asylum Merits interview with
an asylum officer for noncitizens with
positive credible fear determinations, as
both the IFR and NPRM provide, will be
more expeditious than the current
process of referring all noncitizens with
positive credible fear determinations to
section 240 proceedings before the
immigration court. As described in the
NPRM, immigration courts are
experiencing large and growing backlogs
and subsequent adjudication delays. 86
FR 46907. Asylum officers are well
trained and experienced with asylum
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adjudications, and each case that is
granted by USCIS is a direct reduction
in cases that would have been before
EOIR. See id. The threshold asylum
officer hearing proposed in the NPRM
also will ensure that cases referred to
immigration court will include a welldeveloped record. Where cases are
referred with such a record, IJs will not
have to grant continuances for
respondents to file applications for
asylum and related protection. Even
though parties will be able to file
additional evidence, the asylum officer
record will help IJs to narrow issues. For
both these reasons, USCIS adjudication
of claims will promote efficiency before
EOIR.
In addition, the IFR does not adopt
the NPRM’s proposal for broad limits on
introducing new evidence. Instead, the
IFR provides at new 8 CFR 1240.17(g)(1)
that IJs may exclude documentary
evidence or witness testimony ‘‘only if
it is not relevant or probative; if its use
is fundamentally unfair; or if the
documentary evidence is not submitted
or the testimony is not requested by the
applicable deadline, absent a timely
request for a continuance or filing
extension that is granted.’’ The
Departments believe the IFR’s
evidentiary standard addresses the
commenters’ concerns regarding the
need for a full evidentiary hearing.
Further, the Departments believe that,
overall, the IFR’s streamlined section
240 proceedings will be equally
effective, if not more so, than the
NPRM’s proposed proceedings in
enhancing efficient adjudication and
replacing time-consuming evidentiary
hearings. For example, the IFR provides
that the asylum officer’s record will be
automatically transmitted upon DHS’s
issuance of an NTA, which will enable
the parties to narrow the issues and
assist the IJ’s review of the case. The IFR
also provides that if neither party
requests to present testimony, or if the
IJ determines that the asylum
application can be granted without
hearing testimony and DHS does not
request to present testimony or
evidence, the IJ can decide the case
without a hearing. The IFR also
provides various deadlines for the
scheduling of hearings and the issuance
of the IJ decision. These measures
enhance efficiency by precluding the
need for a full evidentiary hearing in
some cases and by facilitating a more
efficient hearing when one is necessary.
Finally, in response to commenters’
concerns regarding administrative and
judicial review of IJ decisions regarding
the admission of evidence, the
Departments emphasize that there is not
a substantive difference regarding IJs’
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decisions on the admission of evidence
in these streamlined section 240
proceedings and standard 240
proceedings. Either party may challenge
the IJ’s decision during a subsequent
appeal to the BIA, which will be
reviewed pursuant to the same
standards of review as for appeals from
ordinary section 240 proceedings. See 8
CFR 1003.1; INA 242, 8 U.S.C. 1252. A
noncitizen who receives an adverse
decision from the BIA may file a
petition for review subject to the
requirements of section 242 of the INA,
8 U.S.C. 1252, and nothing in this rule
affects that statutory provision.
Comments: Commenters expressed
concerns that IJs would serve a
‘‘pseudo-appellate’’ role by reviewing
decisions by asylum officers. The
commenters characterized the current IJ
review process of negative credible fear
interviews as ‘‘deficient’’ and explained
that expanding this aspect of the IJ’s
duty will amplify due process concerns
and result in erroneous removals.
Therefore, commenters urged that, if the
NPRM is not withdrawn, the
Departments should at least
automatically refer claims not granted
by asylum officers for full section 240
proceedings.
Response: The Departments find that
the decision to place individuals whose
applications are not granted by the
asylum officer into streamlined 240
proceedings, rather than the NPRM’s
proposed IJ review proceedings,
addresses commenters’ concerns that
the new procedures would have been
akin to a credible fear review rather than
an adjudication in removal proceedings.
As commenters point out, section 240
proceedings allow noncitizens a fuller
opportunity to present evidence and
testimony to develop the record, secure
and work with counsel if they have not
yet done so, and participate in
additional hearings as needed. See
generally 8 CFR part 1240. The IFR
includes additional procedural
requirements to ensure that proceedings
will proceed more expeditiously, but
will still give noncitizens a full
opportunity to develop the record and
obtain a de novo determination as to
asylum eligibility from the IJ, thus
obviating commenters’ concerns. When
conducting these streamlined 240
proceedings, IJs will exercise
independent judgment and discretion in
reviewing the claims before them for
adjudication. See 8 CFR 1003.10(b); see
generally EOIR, Ethics and
Professionalism Guide for Immigration
Judges (Jan. 2011), https://
www.justice.gov/eoir/sibpages/
IJConduct/EthicsandProfessionalism
GuideforIJs.pdf (IJ Ethics and
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Professionalism Guide) (requiring IJs to,
inter alia, be faithful to the law,
maintain professional competence in
the law, act impartially, and avoid
actions that would create the
appearance of violations of the law or
applicable ethical standards). The
Departments believe the protections
provided in section 240 proceedings are
appropriate to provide a sufficient
record for appeal.
Nevertheless, the Departments also
clarify that, contrary to commenters’
conclusory statements, IJs’ current
credible fear review process is not
‘‘deficient’’ and does not violate due
process. The IFR maintains the NPRM’s
approach of restoring the credible fear
screening standards that were in effect
prior to the regulatory changes made
between 2018 and 2020. See 86 FR
46911. None of those regulations has
gone into effect, as all are delayed,
vacated, or enjoined. See id. at 46909
n.24. The Departments believe that
returning the regulations to the
framework in place prior to the changes
made between 2018 and 2020 will
ensure the process is more efficient,
effective, and consistent with
congressional intent. Id. at 46914. The
Supreme Court has emphasized that
noncitizens who are encountered in
close vicinity to and immediately after
crossing the border and placed in
expedited removal proceedings, which
include the credible fear screening
process, have ‘‘only those rights
regarding admission that Congress has
provided by statute.’’ Thuraissigiam,
140 S. Ct. at 1983. Congress provided
the right to a determination whether the
noncitizen has a ‘‘significant
possibility’’ of establishing eligibility for
asylum under INA 208, 8 U.S.C. 1158.
See also INA 235(b)(1)(B)(ii), (v), 8
U.S.C. 1225(b)(1)(B)(ii), (v). Because the
regulations reestablish the ‘‘significant
possibility’’ standard, consistent with
the statute, it does not infringe on
noncitizens’ rights. See Thuraissigiam,
140 S. Ct. at 1983. In addition, despite
the Departments’ disagreement with the
commenters’ characterization of the
credible fear review process, the
Departments find that this IFR addresses
commenters’ concerns as IJs will
continue to have the traditional
adjudicator authorities in 240
proceedings.
Comments: Commenters stated that
the reports by the U.S. Commission on
International Religious Freedom
(‘‘USCIRF’’), the Administrative
Conference of the United States
(‘‘ACUS’’), and the Migration Policy
Institute (‘‘MPI’’) cited in the NPRM as
support for asylum officers adjudicating
defensive claims do not suggest
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eliminating full evidentiary IJ hearings
of defensive asylum claims, which
commenters believed the NPRM
implied. 86 FR 46917–18. Commenters
stated that requiring the applicant to
petition the IJ for consideration of
additional evidence would curtail due
process beyond the procedure
recommended by USCIRF whereby
asylum officers would either grant
asylum cases immediately after the
credible fear interview or, in more
complicated cases, refer the applicant to
full proceedings before an IJ.
Response: The NPRM’s references to
reports by the USCIRF, ACUS, and MPI
were not meant to imply support for the
NPRM’s proposed process, as
commenters alleged. Rather, the NPRM
clearly stated that those reports
‘‘assumed that individuals denied
asylum by a USCIS asylum officer
would be issued an NTA and placed
into section 240 removal proceedings
before an IJ, where the noncitizen would
have a second, full evidentiary hearing
on the asylum application with a
different decision-maker. This proposed
rule would not adopt that approach
. . . .’’ 86 FR 46918 (emphasis added).
Nevertheless, for the reasons discussed
thus far and above in Section III of this
preamble, this IFR replaces the NPRM’s
proposed IJ review procedure with
streamlined section 240 removal
proceedings.
Comments: Commenters raised
concerns that the NPRM’s procedures
distinct from section 240 IJ review could
have a negative impact on those
applicants who are unrepresented by
counsel, non-English speakers, or
trauma survivors. Accordingly,
commenters recommended that asylum
seekers instead be given an opportunity
to obtain counsel and present all
evidence in support of their claims in
section 240 merits hearings before IJs.
Commenters asserted that only such a
hearing would ensure that pro se
applicants are not wrongfully returned
to danger in violation of the United
States’ nonrefoulement obligations.
Commenters generally argued that
issues related to lack of access to
counsel stem from the fact that
noncitizens appearing before the
immigration courts have no right to
Government-appointed counsel.
Commenters urged the Departments to
consider that, while many asylum
seekers do not have access to legal
representation at any stage of
immigration proceedings, they are
particularly unlikely to have legal
representation at early stages of
presenting their claims. Other
commenters believed that the majority
of asylum applicants do not have
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representation. Commenters expressed
concerns that, under the NPRM,
unrepresented asylum seekers would
not be able to adequately present their
asylum claims before the asylum officer,
and that these initial deficiencies would
later pose significant challenges to
legitimate claims, even with the
assistance of counsel, once asylum
seekers are before the immigration
court. Commenters also raised concerns
that unrepresented applicants, many of
whom are unfamiliar with the
complexities of immigration law and do
not speak English, would be unable to
adequately draft filings, fill out forms,
and present their claims at all,
particularly within the time constraints
presented by the NPRM. Commenters
noted that these concerns are further
exacerbated by the fact that many
applicants suffer from post-traumatic
stress disorder or other mental health
ailments.
Commenters stated that the NPRM
would negatively impact trauma
survivors’ ability to present their claims
because they may not be able to
immediately disclose all relevant facts
pertaining to their claims to their
asylum officers or even their own
counsel. Commenters stated that it is
common for asylum seekers to disclose
only limited information about their
past persecution in early statements and
then to provide greater detail when later
questioned by an IJ. Commenters stated
that it may take several meetings with
an advocate before asylum seekers are
comfortable enough to share the details
of their persecution. Commenters
asserted that the NPRM would increase
the likelihood that such applicants may
face erroneous adverse credibility
determinations, and that the expedited
process would be generally detrimental
to a full exploration of claims.
Commenters particularly argued that
more robust procedural safeguards are
critically important to guaranteeing
LGBTQ+ asylum seekers the
opportunity to present their claims.
Commenters cited Matter of M–A–M–,
25 I&N Dec. 474, as an example of a case
that recognized the important
procedural protections available in
section 240 removal proceedings. In
Matter of M–A–M–, the BIA recognized
the right for applicants who may lack
mental capacity to present expert
testimony to demonstrate that their
mental health conditions impacted their
claims. Id. at 479.
Moreover, commenters believed that
asylum officers are not in the best
position to probe an applicant on the
reasons for inconsistencies in a claim,
particularly when the asylum seeker
acted pro se or received ineffective
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assistance of counsel before the Asylum
Office. Commenters anecdotally stated
that they have witnessed circumstances
where asylum officers failed to
thoroughly probe the reasons for
inconsistencies, but where applicants
later resolved inconsistencies during
direct examination in immigration
court. Without the ability to testify live
on the same issues in a truly de novo
proceeding, one commenter said, many
traumatized asylum seekers would not
have the opportunity to present critical
evidence that would prove their claims.
Response: The IFR addresses
commenter concerns about the rule’s
impact on vulnerable populations,
including individuals with posttraumatic stress disorder, individuals
who face language barriers, and
individuals who are unrepresented, by
providing that noncitizens whose
applications are not granted by the
asylum officer will be placed in
streamlined section 240 proceedings
rather than finalizing the IJ review
procedure proposed in the NPRM. The
Departments have included procedural
rules to ensure the efficient disposition
of these cases, and noncitizens in these
streamlined 240 proceedings will
receive all of the procedural protections
required by section 240 of the Act, 8
U.S.C. 1229a, which commenters were
concerned were lacking in the NPRM.
See INA 240(b)(4), 8 U.S.C. 1229a(b)(4)
(setting forth noncitizen’s rights in
proceedings); see also Matter of M–A–
M–, 25 I&N Dec. at 479–83 (stating that
where a noncitizen has indicia of
incompetency, the IJ must inquire
further and establish safeguards where
appropriate). The Departments believe
that these measures are sufficient to
ensure that all noncitizens, including
vulnerable noncitizens, have adequate
time to prepare and present their claims.
Moreover, the IFR explicitly exempts
certain categories of noncitizens,
including juveniles and mentally
incompetent individuals, from the
streamlined procedures created by this
IFR, as described at new 8 CFR
1240.17(k).
With respect to commenters’ concerns
about noncitizens not having adequate
access to or time to obtain counsel, the
Departments recognize the ‘‘immense
value of legal representation in
immigration proceedings, both to the
individuals that come before [EOIR] and
to the efficiency of [its] hearings.’’
Director’s Memo (‘‘DM’’) 22–01:
Encouraging and Facilitating Pro Bono
Legal Services 1 (Nov. 5, 2021), https://
www.justice.gov/eoir/book/file/
1446651/download. As with all
noncitizens in section 240 removal
proceedings, the individuals subject to
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the IFR have a right to representation at
no cost to the Government. INA
240(b)(4)(A), 8 U.S.C. 1229a(b)(4)(A).80
Additionally, resources are available for
pro se noncitizens in immigration court.
See, e.g., EOIR, Pro Bono Legal Service
Providers, https://probono.eoir.
justice.gov; EOIR, Immigration Court
Online Resource, https://icor.eoir.
justice.gov/en/;cf. EOIR, Press Release,
EOIR Announces ‘‘Access EOIR’’
Initiative (Sept. 28, 2021) (aiming to
increase representation before EOIR),
https://www.justice.gov/eoir/pr/eoirannounces-access-eoir-initiative; EOIR,
Press Release, EOIR Launches Resources
to Increase Information and
Representation (Oct. 1, 2020), https://
www.justice.gov/eoir/pr/eoir-launchesresources-increase-information-andrepresentation.
In addition, because noncitizens in
section 240 removal proceedings,
including the streamlined section 240
proceedings set forth in the IFR, have
the right to provide testimony and
evidence in support of their
applications, the Departments find that
placing noncitizens whose applications
are not granted by the asylum officer in
streamlined section 240 proceedings
rather the NPRM’s proposed distinct
proceedings addresses commenters’
concerns about the effect of a lack of
representation early in the expedited
removal or asylum application process.
In other words, noncitizens who fail to
provide evidence or testimony on
relevant parts of their claims before
asylum officers due to a lack of
representation will have the ability to
submit additional evidence or testimony
to the IJ during subsequent streamlined
section 240 proceedings, as described
above in Section III of this preamble.
Further, noncitizens in these
streamlined section 240 proceedings
will have opportunities to obtain
80 The Departments strive to improve access to
counsel, as evidenced through other policies and
rulemakings, and recognize that increasing access to
counsel will, in turn, further the efficiency of all of
the Departments’ operations, including those set
forth in this rulemaking. See DM 22–01:
Encouraging and Facilitating Pro Bono Legal
Services (Nov. 5, 2021) (‘‘Competent legal
representation provides the court with a clearer
record and can save hearing time through more
focused testimony and evidence, which in turn
allows the judge to make better-informed and more
expeditious rulings.’’); see generally Executive
Order 14012, 86 FR 8277, 8277 (Feb. 2, 2021)
(directing Attorney General and Secretary to
‘‘identify barriers that impede access to immigration
benefits and fair, efficient adjudications of these
benefits and make recommendations on how to
remove these barriers, as appropriate and consistent
with applicable law’’). Nevertheless,
recommendations from commenters calling for
noncitizens to have access to appointed counsel in
section 240 removal proceedings are beyond the
scope of this rulemaking.
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representation even before removal
proceedings are initiated as they may be
represented during the initial
adjudication conducted by the asylum
officer. See 8 CFR 208.9.
The Departments believe that
commenters’ concerns that the
procedures proposed in the NPRM
would negatively impact individuals
whose claims develop over time or who
need additional time and testimony to
explain inconsistencies and aspects of
their claim that they do not feel were
adequately addressed during the
interview are ameliorated by the IFR,
which does not contain the NPRM’s
restrictions on the introduction of new
testimony or documentary evidence.
Instead, the IFR incorporates
evidentiary standards consistent with
those in section 240 proceedings—
evidence must be relevant, probative,
and fundamentally fair, as described at
8 CFR 1240.17(g)(1). See INA
240(b)(4)(B), 8 U.S.C. 1229a(b)(4)(B)
(noncitizens must have a ‘‘reasonable
opportunity’’ to present evidence on
their behalf); 8 CFR 1240.7(a); see also
Nyama, 357 F.3d at 816 (‘‘The
traditional rules of evidence do not
apply to immigration proceedings . . . .
‘The sole test for admission of evidence
is whether the evidence is probative and
its admission is fundamentally fair.’ ’’
(quoting Espinoza, 45 F.3d at 310)).
Noncitizens may also request to provide
additional testimony where they believe
that it is necessary, as described above
in Section III of this preamble.
Comments: Commenters expressed
concerns that, by relying solely on the
record before the asylum officer, the
NPRM would effectively result in IJs
‘‘rubber-stamping’’ asylum officer
decisions without providing meaningful
review and oversight. Commenters
stated that full evidentiary hearings
before an IJ provide an essential check
on errors during the credible fear
interview and affirmative interview
processes.
Commenters stated that the NPRM
does not mandate that IJs have the same
obligations regarding evidence and the
record that are set forth in the INA for
section 240 proceedings, such as an
obligation to ‘‘administer oaths, receive
evidence, and interrogate, examine, and
cross-examine the [noncitizen] and any
witnesses.’’ INA 240(b)(1), 8 U.S.C.
1229a(b)(1). Instead, commenters stated
that the NPRM would create a
presumption against holding
immigration court hearings and against
the presentation of additional evidence
or testimony. Commenters were
concerned that, as a result, IJs would
pretermit claims and affirm decisions
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not granting asylum without first
conducting a hearing in person.
Commenters urged that a fuller review
is necessary to prevent a negative use of
the asylum officer’s increased authority
under the NPRM in the future.
Similarly, commenters also expressed
concern that future IJ performance
metrics could exacerbate these issues by
encouraging overly cursory reviews.
Response: As an initial matter, the
decision to place noncitizens whose
applications are adjudicated but not
granted by the asylum officer in
streamlined section 240 proceedings,
rather than the NPRM’s proposed IJ
review proceedings, addresses
commenters’ concerns that limited
proceedings would not allow for
meaningful review and oversight by the
IJ. In particular, the switch to
streamlined section 240 proceedings
will ensure that the IJ’s review is
meaningful and not a ‘‘rubber-stamp’’ of
the asylum officer’s decision. The
streamlined section 240 proceedings
established by the IFR will allow
noncitizens to submit additional
testimony or evidence, if they deem it
necessary, as described at new 8 CFR
1240.17(e), (f). Accordingly,
commenters’ concerns—that the IJ could
deny an application based solely on the
record before the asylum officer without
allowing the noncitizen to testify or
provide evidence—are no longer
applicable.
The Departments believe that the
procedures in this IFR also ameliorate
commenters’ concerns over statements
in the NPRM that IJs could decide
whether to accept additional evidence
or make a determination based solely on
the asylum officer’s record. In addition
to applying the statutory procedures
regarding evidence and maintenance of
the record set forth in section 240 of the
Act, 8 U.S.C. 1229a, the IFR permits
noncitizens to request to provide
additional testimony where necessary
and only permits the IJ to deny such
requests where the IJ concludes there is
sufficient evidence in the record to grant
the asylum application without hearing
additional testimony. The Departments
further believe that the detailed review
procedures set forth in the IFR alleviate
commenters’ concerns about IJs
adjudicating applications without
adequately reviewing asylum officer
decisions. Because the IFR ameliorates
the commenters’ concerns on these
points, the IFR also addresses the
commenters’ related concern that future
IJ performance metrics could exacerbate
these issues.81
81 EOIR no longer reviews IJ performance through
individual IJ performance metrics. IJs are held to
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Comments: Commenters disputed the
NPRM’s justification that the limited
review proceedings would increase
efficiency in the asylum adjudication
process. For example, commenters
stated that IJs would have to divert
resources from substantive
adjudications to address a large number
of motions or appeals resulting from
confusion over the requirement that the
applicant affirmatively request further IJ
review within a short time period.
Commenters suggested that this
provision may also spark litigation and
diversion of resources to correct
injustices that would otherwise lead the
United States to return refugees to
persecution, in violation of
nonrefoulement principles.
Commenters also remarked that the
NPRM did not adequately explain why
establishing an entirely separate process
through the Asylum Office and courts
would serve efficiency interests when
those same officials would continue to
be tasked with their current functions
and duties. Commenters said that the
Departments did not provide a
meaningful rationale for why a separate
procedure apart from section 240
proceedings was necessary to carry out
efficient, just results for asylum seekers.
Commenters suggested that it would be
more efficient to place all applicants in
section 240 proceedings, instead of the
NPRM’s IJ review procedure, because
the novel proceedings would give rise to
prolonged disputes about the
introduction of new evidence to
supplement the asylum officer’s record
or support prima facie eligibility for
alternative relief. Commenters argued
that motions that would increase under
the NPRM would include motions to file
additional evidence; motions to vacate
the limited asylum-, withholding-, and
CAT-only proceedings to pursue other
relief or protection; and the inevitable
cross-motions, motions to reconsider,
interlocutory appeals to the BIA,
motions to reopen, and petitions for
review by U.S. Courts of Appeals.
Commenters also asserted, generally,
that challenges to expedited removal
cases are already compounding the
backlog of cases.
high ethical standards, in part, to avoid impropriety
or the appearance of impropriety, which would
include deciding cases consistent with performance
metrics rather than applicable law and regulations.
See IJ Ethics and Professionalism Guide (providing
that IJs must be faithful to the law, maintain
professional competence in the law, act impartially,
and avoid actions that would create the appearance
that the IJ is violating the law or applicable ethical
standards); see also EOIR Policy Manual, Part II, ch.
1.3(c) (stating that IJs ‘‘strive to act honorably,
fairly, and in accordance with the highest ethical
standards’’).
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Response: The IFR addresses nearly
all of the commenters’ concerns by
providing that noncitizens whose
applications are adjudicated but not
granted by the asylum officer will now
be placed in streamlined proceedings
under section 240 of the Act, 8 U.S.C.
1229a.
The Departments emphasize that
section 240 proceedings are the default,
most common type of removal
proceeding. This familiar framework
safeguards due process interests by
ensuring that noncitizens have certain
rights and protections in such
proceedings. See INA 240(b)(4), 8 U.S.C.
1229a(b)(4). The Departments believe
that adhering to this statutory
framework, but establishing procedural
case-processing measures specific to
this category of cases, will further the
Departments’ efficiency interests
without undermining fairness in
proceedings. Further, noncitizens in
streamlined section 240 proceedings
may apply for other forms of relief or
protection without the need to first
submit a motion to the IJ to vacate the
asylum officer’s order of removal, which
would have been the case under the
NPRM at 8 CFR 1003.48(d) (proposed).
See 86 FR 46920. The IFR provides, at
new 8 CFR 1240.17(k)(2), that a
noncitizen will not be subject to the
streamlined procedures if the noncitizen
produces evidence of prima facie
eligibility and the noncitizen is seeking
to apply for, or has applied for, such
relief or protection other than asylum,
statutory withholding of removal,
withholding or deferral of removal
under the CAT, and voluntary
departure.
Comments: Commenters asserted that
the NPRM’s IJ review procedure would
violate the Act or is otherwise contrary
to congressional intent.
First, commenters asserted that the
Act requires that individuals in
expedited removal who seek review of
asylum officers’ decisions not to grant
asylum be placed in full section 240
removal proceedings. Commenters
further stated that none of the statutory
sections on which the NPRM relied
displaces the statutory presumption of
section 240 removal proceedings.
Commenters stated that nothing in the
Act suggests that Congress exempted
from section 240 removal proceedings
noncitizens seeking asylum who are
determined to have credible fear, or any
subset of that population.
Commenters argued that the
Departments’ statutory interpretation
erroneously rests on the negative
inference that section 235(b)(1) of the
Act, 8 U.S.C. 1225(b)(1), permits
proceedings other than section 240
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proceedings because that section does
not explicitly require section 240
proceedings, as compared with section
235(b)(2) of the Act, 8 U.S.C. 1225(b)(2),
which explicitly requires section 240
proceedings. Commenters asserted that
reading is erroneous because section
235(b)(1) of the Act, 8 U.S.C. 1225(b)(1),
establishes a general rule that applicants
for admission must be placed in section
240 removal proceedings. Commenters
believe that section 235(b)(2)(B)(ii) of
the Act, 8 U.S.C.1225(b)(2)(B)(ii), then
creates an exception to that automatic
entitlement for those defined as
‘‘arriving’’ in section 235(b)(1) of the
Act, 8 U.S.C. 1225(b)(1), because such
individuals are placed in expedited
removal. In sum, commenters generally
assert that DHS screens 8 U.S.C.
1225(b)(1) applicants to determine
which of the two statutorily established
methods of removal will apply:
Expedited removal for those without
credible fear, or standard removal
proceedings for those who establish
credible fear. Commenters asserted that
the statute has never been and cannot
now reasonably be understood to
exclude all (b)(1) applicants from a full
removal hearing once they are no longer
subject to the expedited removal
process.
Commenters also disputed the
Departments’ interpretation of section
235(b)(2)(A) of the Act, 8 U.S.C.
1225(b)(2)(A), and statement that
‘‘noncitizens whom DHS has elected to
process into the United States using the
expedited removal procedure are
expressly excluded from the class of
noncitizens who are statutorily
guaranteed section 240 removal
proceedings.’’ 86 FR 46917.
Commenters argue that a credible fear
screening creates an exit from expedited
removal proceedings, and, by design,
those who establish credible fear are no
longer subject to expedited removal.
Thus, commenters concluded, the
Departments’ view that people seeking
asylum can be forced into lesser
proceedings in immigration court is
contrary to law.
Commenters also believe that the
legislative history of expedited removal
demonstrates that Congress intended for
all noncitizens found to possess a
credible fear of persecution or torture to
be afforded section 240 proceedings.
Commenters stated that, in drafting the
asylum statute and significantly
amending the Act through IIRIRA, it is
clear that Congress contemplated that
asylum seekers would be afforded an
opportunity to defend against
deportation before an IJ in full section
240 proceedings, which include various
procedural and due process safeguards.
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Specifically, commenters cited the
congressional record in support of their
position. See, e.g., 142 Cong. Rec. S4461
(1996) (statement of Sen. Alan Simpson)
(‘‘[T]he bill provides very clearly an
opportunity for every single person[,
even those] without documents, or with
fraudulent documents . . . to seek
asylum.’’).
Commenters further argued that
IIRIRA includes three levels of
screening to ensure that asylum seekers
are clearly identified so that genuine
asylum seekers are not subject to the
expedited procedures that apply to nonasylum seekers. In support, commenters
referenced statements by the chief
drafters of the law explaining that
asylum seekers can be ordered removed
only after full section 240 proceedings
where they can submit evidence, call
witnesses, and testify. See, e.g., 142
Cong. Rec. S4492 (1996) (statement of
Sen. Alan Simpson) (‘‘If [asylum
seekers] have credible fear, they get a
full hearing without any question.’’).
Commenters also suggested that other
provisions in the Act demonstrate
congressional intent to place such
applicants in section 240 removal
proceedings. For example, commenters
stated that at the same time Congress
enacted expedited removal, Congress
gave asylum seekers a full year to
submit an initial application in
recognition that asylum cases take time
to prepare. Accordingly, commenters
said that the NPRM contravened
congressional intent by precluding
access to section 240 removal
proceedings for applicants not granted
asylum following a positive credible
fear interview.
On the other hand, some commenters
objected to the NPRM on the basis that
it would extend the credible fear and
review process further than Congress
intended. Specifically, these
commenters asserted that the additional
review by the asylum officers and
within USCIS undermined
congressional intent for the expedited
removal process to be truly expedited.
In support, commenters cited Congress’s
statutory scheme to limit the
administrative review of expedited
removal orders and limit judicial review
of determinations made during the
expedited removal process. See INA
242, 8 U.S.C. 1252. Commenters
concluded that creating additional
levels of review would slow the credible
fear process, waste administrative
resources, and run counter to Congress’s
legislative aims.
Commenters stated that the
restrictions on IJs in the NPRM’s limited
proceedings would conflict with the IJ’s
role to develop the record before the
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court. Commenters stated that the Act
and its implementing regulations
require IJs to take an active role in
section 240 removal proceedings to
develop the record and ensure that
applicants are advised of the nature of
the proceedings, as well as their rights
and responsibilities therein. See, e.g.,
Abdurakhmanov v. Holder, 735 F.3d
341, 346 n.4 (6th Cir. 2012) (‘‘An IJ has
. . . an obligation[ ] to ask questions of
the [noncitizen] during the hearing to
establish a full record . . . . [The
questioning] should be designed to elicit
testimony relevant to the fair resolution
of the [noncitizen’s] applications.’’);
Toure v. Att’y Gen., 443 F.3d 310, 325
(3d Cir. 2006) (‘‘[A]n IJ has a duty to
develop an applicant’s testimony,
especially regarding an issue that she
may find dispositive . . . .’’ (citing
Matter of S–M–J–, 21 I&N Dec. at 723–
26)). Commenters stated that this duty
differentiates IJs from Article III judges
but is consistent with other types of
administrative proceedings.
Commenters explained that in the
immigration context, courts have
recognized that unique features of
immigration court proceedings require
IJs to fill this role to ensure fair and
accurate adjudications.
In addition, commenters stated that
the NPRM’s IJ review procedure would
conflict with the United States’
international obligations, including
nonrefoulement, because it would
diminish the significance of
immigration court review as a safeguard.
On the other hand, commenters stated
that the protections afforded to
applicants in section 240 proceedings
comport with UNHCR guidance
emphasizing that the asylum
adjudicator’s role is to ‘‘ensure that the
applicant presents his case as fully as
possible and with all available
evidence.’’ See UNHCR, Handbook on
Procedures and Criteria for Determining
Refugee Status ¶ 205(b)(1) (2019),
https://www.unhcr.org/en-us/
publications/legal/5ddfcdc47/
handbook-procedures-criteriadetermining-refugee-status-under-1951convention.html (last visited Mar. 5,
2022). Commenters also expressed
concerns that the NPRM would
effectively penalize asylum seekers
based on their manner of entry—in
violation of Article 31 of the Refugee
Convention—as the NPRM would apply
only to persons who have sought
asylum at or after recently crossing the
border.
Response: The Departments have
considered commenters’ concerns that
the NPRM’s proposal that noncitizens
not granted asylum by the asylum
officer would immediately be ordered
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removed, with the opportunity to seek
IJ review through a newly created
proceeding, would violate congressional
intent, the Act, and international
obligations. Through this IFR,
noncitizens not granted asylum by the
asylum officer instead will be referred to
streamlined section 240 proceedings
before an IJ. While the Departments are
establishing procedural steps to ensure
the efficient disposition of these cases,
noncitizens in streamlined section 240
proceedings established by the IFR are
entitled to the same general rights and
protections as noncitizens in section
240 proceedings. See, e.g., INA
240(b)(4), 8 U.S.C. 1229a(b)(4) (setting
forth noncitizens’ rights in proceedings).
This shift generally resolves the
commenters’ concerns on these points
by returning to the use of section 240
proceedings and affirming the role of
the IJ as the adjudicator, while still
ensuring that the proceedings are
completed expeditiously.
The Departments disagree, however,
with commenters’ argument that the
NPRM violates congressional intent to
create an efficient expedited removal
process by proposing an additional layer
of adjudication and review by the
asylum officer. Specifically, the
Departments believe that the
commenters’ concerns erroneously
conflate expedited removal of
noncitizens who have not demonstrated
a credible fear of persecution or torture
with the separate process that occurs for
noncitizens who have established a
credible fear of persecution or torture.
The Act makes clear that most
noncitizens who are arriving in the
United States, if inadmissible under
certain provisions of the Act, will be
removed ‘‘without further hearing or
review.’’ INA 235(b)(1)(A)(i), 8 U.S.C.
1225(b)(1)(A)(i). The Act carves out one
exception to this general rule: If the
noncitizen indicates a fear of
persecution or torture or an intention to
apply for asylum, rather than face
immediate removal, the noncitizen will
instead be interviewed by an asylum
officer to determine whether the
noncitizen has a credible fear of
persecution. INA 235(b)(1)(A)(ii), 8
U.S.C. 1225(b)(1)(A)(ii). If, during the
interview, the noncitizen does not
demonstrate a credible fear, the Act
again calls for the noncitizen’s
immediate removal ‘‘without further
hearing or review.’’ INA
235(b)(1)(B)(iii)(I), 8 U.S.C.
1225(b)(1)(B)(iii)(I).82 This IFR does not
82 Although the Act states that, under these
circumstances, the noncitizen will be removed
without further hearing or review, the Act also
provides for a very limited IJ review of the asylum
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make any significant changes to the
implementing regulations for these
statutory provisions.
Although the initial screening process
is intended to be expedited, once a
noncitizen is determined to have a
credible fear of persecution or torture,
the Act no longer calls for the
noncitizen’s removal without further
hearing or review. Rather, it establishes
that the noncitizen’s application for
asylum shall be given ‘‘further
consideration.’’ INA 235(b)(1)(B)(ii), 8
U.S.C. 1225(b)(1)(B)(ii).83 The Act does
not specify the contours of or the
appropriate speed at which such further
consideration should occur before a
noncitizen receives a final adjudication.
The Departments believe that the
‘‘further consideration’’ directed by
Congress reasonably encompasses
establishing a procedure under which
an asylum officer adjudicates the
asylum application in the first instance
and, if the application is not granted,
refers the noncitizen to streamlined
section 240 proceedings. The
Departments believe that this procedure
will be more efficient than the current
lengthy process in which noncitizens
are referred directly to section 240
proceedings, both because cases that can
readily be granted by the asylum officer
will be removed from the docket, and
because cases referred to the
immigration court will arrive in
immigration court with the benefit of a
record assembled by the asylum officer
that enables these section 240
proceedings to be substantially
streamlined, as outlined above in
Section III of this preamble.
Commenters’ references to provisions
of the Act that limit judicial review of
decisions made during the initial
screening process—i.e., whether there is
expressed or established credible fear of
persecution or torture—are inapposite
because those provisions only limit
judicial review of decisions made
during that initial screening process.
The Departments’ view is that Congress
did not eliminate or limit judicial
review in cases involving noncitizens
determined to have credible fear just
because they were initially screened as
possible candidates for expedited
removal. See Thuraissigiam, 140 S. Ct.
at 1965 (‘‘Applicants can avoid
officer’s determination that the noncitizen does not
have a credible fear of persecution or torture. INA
235(b)(1)(B)(iii)(III), 8 U.S.C. 1225(b)(1)(B)(iii)(III).
The IJ’s decision reviewing the asylum officer’s
credible fear determination is final and not subject
to reconsideration or appeal. 8 CFR
1208.30(g)(2)(iv)(A).
83 For further discussion regarding the legal
authority for the NPRM, see Section II.B of this
preamble.
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expedited removal by claiming asylum
. . . . If the asylum officer finds an
applicant’s asserted fear to be credible,
the applicant will receive ‘full
consideration’ of his asylum claim in a
standard removal hearing.’’ (footnotes
omitted)).
Comments: Commenters emphasized
the importance of judicial review for
adjudicating applications for asylum or
protection, particularly for marginalized
groups, and expressed concern that the
NPRM would not sufficiently protect
the right to judicial review.
Commenters suggested placing
applicants whose claims are adjudicated
but not granted by an asylum officer in
section 240 proceedings rather than a
new proceeding to ensure judicial
review and avoid potential future
litigation about the Federal courts’
jurisdiction over these cases. While
commenters primarily advocated for
section 240 proceedings, they also
recommended additional ways to
improve the NPRM’s proceedings to
ensure adequate judicial review, such
as, for example, amending the rule so
that the IJ, not the asylum officer, would
issue a removal order. The noncitizen
could then appeal the IJ’s decision to
the BIA and seek judicial review of the
BIA’s decision.
In contrast, other commenters
disagreed that further changes are
needed to protect judicial review and
emphasized that the NPRM does not
alter any current safeguards for
individuals seeking asylum or
protection. The commenters reiterated
that those who are not granted asylum,
withholding of removal, or protection
under the CAT by an asylum officer
would still have the option to have their
cases heard by the immigration court,
which would be a second level of
review.
Response: The Departments agree
with commenters that the Departments’
procedures must ensure the right to
judicial review of adjudications of
applications for asylum or protection.
Judicial review ensures fairness and
accuracy in immigration proceedings,
and Congress specifically sought to
ensure review remained available for
asylum applications while otherwise
limiting review over other types of
decisions. See INA 242(a)(2)(B)(ii), 8
U.S.C. 1252(a)(2)(B)(ii) (Congress
limiting judicial review of agency
decisions regarding discretionary forms
of relief ‘‘other than the granting of
relief under [INA 208(a),] section
1158(a) of this title.’’).
Regarding commenters’ concerns that
the procedure proposed in the NPRM
might not allow for further judicial
review, the Departments disagree with
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that view and, in any case, emphasize
that the process has been revised as
described above in Section III of this
preamble so that noncitizens whose
applications are adjudicated but not
granted by the asylum officer will be
issued an NTA and placed in
streamlined section 240 proceedings. As
with all section 240 removal
proceedings, a noncitizen may first
appeal the IJ’s decision to the BIA, 8
CFR 1240.15, and then appeal the BIA’s
decision to a Federal circuit court, INA
242, 8 U.S.C. 1252. In addition, under
the IFR, the IJ issues the removal order,
if applicable, rather than the asylum
officer, consistent with some
commenters’ suggestions. The changes
under this IFR demonstrate the
Departments’ continued commitment to
fair adjudications, and address
commenters’ concerns regarding the
need to ensure the availability of
judicial review.
The Departments are committed to
maintaining longstanding procedural
protections inherent in section 240
proceedings for noncitizens subject to
the expedited removal process and
subsequently determined to have a
credible fear of persecution or torture.
The Departments acknowledge that
some commenters supported the
NPRM’s approach, and the Departments
believe that the IFR will maintain the
efficiencies and benefits provided for in
the NPRM through the implementation
of the new streamlined 240 removal
proceedings.
b. De Novo Review of Full Asylum
Hearing Record and Consideration of
Additional Testimony and Evidence
Comments: Commenters disputed the
NPRM’s characterization of the
proposed IJ review proceedings as ‘‘de
novo,’’ stated that use of the term ‘‘de
novo’’ is ‘‘paradoxical’’ and
‘‘misleading,’’ and said that the
proposed IJ review process may violate
asylum seekers’ due process rights.
Commenters said that any standard of
review other than a true de novo review
would be inconsistent with the
challenges associated with the effects of
trauma, gathering evidence, and the
asylum officers’ previous role in
granting or referring cases, not denying
applications for asylum.
Commenters stated that, while 8 CFR
1003.48(e) as proposed in the NPRM
referred to the review by the IJ as ‘‘de
novo,’’ the use of the phrase ‘‘de novo’’
appears to be misplaced. Commenters
further stated that the current review
proceedings for affirmative asylum
applicants referred to immigration
court, in which the IJ holds a new
hearing and issues a decision
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independent from the asylum officer,
are considered de novo review. On the
other hand, commenters noted that,
while the NPRM calls the new
proceedings de novo, the IJ would not
be required to conduct a new hearing
independent of the asylum officer’s
decision. The commenters said a ‘‘de
novo’’ hearing would typically treat a
case as if it were being heard for the first
time, but the NPRM limits the scope of
‘‘de novo’’ hearings by imposing
evidentiary restrictions and limiting the
IJ review to the transcript of the
interview. Similarly, commenters also
opposed the NPRM’s use of the term
‘‘shall’’ when directing the IJ to review
the asylum officer’s decision and use of
the term ‘‘may’’ when directing the IJ to
consider additional evidence.
Commenters explained that such terms
impute an improper deference to the
asylum officer’s decision and limit the
applicant’s ability to supplement the
record.
At least one commenter expressed
concern that the IJ’s review of the
asylum officer’s decision would become
similar to IJ review of asylum officers’
credible fear interview decisions, which
commenters disputed was a de novo
review.
Response: First, the Departments
clarify that de novo review is a ‘‘court’s
nondeferential review of an
administrative decision, usu[ally]
through a review of the administrative
record plus any additional evidence the
parties present.’’ Review, de novo
review, Black’s Law Dictionary (11th ed.
2019). De novo review does not mean,
as some commenters suggested, that
proceedings must begin anew without
reference to the underlying decision
(indeed, this construction would
undermine the entire concept of a
review) or with unlimited opportunities
to submit new record evidence. Id.
(‘‘[N]ondeferential review of an
administrative decision’’ usually
involves review of the ‘‘administrative
record’’ and ‘‘additional evidence’’
presented by the parties.).
For example, the BIA conducts de
novo review of legal questions, even
though it generally may not consider
new record evidence. See 8 CFR
1003.1(d)(3)(ii) (‘‘The Board may review
questions of law, discretion, and
judgment and all other issues in appeals
from decisions of immigration judges de
novo.’’). The de novo review standard
permits the BIA to draw legal
conclusions without deference to the IJ’s
decision, based upon the record before
it. By contrast, the BIA may only
overturn an IJ’s finding of fact where,
based upon the existing record, the IJ’s
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finding was ‘‘clearly erroneous.’’ See 8
CFR 1003.1(d)(3)(i).
In sum, the distinction between de
novo review and other standards of
review, such as clear error, is not based
upon whether parties may submit
additional record evidence, but rather
how much deference the adjudicator
must give to the underlying
determinations based upon the existing
record evidence. Accordingly,
commenters’ implications that a
credible fear review under 8 CFR
1208.30(g) is not a de novo review are
inaccurate. De novo review is a widely
used standard of review in immigration
proceedings and, under the IFR, IJs will
conduct de novo review of asylum
officer decisions as described at new 8
CFR 1240.17(i).
Second, the Departments emphasize
that commenters’ concerns regarding the
submission of evidence under the
NPRM are ameliorated by the IFR’s shift
from the limited review proceedings to
streamlined 240 proceedings as
discussed above in Section III of this
preamble. Specifically, under the IFR,
either party may submit record evidence
and request to present testimony,
pursuant to new 8 CFR 1240.17(f)(2)(i)
and (ii). The IFR directs IJs to review an
asylum officer’s decision de novo, see
new 8 CFR 1240.17(i), and the
admission of evidence is governed by an
evidentiary standard consistent with
that currently used in section 240
proceedings. Given the shift to that
evidentiary standard, the IFR does not
contain the language stating that the IJ
‘‘may’’ accept additional evidence.
Comments: Multiple commenters
expressed due process concerns
associated with the NPRM’s proposed
de novo review proceedings before an IJ,
in particular with the limitations that
any additional testimony or
documentation reviewed by the IJ must
be ‘‘necessary’’ and ‘‘not duplicative.’’
Overall, commenters stated that the
NPRM seemed to eliminate or dilute
longstanding procedural rights that
noncitizens have had in section 240
removal proceedings. Commenters
stated that the NPRM would deprive
many asylum seekers of a meaningful
opportunity to present their full story
because a full examination would not
occur before asylum officers, and
evidentiary hearings before an IJ would
generally be foreclosed. Commenters
explained that this outcome is
particularly inappropriate in situations
where an IJ denies an application on the
basis of an adverse credibility finding.
Some commenters stated that the
Departments appeared to contemplate
that the asylum seeker would not ever
appear before the IJ in most cases
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because the IJ would simply issue a
decision based on the IJ’s review of the
asylum officer’s record. Commenters
compared this alleged limitation to
EOIR’s Case Flow Processing policy,
which commenters stated limits master
calendar hearings. Commenters
explained that this hearing limitation
essentially gives the IJ an appellate
review role but deprives the asylum
seeker’s counsel from providing briefing
to the IJ. One commenter stated that
depriving asylum seekers of an
evidentiary hearing would be ‘‘overkill’’
because the new proceedings outside of
section 240 proceedings already would
save significant time for IJs by
narrowing the legal issues to be decided
and shrinking the scope of relief or
protection.
Commenters stated that the nature of
the hearings before the IJ would
exacerbate rather than correct issues
that may arise in the proceedings before
the asylum officer because the hearing
before the IJ is one in which the IJ
reviews the record already created by
USCIS. For example, commenters
claimed the record would be sparse and
unlikely to reflect a full accounting of
the harm, persecution, or torture the
asylum seeker experienced.
Commenters alleged that the cumulative
effect of this limitation as well as the
evidentiary limitation would be to
extend summary removal from the stage
of threshold contact through the period
when the claim is disposed of on the
merits. At a minimum, commenters
urged that the NPRM be revised to
permit the taking of fresh testimony and
the submission of new evidence to the
IJ upon a proper showing.
Further, commenters disputed that
the NPRM’s proposed procedure would
result in a ‘‘complete’’ record. One
commenter alleged that the proposed
nonadversarial procedures would
relegate attorneys to ‘‘passive observer
status’’ and prevent them from
developing ‘‘critical elements’’ of a
record, usually developed through
presenting testimony, calling witnesses,
or submitting documentary evidence.
Also, regarding the evidentiary rules
in the application review proceedings
before the IJ, commenters said it is
unclear whether an IJ would be required
to give notice and an opportunity to
provide additional evidence before
summarily affirming the asylum
officer’s decision. Commenters said the
Ninth Circuit has long held that the IJ
must give the asylum applicant notice of
the evidence required and an
opportunity to provide it if the IJ
believes further corroborating evidence
is required to support an otherwise
credible application. However, the
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commenters continued, there is no
similar process for asylum interviews,
which generally occur in one day, with
all evidence required to be submitted
prior to the interview.
Commenters said that IJs would need
additional training in order to preserve
fairness and due process, given the
distinct nature of reviewing interview
transcripts. Commenters expressed
concern that the NPRM did not
adequately consider what this training
may involve, but commenters urged the
Departments to develop this training
before enacting a final rule.
Commenters said it is reasonable to
expect that many asylum seekers would
want to provide supplemental evidence
and recommended that the Departments
provide further assurances that asylum
seekers would be able to do so and are
entitled to a comprehensive review of
their case before an IJ.
To comport with due process and
minimize the risk of refoulement,
commenters asserted that the NPRM
should prohibit pretermission by IJs
based solely on the asylum officer’s
record and should instead specify a
presumption of admissibility of new
evidence and eliminate the requirement
that parties must file motions to
supplement the record.
Response: As described above, the
Departments have decided to refer all
noncitizens whose applications are
adjudicated but not granted by the
asylum officer to streamlined section
240 removal proceedings rather than
implementing the IJ review procedure
proposed in the NPRM. As part of the
streamlined section 240 removal
proceedings, the Departments are not
proposing to apply a novel evidentiary
standard, and, instead, will adopt an
evidentiary standard consistent with
that used in section 240 removal
proceedings. Parties to proceedings are
familiar with this standard, and IJs have
experience in its application. Further,
while streamlined section 240 removal
proceedings under this IFR include
certain procedural requirements to
maintain the expedited nature of the
overall process, noncitizens will be
assured the longstanding due process
rights inherent in section 240 removal
proceedings.
The Departments emphasize that this
decision not to adopt the NPRM’s
proposed evidentiary restrictions will
not reduce the efficiencies the
Departments sought in the NPRM. In
fact, as previously explained, the
Departments believe that the IFR’s
streamlined section 240 removal
proceedings will be equally as effective
as the NPRM’s proposed IJ review
proceedings in enhancing efficient
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adjudication and replacing timeconsuming evidentiary hearings. For
example, the IFR provides that the
asylum officer’s record will be
automatically transmitted upon DHS’s
issuance of an NTA, which will
expedite the parties’ ability to narrow
the issues and assist the IJ’s review of
the case. The IFR also provides that if
neither party requests to present
testimony, or if the IJ determines that
the asylum application can be granted
without hearing testimony, and DHS
does not request to present evidence or
witnesses or to cross-examine the
noncitizen, the IJ can decide the case
without a hearing. The IFR also
provides various deadlines and
procedural measures to ensure efficient
processing that preclude the need to
conduct a full evidentiary hearing or
otherwise facilitate a more efficient
hearing.
The Departments disagree with
commenters that noncitizens will be
deprived a meaningful opportunity to
present their claims to asylum officers.
Asylum officers conduct interviews
with the purpose of ‘‘elicit[ing] all
relevant and useful information bearing
on the applicant’s eligibility for
asylum.’’ 8 CFR 208.9(b). Asylum
officers receive specialized training and
information in order to carry out their
duties with professionalism and
competence. See 8 CFR 208.1(b).
Asylum officers have experience with
(and receive extensive training on)
eliciting testimony from applicants and
witnesses, engaging with counsel, and
providing applicants the opportunity to
present, in their own words,
information bearing on eligibility for
asylum. As described in the NPRM,
asylum officers will ‘‘develop[ ] and
consider[ ] the noncitizen’s claim fully,
including by taking testimony and
accepting evidence, during the
nonadversarial proceeding.’’ 86 FR
46918. Asylum officers also are trained
to give applicants the opportunity to
provide additional information that may
not already be in the record so that the
asylum officer has a complete
understanding of the events that form
the basis for the application. Thus, the
hearing before the asylum officer
functions as an evidentiary hearing, as
the applicant is required to ‘‘provide
complete information regarding the
applicant’s identity, including name,
date and place of birth, and nationality,
and may be required to register this
identity.’’ 8 CFR 208.9(b). Further, the
noncitizen may have counsel or a
representative present, present
witnesses, and submit affidavits of
witnesses and other evidence. Id.
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Noncitizens who are placed in the new
process established by this IFR will
have multiple opportunities to provide
information relevant to their claims
before USCIS asylum officers in
nonadversarial settings, and at different
stages will have the opportunity for an
IJ to review or consider their asylum
claim de novo.
Further, the Departments disagree
with commenters that IJs need special
training to review transcripts. IJs
regularly review hearing notes and
records from USCIS, transcripts of
hearings that indicate a criminal
conviction, and transcripts of oral
decisions that are appealed to the BIA.
See, e.g., 8 CFR 1003.5(a) (transcripts for
the BIA); 8 CFR 1003.41(a)(4) (criminal
hearing transcripts); see also EOIR
Policy Manual, Part VIII, Ch. VIII.3.A:
Uniform Docketing System Manual
(providing process under which IJs must
review oral decisions and transcripts
through eTranscription); Operating
Policies and Procedures Memorandum
(‘‘OPPM’’) 84–9: Processing Hearing
Transcriptions (Oct. 17, 1984)
(transcripts from USCIS). In light of
established DOJ guidance, as well as the
general presumption of administrative
regularity, the Departments are
confident that IJs will continue their
work with professionalism and
competency. See Chem. Found., 272
U.S. at 14–15; see also IJ Ethics and
Professionalism Guide.
Regarding comments on
pretermission—that is, the practice of
denying applications on the papers
without hearing an applicant’s
testimony because the IJ concludes that
the applicant has not made a prima facie
case for the relief or protection sought—
to the extent that commenters refer to
pretermission of asylum applications
under the separate Global Asylum rule,
that rule is currently enjoined.84 The
NPRM and this IFR do not rely on or
involve that rule’s discussion of
pretermission of asylum applications. If
commenters are alleging that the
NPRM’s IJ review proceedings would
effectively result in pretermission, the
Departments disagree but emphasize
that, as described above in Section III of
this preamble, this IFR revises the
NPRM to provide streamlined section
240 proceedings with certain procedural
requirements in new 8 CFR 1240.17 that
include, in part, the submission of
additional evidence. In addition, as
provided in new 8 CFR 1240.17(f)(4)(i)–
(ii), an IJ may not determine the
noncitizen’s eligibility for relief in these
proceedings without a hearing unless
84 See supra note 4 (discussing recent regulations
and their current status).
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the noncitizen does not wish to testify
or the IJ determines that the application
can be granted. Accordingly, the
Departments find that commenters’
concerns with pretermission under the
Global Asylum rule, which would have
allowed an IJ to pretermit and deny an
application, are addressed by the
procedures set out in the IFR. The IFR
does not disturb the evidentiary
standard applicable in section 240
removal proceedings.
Comments: One commenter stated
that the criteria for a noncitizen to
supplement the record before the IJ—
whether evidence is ‘‘duplicative’’ or
‘‘necessary’’—is a ‘‘fuzzy concept’’ and
others argued that the standard may
implicate due process violations or
cause delay. Commenters urged the
Departments to describe clearly what
evidence and testimony is ‘‘necessary’’
and ‘‘not duplicative’’ to develop the
factual record and to specify that the
threshold to meet these standards is
low.
For example, one commenter
explained that ‘‘duplicative’’ can mean
‘‘effectively identical,’’ and it can mean
‘‘involving duplication’’ to some lesser
degree. In the latter sense, the
commenter explained that it means
‘‘unnecessarily doubled or repeated,’’
which would likely be subjective. The
commenter said the NPRM provides no
basis for determining what is
‘‘duplicative.’’
Likewise, commenters stated that the
NPRM provides no guidance on what
new testimony or documentation may
be ‘‘necessary.’’ For example, one
commenter stated that much evidence
that is relevant or critical can be seen as
not ‘‘necessary’’ to ‘‘a reasoned
decision.’’ Moreover, commenters
alleged that a strict reading of the
‘‘necessity’’ requirement could be
mandated by future decisions of the
Attorneys General and would turn IJs
into reviewers of a record created by the
asylum officer. Thus, commenters
explained, the NPRM threatens to turn
an immigration court proceeding in this
context into one that is adversarial in
name only, with a concomitant loss of
faith in the integrity of the process.
Commenters stated that, given that the
rules of evidence do not apply in
immigration court, the interpretation of
the evidentiary standards would be left
to each individual IJ. Commenters stated
that, based on their experience, IJs
would have widely different
interpretations, leading to inconsistent
application and confusion among
applicants and counsel. Other
commenters explained that the NPRM
creates a new, unknown standard in
immigration court proceedings rather
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than relying on the longstanding
discretionary authority of IJs to conduct
and control the nature of the
proceedings. One commenter found
‘‘enormous discrepancies’’ among IJs’
handling of discretionary motions.
At least one commenter alleged that
many courts along the Southwest border
would be antagonistic to a discretionary
motion like that contemplated by the
NPRM. The commenter said the
pressure, volume of cases, and speed
required of IJs along the border make it
far less likely that the IJs would look
upon these motions favorably.
Commenters stated that pro se
individuals, in particular, may hesitate
to submit additional evidence out of fear
that it will be rejected as duplicative or
unnecessary.
Commenters stated that the NPRM
lacked guidance for adjudicators on
these terms and would lead to further
delay because the parties would litigate
the issue of admissibility of evidence.
Commenters further stated that this
litigation would also make judicial
review of the determination to exclude
evidence virtually impossible.
Commenters stated that the NPRM
does not specify what an asylum
officer’s decision must contain, such
that an incomplete or undeveloped
asylum application record might pass
muster at the IJ level. One commenter
stated that it is unclear how IJs ‘‘will
explain in court the standards for
submitting additional testimony and
documentation’’ if IJs merely conduct a
paper review ‘‘solely on the basis of the
record before the asylum officer.’’ Thus,
commenters urged the Departments to
specify when and how IJs would
provide this explanation to noncitizens
and mandate that the IJ explain the
standard in all cases, rather than on a
discretionary basis.
Response: As described above in
Section III of this preamble, the
Departments have decided to refer
noncitizens whose applications for
asylum are not granted by the asylum
officer to streamlined section 240
removal proceedings rather than
implementing the IJ review proceedings
proposed in the NPRM. As part of the
streamlined section 240 proceedings,
the Departments are no longer
proposing to apply the NPRM’s
evidentiary standard, but, instead, as
provided in new 8 CFR 1240.17(g)(1),
will apply an evidentiary standard
consistent with that applied in section
240 proceedings. See 8 CFR 1240.7(a);
see also Matter of D–R–, 25 I&N Dec.
445, 458 (BIA 2011) (‘‘In immigration
proceedings, the sole test for admission
of evidence is whether the evidence is
probative and its admission is
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fundamentally fair.’’ (quotation marks
and citation omitted)); Matter of
Interiano-Rosa, 25 I&N Dec. 264, 265
(BIA 2010) (‘‘[IJs] have broad discretion
to conduct and control immigration
proceedings and to admit and consider
relevant and probative evidence.’’).
Parties to proceedings are familiar
with this standard, and IJs have
experience in its application.
Accordingly, the Departments find that
this change addresses commenters’
concerns with the NPRM’s evidentiary
standard, including the potential for its
inconsistent application, negative
impacts on pro se individuals, the need
for corresponding guidance for
adjudicators, and the need for clarity
regarding how noncitizens would be
informed of the new standard. The IFR
does not disturb the current evidentiary
standard for section 240 removal
proceedings.
Nevertheless, in response to
commenters’ concerns about IJs’
inconsistent application of evidentiary
standards and discretionary motions
determinations, the Departments
emphasize that IJs exercise independent
judgment and discretion in adjudicating
cases before them. See 8 CFR
1003.10(b); see generally IJ Ethics and
Professionalism Guide (requiring IJs to,
inter alia, be faithful to the law,
maintain professional competence in
the law, act impartially, and avoid
actions that would create the
appearance of violations of the law or
applicable ethical standards). IJs will
continue to interpret and apply
applicable law and regulations,
regardless of geographic location or
caseload.
In response to comments that the
NPRM could result in the adjudication
of allegedly incomplete or undeveloped
asylum applications, the Departments
first emphasize that asylum officers
receive thorough training and regularly
adjudicate affirmative applications for
asylum. See 8 CFR 208.1(b), 208.14.
Every case presents a unique set of facts,
but asylum officers are trained to elicit
‘‘all relevant and useful information
bearing on whether the [noncitizen] can
establish credible fear’’ of persecution or
a reasonable possibility of torture during
the interview, which forms the basis of
the decision. 8 CFR 208.30(d). Under
the IFR in new 8 CFR 1240.17(c),
asylum officers also provide numerous
documents to the IJ. Also, under the
IFR, in credible fear determinations, the
asylum officer must provide to the IJ a
written record of the determination,
including copies of the asylum officer’s
notes, a summary of the material facts
as stated by the applicant, any
additional facts relied on by the asylum
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officer, and the asylum officer’s
determination of whether, in light of
such facts, the noncitizen established a
credible fear of persecution or torture. 8
CFR 208.30(e)(1), (f), (g). Under new 8
CFR 1240.17(c) and (e), and 8 CFR
208.9(f), from the Asylum Merits
interviews, the asylum officer must
provide to the IJ all supporting
information provided by the noncitizen,
any comments submitted by the
Department of State or DHS, any other
unclassified information considered by
the asylum officer in the written
decision, and a verbatim transcript of
the interview. Notwithstanding these
requirements, under the IFR in new 8
CFR 1240.17(f)(2)(i)(A), and (g), the
noncitizen may submit additional
evidence or testimony, consistent with
the applicable evidentiary standard, to
supplement the record during any
subsequent IJ review. Considering all
this information, the Departments
disagree with the assertion that an IJ
would make a decision based on an
‘‘incomplete’’ or ‘‘undeveloped’’ record,
as commenters alleged.
Comments: Multiple commenters said
that the NPRM’s process and
evidentiary standards would allow IJs to
review an interview transcript and
concur with asylum officers’ decisions
to not grant asylum with little due
process (so-called ‘‘rubber-stamping’’)
and without meaningful participation
by asylum seekers’ counsel.
Commenters alleged that the
requirement that litigants make an
initial showing that evidence is new and
not duplicative would allow IJs to
‘‘rubber-stamp’’ the asylum officer’s
negative determination. One commenter
was especially concerned that the IJ
decisions would be based on ‘‘severely
truncated hearings,’’ where asylum
seekers do not have a right to counsel,
are not allowed to present testimony or
evidence, and where asylum officers
take often incomplete and incorrect
notes. Commenters stated that the
NPRM contained no provision by which
an applicant may challenge a negative
decision by the IJ to exclude additional
evidence, which could lead to a
‘‘rubber-stamp’’ of the underlying
asylum officer’s decision to not grant
asylum. Similarly, one commenter said
that the NPRM would essentially allow
the alleged current ‘‘disturbing practice’’
of IJs ‘‘rubber stamping’’ credible fear
reviews to ‘‘bleed over’’ into the merits
process.
Commenters stated that if the IJ
listened to the recording of the
interview before the asylum officer
rather than waiting for a transcript of
the interview, the entire process could
be completed within a few days or
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weeks of the asylum seeker’s arrival in
the United States, similar to other
procedures under the prior
Administration. Some commenters
alleged that nothing in the NPRM would
require an IJ who rejects testimony or
other evidence to give a reasoned
explanation for that decision, which
could allow IJs who may have a
propensity to deny claims the
procedural opportunity to do so.
Commenters said that IJs would have
little incentive under the NPRM to
permit inclusion of additional evidence
and may opt to exclude evidence if
there are any indicia that the facts were
already in the administrative record.
Commenters remarked that, as the
NPRM acknowledges, IJs are
overburdened with overflowing dockets.
As a result, commenters argued, IJs
would be inclined to deny requests for
submission of additional evidence or
testimony on even a vague finding that
the submissions would be duplicative or
unnecessary. One commenter said the
NPRM would thus perpetuate what the
commenter characterized as the
deterioration of the immigration court
system as a ‘‘rubber-stamping tool’’ for
removal orders issued by DHS and
upend the purpose of the courts.
Commenters stated that applicants
with additional evidence should not be
hindered by evidentiary limitations,
especially given that, as alleged by
commenters, case completion quotas
provide IJs with incentives to adjudicate
claims as quickly as possible. Likewise,
commenters said that IJ performance
metrics compound concerns that IJs
would have a disincentive to find a
need for evidentiary hearings when
asylum cases are not granted.
Commenters said the performance
metrics are deeply problematic because
they create financial incentives for IJs to
prize speed over fairness. Commenters
stated that over 40 percent of IJs have
been on the bench for fewer than five
years, and many have backgrounds in
criminal prosecution or the military and
need to learn the increasingly complex
procedural and substantive immigration
rules on the job. The commenters said
these relatively new IJs would be placed
in a role of appellate review of decisions
rendered by asylum officers who also
will have been newly hired. This
combination of fewer due process rights
in eliciting testimony by new asylum
officers with appellate-type review by
relatively new IJs would not provide
adequate protection to asylum seekers.
Commenters stated that some IJs
depart markedly from the average
asylum grant rates in their own courts,
rejecting more than 90 percent of
asylum claims in non-detained cases. In
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addition, those commenters explained
that IJs’ asylum grant rates are
significantly influenced by factors other
than the merits of the cases, such as the
gender and prior prosecutorial
experience of the IJ. Commenters were
therefore concerned that some IJs may
likewise summarily or arbitrarily deny
asylum applicants the opportunity to
testify, thereby pretermitting their
appeals.
Commenters asserted that the
evidentiary restrictions during IJ review
are particularly problematic in light of
alleged problems, based on political
influence, with the country conditions
information available to the asylum
officers who would be tasked with
making the record the IJ would review.
In other words, at least one commenter
stated, if applicants are denied a full
and fair opportunity to present evidence
that challenges the country conditions
information underlying the asylum
officer’s decision to not grant asylum or
protection, IJs may ‘‘rubber-stamp’’
decisions that are based on inaccurate
information resulting from
impermissible political considerations.
Response: As described above, the
IFR, in new 8 CFR 1240.17, revises the
process so that noncitizens whose
applications for asylum are not granted
following the Asylum Merits interview
are referred to streamlined section 240
removal proceedings, rather than
implementing the novel IJ review
procedure proposed by the NPRM. As
part of this change, the Departments are
no longer proposing evidentiary
standards like those in the NPRM. See
8 CFR 1003.48(e)(1) (proposed); 86 FR
46911, 46920. Rather, the IFR adopts an
approach consistent with the current
evidentiary standard for section 240
removal proceedings; subject to the
applicable deadline in streamlined
section 240 proceedings, IJs may
exclude additional evidence only if it is
not relevant, probative, or timely or if its
use is fundamentally unfair. In other
words, unlike the NPRM, the IFR does
not require the IJ to make a novel
threshold determination regarding the
need for the evidence. In addition, the
noncitizen will have the privilege of
being represented by counsel at no
expense to the Government during
proceedings before the IJ if the
noncitizen chooses. INA 292, 8 U.S.C.
1362.85 Further, unlike the NPRM, this
IFR specifically contemplates that the IJ
will, if necessary, conduct hearings to
narrow the issues and take testimony or
85 To be sure, the NPRM proposed that
noncitizens would have the same privilege. See 8
CFR 1003.12 (proposed), 1003.16; see also 86 FR
46919.
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further evidence, as provided in new 8
CFR 1240.17(f)(4). These features of
streamlined section 240 removal
proceedings preclude the possibility
that an IJ would simply ‘‘rubber-stamp’’
an asylum officer’s asylum decision, as
commenters alleged.
Regarding commenters’ concerns with
the process of IJs’ credible fear reviews,
the IFR returns the credible fear
screening process to that which was in
effect prior to the regulatory changes
made between 2018 and 2020. See
generally 8 CFR 208.30. The DOJ
regulations at 8 CFR 1003.42 and
1208.30(g)(2) provide an extensive
process through which an IJ reviews a
negative credible fear determination. IJs
exercise independent judgment and
discretion and follow applicable laws
and regulations in credible fear reviews,
and they would continue to do so under
this rule. See, e.g., IJ Ethics and
Professionalism Guide (requiring IJs to,
inter alia, be faithful to the law,
maintain professional competence in
the law, act impartially, and avoid
actions that would create the
appearance of violations of the law or
applicable ethical standards).
More specifically, the Departments
reject commenters’ contentions that IJs
currently ‘‘rubber-stamp’’ asylum
officer’s negative credible fear
determinations and that such practice
would carry over into an IJ’s review of
an asylum officer’s decisions under the
NPRM or the IFR. Under 8 CFR
208.30(d)(4) of DHS’s regulations, which
the NPRM did not propose to amend,
noncitizens may consult with a person
or persons of their choosing before the
interview, contrary to commenters’
allegations that noncitizens have no
right to counsel. Upon an exercise of
USCIS’s discretion, that person or
persons may be present at the interview
and may present a statement at the end
of the interview. 8 CFR 208.30(d)(4).
Further, noncitizens may ‘‘present other
evidence, if available,’’ see id., contrary
to commenters’ allegations that
noncitizens may not present testimony
or evidence. The Departments also
disagree with commenters’ allegations
that asylum officers take ‘‘often
incomplete’’ or ‘‘incorrect’’ notes.
Asylum officers receive extensive
training and possess expertise, see 8
CFR 208.1(b); INA 235(b)(1)(E), 8 U.S.C.
1225(b)(1)(E), and the Departments are
confident in the asylum officers’ ability
to carry out their duties in accordance
with all applicable statutes and
regulations. Further, this IFR provides
that the record from the Asylum Merits
interview will include a verbatim
transcript of the interview before the
asylum officer, obviating the need for IJs
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to rely exclusively on asylum officers’
notes.
The Departments also disagree with
commenters who recommended IJs
review recordings of the Asylum Merits
interviews instead of verbatim
transcripts as a way to increase
efficiency. The Departments prefer the
review of transcripts considering their
clarity, ease of use, and increased
specificity in citations. Further, the
Departments disagree that listening to a
recording would save a significant
amount of time compared to reviewing
a transcript. For these reasons, the IFR
includes the transcript alone in the
record that is referred to the IJ for use
in subsequent streamlined 240 removal
proceedings.86
Although the Departments believe
that this IFR addresses commenters’
concerns about ‘‘rubber-stamping’’
because it provides for streamlined
section 240 removal proceedings rather
than the NPRM’s IJ review procedure
and associated standard for the
submission of evidence, the
Departments dispute commenters’
allegations that IJs would reject
evidence or refuse to hold an
evidentiary hearing based on
performance metrics or other bases
unrelated to the specifics of an
individual proceeding. IJs
independently adjudicate each case by
applying applicable law and
regulations, not by considering
performance metrics. 8 CFR 1003.10(b)
(providing that IJs ‘‘may take any action
consistent with their authorities under
the Act and regulations that is
appropriate and necessary for the
disposition of such cases’’). In addition,
EOIR no longer reviews IJ performance
through individual judge performance
metrics. IJs are held to high ethical
standards in part to avoid impropriety
or the appearance of impropriety, which
would include deciding cases consistent
with performance metrics rather than
applicable law and regulations. See also
IJ Ethics and Professionalism Guide
(providing that IJs must be faithful to
the law, maintain professional
competence in the law, act impartially,
and avoid actions that would create the
appearance that the IJ is violating the
law or applicable ethical standards); see
also EOIR Policy Manual, Part II, ch.
1.3(c) (stating that IJs ‘‘strive to act
honorably, fairly, and in accordance
86 While USCIS will have to record the USCIS
interview in order to create a transcript of the
interview, the Departments did not intend to imply
in the NPRM that EOIR would receive a recording
with the record in every case. The receipt of the
recording would be redundant with the transcript
and, as noted, more time consuming to review than
a transcript.
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with the highest ethical standards’’).
Likewise, the Departments do not share
the commenters’ concerns with IJs’
professional experience or diverse
backgrounds. IJs are selected on merit
with baseline qualifications, including
possession of a J.D., LL.M., or LL.B.
degree; active membership in a State
bar; and seven years of experience as a
licensed attorney working in litigation
or administrative law. IJs receive
extensive training upon entry on duty,
annual training, and periodic training
on specialized topics as necessary. IJs
are also expected to maintain
professionalism and competence in the
law.87 Likewise, the Departments reject
commenters’ implications that newly
hired asylum officers are less competent
or professional than IJs. As explained
earlier in Section IV.B.2.a of this
preamble, asylum officers are selected
based on merit, receive extensive
training, and possess expertise in
determining eligibility for protection.
The Departments are confident in
asylum officers’ ability to carry out their
duties in accordance with all applicable
statutes and regulations.
The Departments disagree with
commenters’ use of asylum grant rates
to imply that IJs with low grant rates
make arbitrary decisions or are
influenced by factors outside of the
merits of the case. An individual IJ’s
grant rate may be affected by factors
outside the IJ’s control. For example, an
IJ assigned to a detained docket will
generally have a higher percentage of
applicants who are ineligible for asylum
due to criminal convictions compared
with an IJ who is assigned to a
nondetained docket. The Departments
reiterate the ethical and professional
standards to which IJs are held,
discussed above, which would preclude
arbitrarily or summarily denying
noncitizens the opportunity to testify or
considering improper factors in a case,
as commenters alleged. IJs are required
to adjudicate cases in an impartial
manner based on their independent
judgment and discretion, applying
applicable law and regulations. 8 CFR
1003.10(b).
Overall, commenters’ accusations of
bias or impropriety that would lead to
due process violations are insufficient to
‘‘overcome a presumption of honesty
and integrity in those serving as
adjudicators.’’ Withrow v. Larkin, 421
U.S. 35, 47 (1975). The Departments are
confident in the competency, integrity,
and professionalism of IJs and asylum
officers in providing due process of law
to all noncitizens before them. Further,
if a noncitizen believes that an IJ has
87 See
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acted improperly or otherwise
prejudiced the proceeding, the
noncitizen may appeal the IJ’s decision
to the BIA, 8 CFR 1240.15, and in turn
appeal the BIA’s decision to a Federal
circuit court, INA 242, 8 U.S.C. 1252.
See also Avendano-Hernandez v. Lynch,
800 F.3d 1072, 1075 (9th Cir. 2015)
(remanding the case and stating that the
IJ ‘‘exhibit[ed] some of the same
misconceptions about the transgender
community that [the noncitizen] faced
in her home country’’ by failing ‘‘to
recognize the difference between gender
identity and sexual orientation,’’ and
refusing to allow the use of female
pronouns); see also Shahinaj v.
Gonzales, 481 F.3d 1027, 1029 (8th Cir.
2007) (remanding the IJ’s adverse
credibility finding that was based in
part on ‘‘the IJ’s personal and improper
opinion [that the noncitizen] did not
dress or speak like or exhibit the
mannerisms of a homosexual’’). In
addition, individuals who believe that
an IJ has engaged in judicial misconduct
may submit a complaint to EOIR’s
Judicial Conduct and Professionalism
Unit:
Executive Office for Immigration Review,
attn.: Judicial Conduct and Professionalism
Unit, 5107 Leesburg Pike, Suite 2600, Falls
Church, VA 22041, judicial.conduct@
usdoj.gov.
The Departments disagree with
commenters who broadly asserted that
noncitizens should not be ‘‘hindered’’
by evidentiary limitations. Although the
IFR does not adopt the NPRM’s
proposed evidentiary standard, the IFR
includes an evidentiary standard
consistent with that currently used in
section 240 proceedings. See Nyama,
357 F.3d at 816 (‘‘The traditional rules
of evidence do not apply to immigration
proceedings . . . . ‘The sole test for
admission of evidence is whether the
evidence is probative and its admission
is fundamentally fair.’ ’’ (quoting
Espinoza, 45 F.3d at 310)); Matter of
Ramirez-Sanchez, 17 I&N Dec. at 505
(holding that evidence must be
‘‘relevant and probative and its use must
not be fundamentally unfair’’). The IFR
further provides, in new 8 CFR
1240.17(g)(2), that evidence filed after
the applicable deadline may be
considered if it could not reasonably
have been obtained and presented
before the deadline through the exercise
of due diligence. While the bar for
admitting evidence in immigration
proceedings is relatively low,
noncitizens have never had a wholly
unrestricted right to present any and all
evidence or testimony.
Finally, the Departments also disagree
with commenters’ allegations that
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country conditions information
available to asylum officers is
inaccurate, inappropriately politically
influenced, or otherwise problematic.
Federal Government country conditions
reports, such as the U.S. Department of
State country conditions reports, are
longstanding, credible sources of
information. See, e.g., Sowe v. Mukasey,
538 F.3d 1281, 1285 (9th Cir. 2008)
(‘‘U.S. Department of State country
reports are the most appropriate and
perhaps the best resource for
information on political situations in
foreign nations.’’ (quotation marks
omitted)); Xiao Ji Chen v. U.S. Dep’t of
Justice, 471 F.3d 315, 341 (2d Cir. 2006)
(State Department country reports are
‘‘usually the best available source of
information on country conditions’’
(quotation marks omitted)). Commenters
have provided no reasoning beyond
conclusory allegations that the country
conditions information available to
asylum officers is inaccurate or
inappropriately politically influenced.
Further, under the IFR, IJs will consider
all relevant and probative evidence,
consistent with the evidentiary
standards in section 240 proceedings
and subject to the applicable deadline.
Thus, IJs may consider country
conditions information in accordance
with its probative value, which will
vary by case, as well as evidence
submitted by the noncitizen that
challenges such country conditions
information.
Comments: Multiple commenters
expressed concerns that limiting an
asylum seeker’s oral testimony to items
that are not duplicative of the written
application, on the belief that the
written record would suffice for
deciding the applicant’s veracity, would
violate the asylum seeker’s due process
rights.
Commenters stated that it would be
difficult for IJs to assess credibility
issues through a transcript or videos,
and commenters disagreed that IJs could
review credibility issues de novo absent
additional testimony. Instead,
commenters asserted that live, in-person
testimony is required to assess an
applicant’s demeanor, candor, and
responsiveness to questions. Further,
commenters cited Goldberg v. Kelly, 397
U.S. 254, 269 (1970), for the proposition
that the right to present one’s testimony
is crucial ‘‘where credibility and
veracity are at issue.’’ One commenter
noted that, in such instances, Goldberg
v. Kelly provides that a person ‘‘must be
allowed to state his position orally’’ and
‘‘written submissions are a wholly
unsatisfactory basis for decision.’’ Id. at
369. Accordingly, commenters stated
that, to comport with due process, it is
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critical that IJs provide applicants with
ample opportunity to present their case,
including the chance to explain any
perceived omissions or inconsistencies,
before making credibility findings.
Additionally, commenters
emphasized that IJs have a duty to
develop the record in immigration
proceedings, for which the ability to
personally examine the applicant is a
crucial tool.
Relatedly, commenters stated that, if
represented, the applicant’s counsel
should be allowed to present and guide
relevant, probative testimony because
this form of examination most
effectively elicits the noncitizen’s
factual basis for relief or protection. The
commenters said that records from
asylum interviews do not present all of
the relevant facts as coherently as a
direct examination by counsel who is
familiar with the case. Moreover,
commenters stated that during the
course of testimony, a question from
counsel or from the IJ could elicit an
answer that unexpectedly gives rise to a
new line of questioning or even a new
legal theory of the case.
Response: As discussed above in
Section III of this preamble, the IFR
provides that noncitizens whose
applications are not granted by the
asylum officer will be placed in
streamlined section 240 removal
proceedings instead of implementing
the NPRM’s IJ review procedure. In
streamlined section 240 proceedings,
the noncitizen is entitled to testify
before the IJ if the noncitizen timely
requests the opportunity to do so, unless
the IJ determines that asylum may be
granted without the need to hear
additional testimony. However, under
new 8 CFR 1240.17(f)(2), and (f)(4)(i)–
(ii), the IJ may forego a hearing and
decide the case on the documentary
record if (1) neither the noncitizen nor
DHS has timely requested to present
testimony under the pre-hearing
procedures and DHS has not requested
to cross-examine the noncitizen, or (2)
the noncitizen elected to testify or
provide evidence but the IJ determines
that relief or protection may be granted
without further proceedings and DHS
has not requested to cross-examine the
noncitizen. Additionally, noncitizens
will have the privilege of representation
at no expense to the Government, and,
if the noncitizen is represented, the
noncitizen’s representative will be able
to shape the course of direct
examination. INA 240(b)(4), 8 U.S.C.
1229a(b)(4). Moreover, IJs will continue
to have the authority to ‘‘interrogate,
examine, and cross-examine the
[noncitizen] and any witnesses,’’
thereby maintaining the IJ’s ability to
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18171
develop the record. INA 240(b)(1), 8
U.S.C. 1229a(b)(1). Further, IJs will
continue to assess a noncitizen’s
credibility, as set forth in section
240(c)(4)(C) of the Act, 8 U.S.C.
1229a(c)(4)(C). Thus, the Departments
believe that the changes made in this
IFR, provided generally in new 8 CFR
1240.17, address commenters’ concerns
by preserving noncitizens’ ability to
testify before an IJ in support of their
claims, while at the same time
maintaining the efficiencies highlighted
in the NPRM by establishing expedited
procedural requirements for the timely
resolution of noncitizens’ proceedings.
Comments: Commenters also stated
that applicants must be given the
opportunity to submit evidence, as
needed, to develop their claims in the
IJ review stage because the ability to
present additional evidence before the IJ
is crucial to ensuring due process for
immigrants seeking protection.
First, several commenters said that
duplicative evidence is sometimes
necessary to persuade an IJ. For
example, commenters indicated that
multiple reports of the same phenomena
might persuade an IJ of the prevalence
of an issue. Likewise, commenters said
that some IJs may not be persuaded by
a single piece of evidence, but
duplicative evidence may satisfy the IJ
or increase the evidentiary weight an IJ
gives to an applicant’s testimony.
Similarly, several commenters said
that the law accords greater deference to
Government sources, such as State
Department reports, and IJs may find
other or contradictory evidence
deserving of little evidentiary weight.
Thus, commenters explained, while
duplicative in a strict sense, filing
several reports from different sources
that similarly rebut the State
Department’s conclusions can be
necessary to making a successful claim.
However, under the NPRM, commenters
asserted that IJs can exclude this
evidence merely because it is facially
duplicative without ever reaching the
question as to whether it is necessary.
Additionally, commenters pointed out
that corroborating accounts of
persecution, such as declarations from
multiple witnesses about the same
event, can often assist in showing the
applicant’s credibility and the severity
of the persecution they suffered.
Commenters also indicated that asylum
adjudications may hinge on considering
evidence in the aggregate, such as
whether a series of incidents rises to the
level of persecution, or whether
evidence of similarly situated cases and
country conditions cumulatively
establish a likelihood of future harm to
the applicant. Thus, commenters stated
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that the NPRM creates the risk that IJs
may erroneously reject evidence as
‘‘duplicative’’ when it is in fact critical
to a cumulative analysis, noting that for
the IJ, it is precisely the overwhelming
nature of the evidence pointing toward
one conclusion that makes it persuasive.
Accordingly, commenters argued that
the NPRM’s restriction on duplicative
evidence would make it impossible to
prove, to the satisfaction of the
adjudicator, many meritorious claims.
Commenters also stated that, in some
instances, an IJ may not be able to
determine if new evidence or testimony
is ‘‘duplicative’’ and ‘‘necessary’’ until
the hearing is concluded. According to
commenters, questioning from counsel
or from an IJ during seemingly
duplicative testimony may elicit new
information relevant to an asylum
seeker’s claim. Thus, commenters
expressed concern that while the need
for duplicative evidence might not
become apparent until the hearing is
concluded, the decision to exclude
additional testimony and documentary
evidence will have been made at the
outset of the proceeding. As it is not
always possible to predict what will be
a central issue in a case, and as
duplicative evidence can actually be
necessary to meet the applicant’s
burden of proof, commenters believed
that permitting duplicative evidence
would not be ‘‘inefficient.’’
Response: As discussed above in
Section III of this preamble, the IFR
provides that individuals whose
applications are not granted by the
asylum officer will be placed in
streamlined section 240 removal
proceedings rather than the NPRM’s
proposed IJ review procedure. As part of
those streamlined section 240
proceedings, noncitizens may submit
additional evidence before the IJ in
support of their claims. Because these
removal proceedings are governed by
section 240 of the Act, 8 U.S.C. 1229a—
subject to specific procedural
requirements and timelines, as
described above in Section III—
noncitizens will be able to submit
evidence in these proceedings, as
provided in new 8 CFR 1240.17(g)(1),
and the IJ will only exclude such
evidence if the IJ determines that the
evidence is untimely, that it is not
relevant or probative, or that its use is
fundamentally unfair. See 8 CFR
1240.7(a); see also Matter of D–R–, 25
I&N Dec. at 458 (‘‘In immigration
proceedings, the sole test for admission
of evidence is whether the evidence is
probative and its admission is
fundamentally fair.’’ (quotation marks
omitted)); Matter of Interiano-Rosa, 25
I&N Dec. 264, 265 (BIA 2010) (‘‘[IJs]
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have broad discretion to conduct and
control immigration proceedings and to
admit and consider relevant and
probative evidence.’’). In other words,
the ability of noncitizens in these
proceedings to introduce evidence or
testimony will not hinge on the IJ’s
analysis of whether or not the evidence
is duplicative of the record from the
noncitizen’s hearing before the asylum
officer. Consistent with currently
applicable evidentiary rules in section
240 proceedings, noncitizens may
instead submit evidence that
commenters noted would otherwise be
duplicative. Given the above,
commenters’ concerns about the
evidentiary restrictions in the NPRM’s
proposed limited IJ proceedings are
moot.
Comments: Commenters expressed
concerns that the NPRM would harm
applicants who face unique hurdles
during proceedings, including
individuals who were unable to provide
a complete record before the asylum
officer due to trauma, lack an
understanding of the process, are
unrepresented, have language barriers,
or are members of a vulnerable or
marginalized population. Specifically,
commenters were concerned with the
NPRM’s limitation that IJs only review
the record created by the asylum officer
and the NPRM’s evidentiary standard
that applicants can only submit ‘‘nonduplicative’’ evidence to the IJ. With so
much at stake, commenters believed
that these applicants should not be
hindered by rules that limit their ability
to fully present their claims.
Commenters provided a wide range of
reasons that the NPRM’s evidentiary
standards would particularly
disadvantage pro se applicants.
Commenters speculated that pro se
individuals, particularly those without
English language proficiency, may not
be aware of the full scope of evidence
they can provide before the asylum
officer and that USCIS’s traditional use
of broad, open-ended questions may not
be sufficient to elicit relevant
information for the adjudication of an
asylum claim. Similarly, commenters
explained that those applicants who do
not retain a lawyer prior to the Asylum
Merits interview may lose their
opportunity to develop the facts and law
in their claim. Commenters also
indicated that detained applicants
frequently need time to contact family
to support their legal claims; thus,
commenters believed that the NPRM
disproportionately disadvantages those
without counsel in detention.
Commenters also believed the NPRM
would make it difficult for
unrepresented, noncitizens without
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English language proficiency to examine
the record and make their case to the IJ
during the review process. According to
one commenter, the record forwarded
by the Asylum Office to the IJ for review
will ‘‘undoubtedly be in English,’’
making it effectively impossible for
applicants who are not represented and
who do not read English to ascertain
what is in the record, to make
arguments about how the asylum officer
erred, and to determine what additional
information or evidence they possess
and could provide to support their
claim.
Additionally, commenters stated that
the NPRM did not account for language
access issues, noting that when an
applicant speaks a rare language or
dialect, the Asylum Office frequently
cannot find an interpreter, and this
language gap frequently results in
mistakes in the record. Given the
heightened evidentiary standard for
introducing new evidence into the
record, commenters expressed concern
that interpretation mistakes would be
difficult to correct through the appeal
process proposed by the NPRM.
Commenters stated that the NPRM’s
evidentiary restrictions in IJ review
proceedings would prejudice many
unrepresented applicants because pro se
individuals would be unable to comply
with the pre-trial procedures requiring
detailed justifications for the admission
of proposed evidence. One commenter
did not believe that having an IJ explain
‘‘restrictive and vague standards’’ to pro
se applicants in court would be
sufficient to apprise those applicants of
the procedures they should follow to
provide further relevant evidence to the
court. Commenters argued that most
applicants cannot be expected to meet
these additional procedural burdens to
submit evidence. Further, commenters
stated that demanding that applicants
meet additional evidentiary burdens
before the IJ—especially if the applicant
was not adequately represented when
presenting the claim to the asylum
officer—does not advance the fairness of
the system. Moreover, commenters
indicated that if the IJ needs to make a
decision to admit new evidence or to
allow further testimony based on a
review of the evidence the applicant
seeks to present, the NPRM added what
is, in effect, a motion to reopen to every
asylum claim, which may overly burden
the finite legal services available to
applicants.
Additionally, commenters noted that
some applicants suffer from cognitive or
emotional issues that may prevent them
from testifying effectively before the
asylum officer or without a lengthy
interview over the course of multiple
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days or weeks. Commenters also noted
that the ability to present new evidence
is crucial in cases involving applicants
who are members of the LGBTQ+
community because some applicants
may not have ‘‘come out’’ yet to
themselves or to their families when
they arrive in the United States, or at the
time of an asylum interview, given that
the way an individual identifies may
evolve over time. Similarly, commenters
indicated that IJs may need more
educational evidence about asylum
claims for transgender and gender
nonconforming applicants or applicants
who are living with HIV, stating that the
time to acquire evidence, to obtain legal
representation, and to present
testimony, including expert testimony,
are particularly crucial in such cases.
Response: As discussed above in
Section III of this preamble, the IFR
provides that noncitizens whose asylum
applications are not granted by an
asylum officer will be placed in
streamlined section 240 removal
proceedings rather than finalizing the
NPRM’s proposed IJ review procedure.
Because section 240 proceedings
provide noncitizens with procedural
safeguards, including the right to
counsel at no expense to the
Government and the ability to
reasonably present their case, the
Departments believe that this shift
largely addresses commenters’ concerns
with the NPRM’s effect on
underrepresented, non-English
speaking, traumatized, and other
marginalized noncitizens. In response to
commenters’ concerns related to
unrepresented individuals appearing
before an asylum officer for an Asylum
Merits interview, the Departments note
that, as explained earlier in this IFR,
USCIS asylum officers have experience
with (and receive extensive training on)
eliciting testimony from applicants and
witnesses and providing applicants the
opportunity to present, in their own
words, information bearing on eligibility
for asylum. Asylum officers also are
trained to give applicants the
opportunity to provide additional
information that may not already be in
the record so that the asylum officer has
a complete understanding of the events
that form the basis for the application.
See supra Section IV.D.5 of this
preamble. With respect to commenters’
concerns about interpreters for Asylum
Merits interviews, the Departments note
that USCIS has existing contracts with
telephonic interpreters to provide
interpretation for credible fear screening
and affirmative asylum interviews, and
thus has extensive experience providing
contract interpreter services. USCIS
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contractors must provide interpreters
capable of accurately interpreting the
intended meaning of statements made
by the asylum officer, applicant,
representative, and witnesses during
interviews or hearings. The USCIS
contractor will provide interpreters who
are fluent in reading and speaking
English and one or more other
languages. The one exception to the
English fluency requirement involves
the use of relay interpreters in limited
circumstances at USCIS’s discretion. A
relay interpreter is used when an
interpreter does not speak both English
and the language the applicant speaks,
such as a rare language or dialect. See
supra Section IV.D.5 of this preamble.
As explained earlier in this IFR, USCIS
will arrange for the assistance of an
interpreter in conducting the Asylum
Merits interview, and if an interpreter is
unavailable, will attribute any delays to
USCIS for the purpose of employment
authorization eligibility, as described in
new 8 CFR 208.9(g)(2). Thus, USCIS
will ensure that there is clear
communication among the various
individuals participating in any Asylum
Merits interview.
The Departments recognize that
unrepresented noncitizens may have
difficulties identifying errors in the
asylum officer’s decision as well as
making legal arguments before the IJ
regarding those errors. Accordingly,
under the IFR, unrepresented
noncitizens are not required to submit a
written statement to the IJ identifying
errors in the asylum officer’s decision;
instead, under new 8 CFR 1240.17(f)(2),
the IJ will conduct a status conference
to narrow the issues, determine the
noncitizen’s position, and ascertain
whether a merits hearing will be
needed. At this status conference, the
noncitizen will state whether the
noncitizen intends to testify, identify
any witnesses the noncitizen intends to
call in support of the noncitizen’s
application, and provide any additional
documentation in support of the
noncitizen’s application. Id. In addition,
individuals who speak a language other
than English will be provided an
interpreter.
Further, should any noncitizen—
including unrepresented or other
vulnerable noncitizens—wish to
provide additional testimony and
evidence before the IJ, the respondent
may do so under the IFR, as provided
in new 8 CFR 1240.17(f)(2)(i), without
needing to satisfy the kind of threshold
requirements proposed in the NPRM. As
previously stated, the only limitation on
the admission of evidence in the IFR’s
streamlined section 240 proceedings is
that the IJ must exclude evidence if it is
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untimely, not relevant or probative, or if
its use is fundamentally unfair, which is
consistent with the standard evidentiary
rules in all other section 240
proceedings. Matter of D–R–, 25 I&N
Dec. at 458 (‘‘In immigration
proceedings, the sole test for admission
of evidence is whether the evidence is
probative and its admission is
fundamentally fair.’’ (quotation marks
omitted)).
Finally, regarding commenters’
concerns over the ability of noncitizens
with competency concerns to testify
effectively in a short time period, the
Departments note that the IFR, in new
8 CFR 1240.17(k)(6), excepts
noncitizens who have exhibited indicia
of incompetency. These noncitizens
would instead be placed in ordinary
section 240 removal proceedings.88
Thus, the Departments believe that
the IFR adequately responds to
commenters’ concerns by placing all
applicants who are not granted asylum
following an Asylum Merits interview
into streamlined section 240 removal
proceedings, thereby providing
additional procedural protections and
safeguards, and ensuring due process.
See Hussain v. Rosen, 985 F.3d 634, 644
(9th Cir. 2021) (‘‘[D]ue process has been
provided whenever a[ noncitizen] is
given a full and fair opportunity to be
represented by counsel, to prepare an
application for . . . relief, and to
present testimony and other evidence in
support of the application.’’ (quotation
marks omitted)).
Comments: Commenters stated that,
contrary to the Departments’ goals, the
NPRM’s proposed evidentiary
requirements would result in a less
efficient and more burdensome
adjudicatory system. For example,
commenters stated that, in addition to
providing evidence, applicants and
counsel would have to proffer each
piece of evidence, which would
increase the time and cost of
proceedings. Commenters stated that,
although the NPRM provides for the
possibility of supplementing the record,
the NPRM frames it as the exception for
the sake of judicial efficiency and places
a new burden on the applicant to prove
that any new evidence is necessary for
the case.
Commenters said it would be
impossible to gather the relevant
evidence needed and to prepare clients
for testimony in such a short time frame.
Commenters said applicants often need
88 In addition, EOIR will provide a qualified
representative through the EOIR National Qualified
Representative Program (‘‘NQRP’’) to a respondent
who is found to be incompetent to represent
themselves in immigration proceedings and who is
both unrepresented and detained.
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to gather evidence from their home
countries, which could not be obtained
in only a few weeks, especially for
clients who are detained. Some
commenters similarly said it is well
established under U.S. law that asylum
seekers often flee for their lives without
the ability to first collect documentation
to support their claims, and it can be
difficult, if not impossible, for asylum
seekers or their representatives to gather
evidence from family and friends in
their country of origin. It is thus
unreasonable to expect that asylum
seekers will present all their evidence at
a streamlined hearing before an asylum
officer, thus leading to an incomplete
record for IJ review. Commenters stated
that, to fulfill their ethical duties to their
clients, legal advocates would have to
immediately seek to fill the inevitable
evidentiary gaps in the record, and then
prepare written motions seeking to
admit that evidence and seeking a full
individual merits hearing.
Commenters said the NPRM’s
evidentiary restrictions would add
challenges for an IJ to conduct
meaningful de novo review of an
appeal. Commenters stated IJs could
instead conduct their review directly in
court, without relying on proceedings
with the asylum officer, and with better
results because the IJ would be able to
make a credibility assessment of the
applicant, as well as any witnesses.
Some commenters remarked that the
majority of claims not granted by an
asylum officer would end up in
immigration court, and, under the
NPRM, IJs would be flooded with
requests to present new evidence and to
grant individual hearings.
Commenters wrote that, if the IJ were
to grant a motion to allow testimony and
additional evidence, the proposed
regulation would have failed to save any
time or expense either to noncitizens or
EOIR, because the case would then
proceed in immigration court just as an
affirmative case that is referred to court
does now. On the other hand, if the IJ
were to reject an applicant’s additional
testimony or other evidence, then the
applicants would almost certainly file
an appeal.
Commenters expressed concern that
judicial review of the NPRM’s
evidentiary restrictions could be limited
and inefficient in practice. For example,
if the IJ does not provide a reasoned
explanation for the rejection (which the
proposed NPRM does not require), a
court of appeals would be highly likely
to remand the case to the BIA, with a
further remand to the IJ, because
judicial review of the IJ’s action would
be nearly impossible without such an
explanation. Commenters similarly
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stated that a decision by the IJ to reject
additional testimony or documents
would not require specific reasons,
making judicial review of the
determination that the evidence is not
necessary or would be duplicative
virtually impossible. Commenters stated
that denials of requests to present
additional evidence would lead to an
increase in interlocutory appeals to the
BIA and could lead to additional rounds
of Federal circuit court appeals as
asylum seekers challenge the sufficiency
of the immigration court record. In
addition, commenters stated, many
Federal courts place onerous exhaustion
requirements on petitions for review of
BIA decisions, and some courts even
suggest that noncitizens must seek
reconsideration to point out ignored
arguments or improper legal approaches
before having those arguments
considered on appeal. As a result,
commenters stated that the NPRM’s
procedures, which were designed to be
efficient, would cause significant
inefficiencies on the back end by forcing
applicants to file motions to reconsider
before the immigration court and the
BIA.
Response: As described above in
Section III of this preamble, the IFR
revises the process in new 8 CFR
1240.17(a) and (b), so that noncitizens
whose applications for asylum are
adjudicated but not granted by an
asylum officer are referred to
streamlined 240 proceedings through
the issuance of an NTA, rather than
seeking IJ review through the procedure
proposed by the NPRM. As part of this
change, the Departments are also
removing the evidentiary standards
proposed by the NPRM. See 8 CFR
1003.48(e)(1) (proposed); 86 FR 46911,
46920. Instead, as provided in new 8
CFR 1240.17(g)(1), the IFR affirms that
noncitizens in the streamlined 240
proceedings may submit additional
evidence to the IJ consistent with the
traditional evidentiary standard applied
in 240 proceedings. With this change,
the IFR does not include those
procedural requirements that
commenters were concerned would
create inefficiencies.
Specifically, unlike what was
proposed in the NPRM, the IFR does not
require the noncitizen to demonstrate
that any desired new evidence or
testimony is non-duplicative and
necessary or require the IJ to make a
threshold determination that the
evidence satisfies that standard. Because
the noncitizen may submit evidence
during streamlined section 240
proceedings, any delay in the
availability of evidence during the
asylum officer review, and any
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corresponding gap in the record, may be
addressed before the IJ. The lack of an
additional, novel evidentiary standard
reduces the likelihood of appeals and
subsequent litigation, identified by the
commenters, surrounding the
submission of evidence.
In addition, given that the IFR is
consistent with the longstanding
evidence standard used in section 240
proceedings, the Departments do not
believe that the IFR will have a chilling
effect on the availability of judicial
review regarding an IJ’s evidentiary
determinations. The IFR does not
amend a noncitizen’s right to appeal a
decision, in accordance with the
statutes and regulations. See 8 CFR
1003.3, 1003.38.
Comments: Commenters stated that
while the NPRM’s proposed ‘‘nonduplicative’’ and ‘‘necessary’’ standard
for the submission of new evidence may
create more efficiency, it is
inappropriate because it (1) reverses
Congress’s original intent to protect
asylum seekers from expedited removal
and give them sufficient time after their
initial arrival in the United States to
prepare an asylum application; (2)
violates international obligations to
prevent the refoulement of genuine
refugees; and (3) undermines the United
States’ commitment to asylum
protection and the preservation of
human rights. Commenters stated that
the proposed restriction on new
evidence in the proposed IJ review
proceedings would be fundamentally
unfair and violate both U.S. asylum law
and the Refugee Convention and
Protocol. Similarly, commenters stated
that the NPRM’s evidentiary
restrictions, if adopted, conflict with the
statutory and regulatory affirmative duty
of IJs to fully develop the record.
Response: As described above in
Section III of this preamble, the IFR
revises the process in new 8 CFR
1240.17(a) and (b) to provide that
noncitizens whose applications for
asylum are not granted by an asylum
officer are referred to streamlined
section 240 removal proceedings
through the issuance of an NTA, rather
than seeking IJ review through the
procedure proposed by the NPRM. As
part of this change, the Departments are
also removing the ‘‘non-duplicative’’
and ‘‘necessary’’ evidentiary standards
proposed by the NPRM. See 8 CFR
1003.48(e)(1) (proposed); 86 FR 46911,
46920. Instead, the IFR affirms that
noncitizens in streamlined section 240
removal proceedings may submit
additional evidence to the IJ, as
provided in new 8 CFR 1240.17(g)(1),
consistent with the traditional
evidentiary standard application in 240
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proceedings. This change addresses
commenters’ concerns that the NPRM’s
evidentiary standard violates
congressional intent and the United
States’ international obligations.
Similarly, the IFR’s changes address
commenters’ concerns regarding IJs’
duty to develop the record. Unlike the
proposal in the NPRM, the IFR
specifically contemplates, in new 8 CFR
1240.17(f)(1) and (2), the IJ conducting
a master calendar hearing in all cases,
followed by a status conference to
discuss the noncitizen’s claim and
narrow the issues. Overall, IJs will
continue to exercise independent
judgment and discretion in accordance
with the case law, statutes, and
regulations to decide each case before
them. See 8 CFR 1003.10(b).
Comments: Commenters suggested
numerous alternative formulations
regarding the NPRM’s proposed
evidentiary standard for IJ review
proceedings. Some commenters
proposed that the standard for
introduction of new evidence before the
IJ should be lower, stating that a low
threshold will ensure that newlydeveloped evidence and any evidence
the asylum officer erroneously failed to
include in the record is considered in
immigration court. Commenters stated
that lowering the evidentiary threshold
would still provide improved efficiency
because IJs would still only hear new
evidence, decreasing the amount of time
spent reviewing each case and helping
to stem the growth of EOIR’s case
backlog.
Other commenters similarly argued
that, if the proposed process cannot be
amended to guarantee section 240
removal proceedings for asylum seekers,
the Departments should allow
applicants to freely present evidence
and testimony during the IJ review
proceedings.
Commenters also suggested changes
that they stated would better align the
procedures for these review proceedings
with international law and international
procedures. First, commenters stated
that the Departments could follow the
example set by the United Nations
Committee Against Torture and require
an explanation for late submission, with
a presumption in favor of accepting the
explanation and admitting the evidence.
Second, commenters stated that the
UNHCR urges states to consider all
available evidence to meet their
obligations under international law.
Commenters noted that a more lenient
evidentiary standard would better align
with the United States’ obligations
under the Refugee Protocol, including
ensuring that adjudicators consider all
evidence that could support a claim,
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even when only submitted on appeal,
and that the unique realities implicated
in adjudicating international protection
claims require flexibility.
Response: As explained above in
Section III of this preamble, under the
IFR in new 8 CFR 1240.17(a) and (b), if
the application for asylum is
adjudicated but not granted by the
asylum officer, DHS will issue an NTA
and refer the applicant to streamlined
section 240 removal proceedings before
an IJ. Because the Departments are not
pursuing the proposed IJ review
procedure, including the proposed
limitations on new evidence, the
Departments need not further respond
directly to commenters’ suggestions for
how those proceedings could have been
improved. Further, the Departments
believe that the change in the IFR to
streamlined 240 proceedings ultimately
addresses commenters’ concerns, as
noncitizens will have the opportunity to
address any perceived errors in the
asylum officer’s written decision,
submit new evidence without regard to
the evidentiary limitations proposed in
the NPRM, and testify before the IJ.
Comments: Commenters expressed
concern that the NPRM would
essentially give the IJ an appellate
review role but would not provide rights
for noncitizens or their counsel to
address any errors in the asylum
officer’s decision. Specifically,
commenters stated, the NPRM does not
contain any information about whether
the IJ would issue a briefing schedule,
whether the parties would appear before
the IJ for a hearing, or whether it would
be incumbent on the noncitizen to
convince the IJ that further legal
argument is necessary in the case. Other
commenters were concerned that the
NPRM did not provide sufficient
guidance as to the structure of the
hearing before an IJ.
Response: As part of the shift from the
NPRM’s proposed IJ review procedure
to streamlined section 240 removal
proceedings, this IFR contains detailed
instructions regarding the mechanics of
these proceedings before the IJ,
including a requirement that IJs hold a
status conference and afford the parties
an opportunity to make additional legal
argument. These provisions are
designed to ensure that these
proceedings are adjudicated efficiently
while at the same time responding to
commenters’ interest in having more
procedural details specified in the
regulation. Specifically, under new 8
CFR 1240.17(b) and (f), the IJ will
conduct at least an initial master
calendar hearing in all cases and will
also conduct a status conference and
possibly receive written statements to
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narrow the issues. Under new 8 CFR
1240.17(f)(2), the noncitizen shall
describe any alleged errors or omissions
in the asylum officer’s decision or the
record of proceedings before the asylum
officer and provide any additional
documentation in support of the
applications. See 8 CFR
1240.17(f)(2)(i)(A)(1)(ii)–(iii). If, under
new 8 CFR 1240.17(f)(4), the IJ
determines that the application cannot
be granted on the documentary record
and the noncitizen has elected to testify
or DHS has elected to cross-examine the
noncitizen or present testimony or
evidence, the IJ will hold an evidentiary
hearing.
Comments: Commenters further
indicated that the NPRM does not
require the Departments to inform the
noncitizen or their counsel that the case
is being reviewed by an IJ.
Response: The Departments disagree
with commenters’ concerns on this
point because, under the NPRM, the
case would only be reviewed by an IJ if
the noncitizen or their counsel first
requested such review. Nevertheless,
the Departments emphasize that any
concerns about the provision of notice
regarding the IJ review are addressed by
this IFR. Under new 8 CFR 1240.17(b),
a noncitizen whose application for
asylum is not granted following an
Asylum Merits interview will receive
notice about the IJ proceedings, because
DHS will serve an NTA on all such
individuals in order to initiate the
section 240 removal proceedings. See
also INA 239(a)(1), 8 U.S.C. 1229(a)(1).
Comments: Commenters stated that,
while a verbatim transcript of the
Asylum Merits interview will be
provided to the IJ, there is no indication
that the noncitizen will have access to
the audio recording of proceedings with
the asylum officer to review for
interpretation errors.
Response: The Departments intend to
make available a process by which
parties to EOIR proceedings under 8
CFR 1240.17 will be able to timely
review, upon request, the recording of
the USCIS Asylum Merits interview. In
addition, noncitizens should follow
EOIR’s procedures to obtain access and
copies of their immigration records after
cases have been docketed with the
immigration courts.
Comment: Another commenter stated
that the NPRM is silent as to whether a
noncitizen’s motion to present further
evidence to the IJ will be considered
applicant-caused delay for purposes of
the EAD clock and urged the
Departments not to penalize noncitizens
in this way for moving to include
further evidence that would be
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necessary to a fair adjudication of their
claim.
Response: The Departments
understand asylum applicants’ desire to
obtain EADs, but neither the NPRM nor
this IFR amends DHS’s procedures
pertaining to the issuance of EADs.
Accordingly, any delay attributable to
an applicant, including a continuance to
obtain evidence sought in immigration
court, will be considered an applicantcaused delay for purposes of EAD
eligibility just as it would under the
status quo.
Comments: Commenters also
expressed concerns that the NPRM ‘‘ties
the hands’’ of the Government and that
these asylum adjudications will be
susceptible to fraudulent and frivolous
claims. Commenters pointed out that
the NPRM requires DHS to proffer
evidence or testimony for an
admissibility ruling but does not
provide a clear opportunity for DHS to
cross-examine noncitizens regarding
evidence the noncitizens may have
relied on during their interviews with
asylum officers.
Response: The Departments disagree
with any allegation that this rule would
increase fraudulent asylum
applications. First, all asylum
applications submitted to USCIS for
initial adjudication by the asylum
officer will be subject to the
consequences of filing a frivolous
application. 8 CFR 208.3(c); see also
INA 208(d)(4), 8 U.S.C. 1158(d)(4).
Second, although the NPRM would have
required both parties to make new
threshold evidentiary showings in order
to submit additional testimony or
evidence before the IJ, the IFR, in new
8 CFR 1240.17(f)(2)(ii) and (f)(3),
provides DHS with an explicit
opportunity in all cases to respond to
any new argument or evidence by the
noncitizen, call witnesses, and submit
additional documentation, including
documentation for rebuttal or
impeachment purposes. In addition,
both the NPRM and IFR in 8 CFR
208.9(c) provide DHS the opportunity to
address credibility concerns with the
applicant during the asylum officer
hearing. Although the hearing before the
asylum officer is nonadversarial, the
asylum officer, a DHS employee, has the
authority to ‘‘present evidence, receive
evidence, and question the applicant
and any witnesses’’ during the
interview. Id. Accordingly, the IFR
maintains certain procedures proposed
in the NPRM and provides additional
procedures that are responsive to
commenters’ concerns.
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c. Immigration Judge’s Discretion To
Vacate Asylum Officer’s Removal Order
As discussed below, commenters
opposed the limitation on noncitizens’
ability to seek other forms of relief or
protection beyond asylum, withholding
of removal, or protection under the CAT
in the proposed IJ review proceedings
unless the noncitizen files a motion to
vacate the removal order entered by the
asylum officer and the IJ grants that
motion as a matter of discretion. See 8
CFR 1003.48(d) (proposed).
Comments: Commenters opposed the
limitation on noncitizens’ ability to seek
other forms of relief or protection
beyond asylum, withholding of removal,
or protection under the CAT in the
proposed IJ review proceedings unless
the noncitizen files a motion to vacate
the removal order entered by the asylum
officer and the IJ grants that motion as
a matter of discretion. See 8 CFR
1003.48(d) (proposed).
Commenters pointed out that
noncitizens frequently apply for other
forms of immigration relief, such as
Special Immigrant Juvenile
classification, T nonimmigrant status, or
U nonimmigrant status concurrently
with their applications for asylum,
withholding, and protection under the
CAT, and expressed a range of concerns
that the rule would limit the ability of
noncitizens to pursue these types of
statutorily-available statuses in the
proposed limited IJ review proceedings,
which commenters stated was contrary
to congressional intent to provide other
forms of relief or protection.
First, commenters said that the
NPRM’s proposed procedure for a
discretionary motion to vacate a
removal order and transfer the
noncitizen to section 240 proceedings is
insufficient and that the NPRM would
effectively cut off access to these
remedies for vulnerable applicants. For
example, commenters speculated that
unrepresented or child applicants
would be unable to meet the procedural
requirements for filing the proposed
motion, such as a showing of prima
facie eligibility. Commenters also noted
that some forms of relief are much
harder to seek if the applicant is
removed than they would be if the
applicant could have sought them
during the proceedings before the IJ. For
example, it could be difficult to confer
with an attorney with the relevant
expertise while abroad.
Second, commenters found the
discretionary motion requirement
inefficient. Commenters noted that
applicants who seek collateral relief
before USCIS, such as T or U
nonimmigrant status, often seek
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administrative closure or termination of
the immigration court proceedings
while those applications are
adjudicated. Because these cases are
then off the IJ’s docket, administrative
closure or termination in these cases
serves the stated goal of efficiency in
immigration proceedings, but the NPRM
would not allow for this efficiency.
Third, commenters noted that the rule
would effectively prevent individuals
who become eligible for other relief
during appeal from seeking it because
they would not have sought to have the
case transferred to section 240
proceedings in a timely manner.
Commenters asserted that the NPRM
provides no justification for this
punitive and burdensome change in
opportunity for an asylum applicant
whose case originated in credible fear
screening to seek other relief for which
they may become eligible while the case
is on appeal.
Finally, commenters further stated
that limiting or denying access to all
forms of complementary protection
conflicts with international standards.
Response: As explained above in
Section III of this preamble, the
Departments are not adopting the IJ
review procedure proposed in the
NPRM; instead, this IFR provides that
noncitizens whose applications for
asylum are not granted by an asylum
officer will be issued an NTA and
referred to an IJ for further review of
their applications in a streamlined
section 240 removal proceeding. Under
the new 8 CFR 1240.17(k)(2),
noncitizens who provide evidence of
prima facie eligibility for forms of relief
or protection other than asylum,
withholding of removal, protection
under the CAT, and voluntary departure
and who either seek to apply or have
applied for such relief or protection will
be exempted from the timelines
applicable in these streamlined
proceedings. The IJ will then consider
the noncitizen’s eligibility for relief as
in section 240 proceedings generally.
See, e.g., 8 CFR 1240.1(a)(1)(ii)
(providing the IJ with the authority to
determine a wide range of applications
for relief or protection). Further, there
will no longer be an intervening
requirement for the noncitizen to file a
discretionary motion to vacate the
asylum officer’s removal order and for
the IJ to grant such a motion before the
noncitizen may seek additional forms of
relief or protection. Instead, under new
8 CFR 1240.17(k)(2), noncitizens who
produce evidence of prima facie
eligibility and submit or intend to
submit an application or petition for
another form of relief or protection will
be exempt from the streamlined
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procedure set out in the IFR.
Accordingly, the shift to streamlined
section 240 proceedings addresses
commenters’ concerns about the motion
process and limitation on the available
forms of relief or protection for
noncitizens in these proceedings.
Comments: Commenters were
concerned that the proposal to require a
motion for the IJ to vacate the removal
order is a new process that will waste
Government resources by adding
another motion for IJs to review and that
it would likely generate additional
rounds of appeals. Commenters stated
that it would be more efficient to
instead allow an IJ to decide the entire
matter in front of them without being
forced to ignore or exclude other
information that would show removal is
unwarranted.
Similarly, rather than a process that
requires the applicant to identify other
grounds of immigration eligibility
beyond the three enumerated in 8 CFR
1003.48(a), as set out in the NPRM,
commenters argued that it would be
fairer and more efficient if the asylum
officer and the IJ could inquire about all
possible grounds during their respective
hearings. Commenters further suggested
that the Departments revise the NPRM
to have the asylum office refer all cases
not granted asylum to section 240
removal proceedings.
Response: The Departments believe
that these commenter concerns will be
addressed by this IFR, which establishes
that noncitizens who are not granted
asylum after an Asylum Merits
interview will be placed into
streamlined section 240 removal
proceedings, rather than the IJ review
proceedings proposed by the NPRM.
Under the IFR, asylum officers will not
issue removal orders that would need to
be vacated by the IJ. Rather, a noncitizen
will not be ordered removed until after
the IJ has reviewed the asylum officer’s
decision and concluded that the
noncitizen does not warrant asylum.89
Additionally, the noncitizen need not
affirmatively request or seek review of
the asylum officer’s decision. Rather,
89 A respondent who fails to appear for their
hearing, however, may be ordered removed in
absentia for failure to appear. See INA 240(b)(5)(A),
8 U.S.C. 1229a(b)(5)(A). As discussed above in
Section III of this preamble, under new 8 CFR
1240.17(d), if the asylum officer had determined
that a respondent who fails to appear before the IJ
was eligible for statutory withholding of removal or
protection under the CAT, the IJ will issue an inabsentia removal order and generally will give
effect to protection for which the asylum officer
found the respondent eligible, unless DHS makes a
prima facie showing, through evidence that
specifically pertains to the respondent and was not
in the record of proceedings for the USCIS Asylum
Merits interview, that the respondent is not eligible
for such protection.
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under new 8 CFR 1240.17(a) and (b), if
the asylum officer does not grant
asylum, DHS will serve the applicant
with an NTA and initiate a streamlined
section 240 removal proceeding by
filing the NTA with the immigration
court. Further, just as in all proceedings
governed by section 240 of the Act, 8
U.S.C. 1229a, noncitizens may seek
other forms of relief or protection, and
the IJ will consider additional possible
grounds for relief or protection beyond
asylum, withholding of removal, and
protection under the CAT. See 8 CFR
1240.11(a)(2) (‘‘The immigration judge
shall inform the [noncitizen] of his or
her apparent eligibility to apply for any
of the benefits enumerated in this
chapter and shall afford the [noncitizen]
an opportunity to make application
during the hearing . . . .’’). Further,
under new 8 CFR 1240.17(k)(2), the
proceedings for noncitizens who apply
for other forms of relief or protection
and produce evidence of prima facie
eligibility will not be subject to the same
expedited procedures detailed in this
IFR for these proceedings generally.
Comments: Commenters expressed
concerns that the NPRM’s requirement
for applicants to file a motion before
they may seek additional forms of relief
or protection would prejudice
noncitizens who are without counsel or
do not speak English because these
noncitizens would likely be unaware of
their eligibility for additional forms of
relief or protection, would be unaware
of the option to file a motion for vacatur,
or would not realistically be able to file
such motions. Specifically, at least one
commenter argued that the NPRM
would lead to due process violations by
denying noncitizens the right to seek
relief or protection for which they might
be eligible. Similarly, commenters
argued that the NPRM’s time and
number limitations on motions for
section 240 removal proceedings raise
due process concerns for noncitizens
with disabilities or PTSD, or those who
speak rare languages.
Commenters further expressed
concern that pro se individuals would
be particularly harmed by the NPRM’s
rules for the motion to vacate. For
example, one commenter noted that a
pro se noncitizen who previously
moved unsuccessfully to vacate with
insufficient evidence or argument
would be precluded from filing any
additional evidence or an additional
motion, even if the noncitizen later
obtained the help of an attorney or
representative who is able to show
prima facie eligibility for asylum or
protection. Instead, commenters
suggested that asylum applicants should
be allowed to make more than one
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18177
motion to show they are eligible for a
different form of relief or protection.
Commenters asserted that this change
will not significantly impact the
efficiency of IJ review because most
asylum seekers requesting further
review do not usually have a claim to
a different form of relief from removal.
Response: The IFR’s changes from the
NPRM address commenter concerns
about the impact of the motion to vacate
requirement on pro se and non-English
speaking noncitizens. Specifically, as
discussed elsewhere, the IFR establishes
that USCIS will affirmatively refer all
applicants whose applications are not
granted by the asylum officer to
streamlined section 240 removal
proceedings for adjudication by an IJ.
Adjudication by the IJ is automatic upon
DHS’s filing of the NTA with the
immigration court. Additionally, as in
all proceedings governed by section 240
of the Act, DOJ’s regulations allow
noncitizens to seek other forms of relief
or protection, without first filing a
motion, and the IJ will consider
additional possible grounds for relief or
protection beyond asylum, withholding
of removal, and protection under the
CAT. See 8 CFR 1240.11(a)(2) (‘‘The
immigration judge shall inform the
[noncitizen] of his or her apparent
eligibility to apply for any of the
benefits enumerated in this chapter and
shall afford the [noncitizen] an
opportunity to make application during
the hearing . . . .’’); see also Quintero,
998 F.3d at 623–24 (collecting cases
discussing an IJ’s affirmative duty to
develop the record). Further, pursuant
to new 8 CFR 1240.17(k)(2), the
proceedings for noncitizens who apply
for other forms of relief or protection
and produce evidence of prima facie
eligibility will not be subject to the same
expedited timeline procedures detailed
in this IFR for these expedited
proceedings generally. No motion is
necessary to demonstrate prima facie
eligibility because the IJ could make
such determination based on oral
representations or information
otherwise provided to the IJ.
In addition, as noted above, the IFR,
as provided in new 8 CFR 1240.17(k)(6),
excepts respondents who have exhibited
indicia of incompetency from these
streamlined section 240 proceedings.
These respondents would instead be
placed in ordinary section 240
proceedings.
Comments: Commenters disagreed
with the NPRM’s approach that
applicants who may be eligible to seek
some other form of relief or protection
beyond asylum, withholding of removal,
and protection under the CAT would be
able to do so only after the completion
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of a full asylum application and
interview. Commenters explained that
this approach would force applicants to
relive and testify in depth about
traumatic events in their lives relevant
to their asylum claims, even if they have
alternative avenues to relief—such as T
nonimmigrant status or SIJ
classification—that do not require inperson hearings and would not lead to
possible re-traumatization.
At least one commenter disagreed
with the NPRM’s lack of a provision
regarding continuances for a noncitizen
to obtain evidence of the additional
relief or protection for which they may
be eligible. The commenter noted that it
often takes months to obtain relevant
evidence, but under the NPRM,
noncitizens may be forced to go forward
with IJ review before this process is
complete. Additionally, commenters
objected to the proposed limitations
providing for only one motion for
vacatur and requiring that the filing
would have to precede a determination
on the merits of the protection claim.
Commenters argued that these
limitations would effectively force
applicants to choose which remedy they
wish to seek before their appellate rights
are exhausted with respect to the
asylum, statutory withholding, and CAT
claims. Commenters stated that
requiring the motion to be filed prior to
the IJ’s decision on eligibility for asylum
or related protection undermines the
Departments’ goal of balancing fairness
and efficiency.
Commenters suggested that there
should be exceptions to the time and
numerical limitations on the proposed
motion for vacatur to account for
scenarios such as those in which (1) the
noncitizen receives ineffective
assistance of counsel, (2) new facts exist
that give rise to new fears and forms of
relief or protection, (3) updates to
immigration laws are made, or (4) other
unusual circumstances arise.
Response: The IFR’s changes from the
NPRM, as discussed above in Section III
of this preamble, address commenters’
concerns with the NPRM’s proposals
related to the timing and number limits
for motions to vacate the asylum
officer’s removal order. Specifically,
because asylum officers will not be
issuing removal orders and applicants
instead will be placed in streamlined
section 240 removal proceedings,
noncitizens may seek other forms of
relief or protection beyond asylum,
withholding of removal, and protection
under the CAT, without an intervening
motion or other threshold requirement
like that set out by the NPRM. See 8
CFR 1240.11(a)(2) (‘‘The immigration
judge shall inform the [noncitizen] of
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his or her apparent eligibility to apply
for any of the benefits enumerated in
this chapter and shall afford the
[noncitizen] an opportunity to make
application during the hearing[.]’’).
Should noncitizens request a
continuance to obtain evidence of prima
facie eligibility for other forms of relief
or protection, the base standard for
continuances in streamlined section 240
proceedings will continue to be good
cause, as provided in new 8 CFR
1240.17(h)(2)(i). However, as discussed
above in Section III of this preamble, the
aggregate length of continuances for
good cause is capped at 30 days, as
provided in new 8 CFR 1240.17(h)(2)(i)
and (h)(3). Additional continuances
beyond 30 days will require a
heightened showing, as provided in new
8 CFR 1240.17(h)(2)(ii)–(iii).
Further, under new 8 CFR
1240.17(k)(2), the proceedings for
noncitizens who apply for other forms
of relief or protection and produce
evidence of prima facie eligibility will
not be subject to the same streamlined
procedures detailed in this IFR. In
addition, for such cases, IJs may utilize
the same common docket-management
tools as those generally used in section
240 removal proceedings, such as
continuances and administrative
closure, in appropriate cases where a
noncitizen may be eligible for
alternative forms of relief, such as
adjustment of status under section 245
of the Act, 8 U.S.C. 1255.
With respect to commenters who
expressed concern about the possible
trauma that noncitizens might endure
from testifying, the Departments note
that the IFR does not require
noncitizens to testify before the IJ.
Rather, it gives noncitizens the
opportunity to provide further
testimony should they wish to do so.
Thus, as provided in new 8 CFR
1240.17(f)(2)(i), if noncitizens feel that
they have had adequate opportunity to
articulate the nature of their claims
before the asylum officer, they need not
elect to further testify and may rest on
the record of proceedings before the
asylum officer. Additionally, the IFR
provides in new 8 CFR 1240.17(f)(2) that
the parties will engage in a status
conference prior to the merits hearing
during which the parties will narrow
the issues in dispute. In some instances,
the IJ may determine that the
application can be decided on the
documentary record without additional
testimony from the noncitizen. Id.
Further, under new 8 CFR
1240.17(f)(2)(ii), DHS may decide not to
contest certain issues, and noncitizens
need not testify about sensitive issues
that DHS does not contest. The
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Departments also note that both asylum
officers and IJs undergo ongoing training
and support to promote the quality of
adjudications and to prepare them to
address sensitive claims. Asylum
officers who conduct interviews are
required by regulation to undergo
‘‘special training in international human
rights law, nonadversarial interview
techniques, and other relevant national
and international refugee laws and
principles.’’ 8 CFR 208.1(b). Asylum
officers are also required to determine
that noncitizens are able to participate
effectively in their interviews before
proceeding. 8 CFR 208.30(d)(1), (5).
These DHS regulations are intended to
recognize and accommodate the
sensitive nature of fear-based claims and
to foster an environment in which
noncitizens may express their claims to
an asylum officer. Similarly, IJs must
undergo comprehensive, ongoing
training, as provided in DOJ’s existing
regulations. 8 CFR 1003.0(b)(1)(vii). IJs
are further directed to conduct hearings
in a manner that would not discourage
a noncitizen from presenting testimony
on difficult subject matter. See OPPM
17–03: Guidelines for Immigration Court
Cases Involving Juveniles, Including
Unaccompanied Alien Children 3 (Dec.
20, 2017) (‘‘Every [IJ] should employ
age-appropriate procedures whenever a
juvenile noncitizen or witness is present
in the courtroom.’’); Matter of J–R–R–A–
, 26 I&N Dec. 609, 612 (BIA 2015)
(‘‘[W]here a mental health concern may
be affecting the reliability of the
applicant’s testimony, the [IJ] should, as
a safeguard, generally accept that the
applicant believes what he has
presented, even though his account may
not be believable to others or otherwise
sufficient to support the claim.’’); Matter
of Y–S–L–C–, 26 I&N Dec. 688, 690–91
(BIA 2015) (‘‘Conduct by an [IJ] that can
be perceived as bullying or hostile can
have a chilling effect on a [noncitizen’s]
testimony and thereby limit his or her
ability to fully develop the facts of the
claim . . . . [S]uch treatment of any
[noncitizen] is never appropriate[.]’’).
DHS retains the option to issue an NTA
to place the noncitizen in ordinary
section 240 removal proceedings prior
to the Asylum Merits interview, and it
could do so if the applicant appears to
have a strong claim for a form of relief
or protection that the asylum officer
cannot grant. This procedure would be
another means of preventing the
applicant from having to testify twice.
Comments: Several commenters
expressed concern that the proposed
motion to vacate removal orders would
be left to the discretion of the IJ, even
if the applicant had established prima
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facie eligibility for a different form of
relief from removal. In particular,
commenters stated that the NPRM did
not make clear how that discretion
should be exercised. Commenters
argued that the ability to appeal such
denials to the BIA would not be a
sufficient safeguard because of the
complexity of filing an appeal for some
applicants. Commenters asserted that
the discretionary nature of the motion
would result in the wrongful removal of
noncitizens with available relief, which
would run afoul of due-process
obligations. Further, some commenters
worried that DHS could exercise
discretion not to refer an applicant to
section 240 removal proceedings even if
an IJ were to grant a motion to vacate.
Response: The IFR’s changes from the
NPRM, as discussed above in Section III
of this preamble, address commenters’
concerns with the NPRM’s proposed
framework under which both the IJ and
DHS would make discretionary
determinations in the context of a
motion to vacate. First, under the IFR,
when an asylum officer does not grant
asylum, DHS will serve an applicant
with an NTA and initiate streamlined
section 240 removal proceedings by
filing the NTA with the immigration
court. See 8 CFR 208.14(c). Second, as
recognized in new 8 CFR 1240.17(k)(2),
because applicants will be referred to
streamlined section 240 removal
proceedings, they may seek other forms
of relief or protection beyond asylum,
withholding of removal, and protection
under the CAT, without an intervening
motion or other threshold requirement
like that set out by the NPRM. See also
8 CFR 1240.11(a)(2) (‘‘The [IJ] shall
inform the [noncitizen] of his or her
apparent eligibility to apply for any of
the benefits enumerated in this chapter
and shall afford the [noncitizen] an
opportunity to make application during
the hearing[.]’’). Finally, as provided in
new 8 CFR 1240.17(k)(2), noncitizens
who produce evidence of prima facie
eligibility for relief or protection other
than asylum, withholding of removal,
protection under the CAT, or voluntary
departure and indicate an intent to
apply for, or who have applied for, such
form of relief or protection will be
excepted from these streamlined section
240 proceedings and have their cases
adjudicated under the standard
processes. Accordingly, noncitizens
who are eligible to seek forms of relief
or protection other than asylum,
withholding of removal, and protection
under the CAT do not have to receive
a favorable discretionary grant in order
to do so.
Comments: Commenters asserted that
the NPRM’s proposed differing
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treatment of various categories of
asylum seekers is unfairly arbitrary. For
example, commenters feared that the
eligibility of asylum seekers to apply for
any form of relief or protection—rather
than just asylum, statutory withholding
of removal, and protection under the
CAT—would be based solely on how
CBP and ICE have exercised discretion
to process noncitizens on a given day.
Commenters argued that the
Departments should allow IJs to grant
motions to vacate removal orders both
where the noncitizen would be eligible
to apply for relief or protection if in a
section 240 proceeding and where the
noncitizen would be eligible to apply
for collateral relief adjudicated by
USCIS because it did not appear that an
IJ would have the authority to terminate
a case under the NPRM.
Commenters also urged that a
noncitizen should be allowed to file an
interlocutory appeal to the BIA if an IJ
denied a motion to vacate under the
NPRM.
Finally, commenters requested a
clarification and rationale for the
NPRM’s prohibition on a motion to
vacate premised on an application for
voluntary departure. Commenters
expressed concern that, if neither USCIS
nor EOIR can grant voluntary departure,
individuals could be separated from
their families or otherwise negatively
affected.
Response: The IFR’s changes from the
NPRM, as discussed above in Section
III.D of this preamble, address
commenters’ concerns with the NPRM’s
motion to vacate framework. First,
under the IFR, any applicant not granted
asylum by an asylum officer after an
Asylum Merits interview will be served
with an NTA and placed in streamlined
section 240 removal proceedings
without the need to request an IJ’s
review.90 Accordingly, individuals in
streamlined section 240 proceedings
will be able to apply for all forms of
relief or protection for which they may
be eligible, including voluntary
departure, thus addressing commenters’
concerns on this issue.
90 To the extent that commenters’ concerns relate
to the general discretion of DHS to determine
whether to place an applicant for admission in
expedited removal under section 235 of the Act, 8
U.S.C. 1235, or to issue an NTA and refer the
applicant to section 240 proceedings, commenters’
concerns are beyond the scope of this rule. See, e.g.,
Matter of M–S–, 27 I&N Dec. 509, 510 (A.G. 2019)
(‘‘[I]f the [noncitizen] is inadmissible on one of two
specified grounds and meets certain additional
criteria, DHS may place him in either expedited or
full proceedings.’’).
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d. Immigration Judge’s Authority To
Review All Asylum Officer Decisions
Comments: Commenters stated that
asylum applicants who were not granted
asylum but were granted withholding of
removal or CAT protection may be
deterred from seeking IJ review because
of the possibility of being denied all
relief or protection and removed.
Commenters stated that such deterrence
is particularly inappropriate for
individuals granted withholding of
removal or CAT protection because they
are unable to travel abroad or petition
for relatives to follow to the United
States. Commenters also stated that the
proposed rule would leave those
granted withholding of removal or CAT
protection by the asylum officer with a
difficult choice of seeking review and
potentially being removed to their
country of feared harm or facing
permanent separation from family
members. Overall, commenters
expressed concern that the proposal
could have a chilling effect on the
decision to seek review of an asylum
officer’s decision to not grant asylum
where doing so would require risking
the loss of already-issued protection,
citing international treaty obligations to
not return refugees to countries where
they might suffer persecution or torture.
Other commenters were concerned that
an asylum applicant would not receive
notice that seeking review of an asylum
officer’s decision to not grant asylum
could also result in IJ review of granted
protections.
Some commenters asserted that
requiring IJs to review grants of
protection is contrary to the rule’s stated
goals of improving efficiency and
addressing the immigration court
backlog. Commenters argued that it is
inefficient to require an IJ to revisit
portions of the asylum officer’s decision
that neither party has requested the IJ
review and observed that granted cases
can and will be reviewed upon the
asylee’s application for permanent
residence. Other commenters stated that
an IJ’s unilateral decision to reverse
protections that were granted by an
asylum officer would undercut the IJ’s
role as a neutral arbiter.
Commenters asserted that allowing IJs
to review grants of protection is
inconsistent with the principles of
adversarial adjudication. Commenters
noted that the proposed rule would
have DHS (as the adverse party to an
asylum seeker in immigration court)
argue that a benefit was wrongfully
granted by another DHS component
(USCIS) and asserted that it would be
irrational for ICE to argue in this manner
before EOIR that another component of
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DHS erred in its decision-making.
Similarly, commenters argued that the
executive branch cannot contest a
decision also issued by the executive
branch, asserting that the same
reasoning has long applied to the
prohibition on DHS seeking judicial
review of BIA decisions in Federal
court. According to commenters, this
aspect of the rule would discourage
cooperation between the parties to
narrow the issues or stipulate to relief,
resulting in unnecessary court battles
and delay.
Commenters argued that it would be
inequitable for DHS to obtain automatic
review of a grant of withholding of
removal or CAT protection when
noncitizens do not obtain automatic
review of denials. Some commenters
also worried that authorizing, but not
requiring, IJs to review withholding of
removal and CAT decisions risks
inconsistent revocation of these benefits
if some IJs decide to conduct this review
and others do not, arguing that the risk
of arbitrarily and permanently
separating families outweighs any
efficiency concerns.
Commenters also asserted that ‘‘mixed
cases’’ could create confusion for
noncitizens attempting to request
review of their case before U.S. Courts
of Appeals. For example, commenters
stated that IJs could reverse the denial
of withholding of removal but leave the
asylum denial and order of removal on
the basis of prior grounds of
inadmissibility undisturbed.
Commenters worried that, in such cases,
noncitizens requesting review before
courts of appeal would likely exceed the
‘‘mandatory and jurisdictional’’ 30-day
limit to review their asylum denial and
accompanying removal order. Finally,
commenters asserted that these
procedural hurdles would deter pro
bono attorneys from taking cases.
Response: As described above in
Section III of this preamble, this IFR
does not adopt the NPRM’s proposed IJ
review procedure and instead
implements streamlined section 240
removal proceedings in new 8 CFR
1240.17. One consequence of this
change from the NPRM, which the
Departments emphasize was requested
by the majority of those who
commented on this aspect of the NPRM,
is that the asylum officer will not issue
orders of removal or grant withholding
of removal or protection under the CAT.
Rather, because the IJ will issue orders
of removal, the IJ will also grant or deny
withholding of removal and protection
under the CAT. See Matter of I–S– & C–
S–, 24 I&N Dec. 432, 434 (BIA 2008)
(‘‘[W]hen an [IJ] decides to grant
withholding of removal, an explicit
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order of removal must be included in
the decision.’’).
Nevertheless, asylum officers will
continue to consider the applicant’s
eligibility for withholding of removal
and protection under the CAT during
the Asylum Merits interviews and, if
they do not grant the application for
asylum, will indicate whether the
applicant has demonstrated eligibility
for withholding of removal or protection
under the CAT based on the record
before USCIS. See 8 CFR 208.14(c)(1); 8
CFR 208.16(a). Upon an asylum officer’s
decision to not grant asylum, the
noncitizen is placed in streamlined
section 240 removal proceedings. The
IFR provides that the IJ will schedule a
status conference where the noncitizen
will indicate whether the noncitizen
intends to contest removal or seek any
protections for which the asylum officer
did not determine that the noncitizen
was eligible. If the noncitizen does not
intend to contest removal or seek any
protections for which the asylum officer
did not determine that the noncitizen
was eligible, the IJ will order the
noncitizen removed. If the asylum
officer determined that the noncitizen
was eligible for withholding of removal
or protection under the CAT, the IJ will
give effect to the protection for which
the asylum officer determined that the
noncitizen was eligible, subject to the
ability of DHS to present new evidence
establishing that the applicant is not
eligible for protection.
However, the noncitizen can elect to
contest removal or seek protections that
were not granted by the asylum officer.
Where the asylum officer did not grant
the application for asylum and
determined that the applicant is not
eligible for statutory withholding of
removal or withholding or deferral of
removal under the CAT, the IJ will
review each of the applications de novo
as provided in new 8 CFR 1240.17(i)(1).
Where the asylum officer did not grant
asylum but determined that the
applicant was eligible for statutory
withholding of removal or protection
under the CAT, the IJ will adjudicate the
application for asylum de novo, as
provided in new 8 CFR 1240.17(i)(2).
Further, under new 8 CFR 1240.17(i)(2),
if the IJ denies asylum and enters an
order of removal, the IJ will also issue
an order giving effect to the protections
for which the asylum officer determined
that the noncitizen was eligible, unless
DHS affirmatively demonstrates through
evidence or testimony that specifically
pertains to the respondent and that was
not included in the record of
proceedings for the USCIS Asylum
Merits interview that the noncitizen is
not eligible for such protection. The IJ
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will grant any protections for which the
IJ finds the noncitizen eligible.
The Departments believe that these
procedures outlined in the IFR address
many concerns of the commenters while
also promoting efficiency in
governmental processes. First, the IFR
does not allow the IJ to reconsider sua
sponte relief or protection for which the
asylum officer determined the
noncitizen was eligible. Instead, under
new 8 CFR 1240.17(i)(2), if the
noncitizen elects to contest removability
or the asylum officer’s determination,
the burden shifts to DHS to present
evidence showing that evidence or
testimony not included in the asylum
officer record and specifically
pertaining to the noncitizen establishes
that the noncitizen is not eligible for the
relief or protection. The Departments
believe it is necessary for DHS to be able
to revisit the issue of eligibility in
special circumstances, such as when
there may be evidence of fraud or new
derogatory information affecting
eligibility. As explained above, the
Departments believe that, without a
process for DHS to address such issues
in the streamlined section 240 removal
proceedings, DHS would otherwise have
to follow the procedures in 8 CFR
208.17(d) and 208.24(f) in instances
where overturning the asylum officer’s
eligibility determination is justified.
e. Appeal of Immigration Judge’s
Decision to the Board of Immigration
Appeals
Comments: Some commenters
expressed support for the appeal
procedures in the NPRM.
Other commenters expressed concern
that, without a traditional immigration
court hearing transcript to review, BIA
and Federal court review would be
cursory. Similarly, commenters asserted
that the BIA and Federal court review
under the NPRM would be meaningless
because they believed such review
would be conducted on the basis of a
partial, incomplete record and that, in
many cases, there would be initial
rounds of litigation regarding
application of the NPRM’s limitations
on the introduction of evidence.
Response: As discussed above in
Section III of this preamble, under this
IFR, applicants not granted asylum by
the asylum officer after an Asylum
Merits interview will be referred to
streamlined section 240 removal
proceedings before the immigration
court. This change from the NPRM
addresses commenters’ concerns about
the effect of the nature of the IJ review
proceedings set out in the NPRM on any
subsequent BIA or appellate review.
Under the IFR, in new 8 CFR 1240.17(a)
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and (g)(1), noncitizens will be afforded
longstanding procedural protections and
due process safeguards inherent in
section 240 proceedings, including the
right to representation at no cost to the
Government and the rights to present
evidence and testimony. See INA
240(b)(4)(A)–(B), 8 U.S.C.
1229a(b)(4)(A)–(B). More specifically,
under new 8 CFR 1240.17(a),
noncitizens will have the opportunity to
be heard at scheduled hearings and the
ability to develop the record by
presenting evidence that is timely
submitted, relevant, probative, and not
fundamentally unfair. Furthermore,
under new 8 CFR 1240.17(g)(2), IJs may
consider late-filed evidence that is filed
before the IJ issues a decision in the case
if it could not reasonably have been
obtained and presented before the
deadline through the exercise of due
diligence. A complete record of all
evidence and testimony will be kept in
accordance with the standard
procedures for section 240 proceedings.
INA 240(b)(4)(C), 8 U.S.C.
1229a(b)(4)(C). This includes but is not
limited to: (1) The record of proceedings
before the asylum office, as outlined in
8 CFR 208.9(f); (2) a written statement,
if any, from the noncitizen describing
any alleged errors and omissions in the
asylum officer’s decision or the record
of proceedings before the asylum office;
and (3) documentation and testimony in
support of the application for relief or
protection. The Departments believe
that this requirement will alleviate
procedural concerns and ensure that the
BIA will have a full record on appeal
and that U.S. Courts of Appeals will
have a full record in a petition for
review.
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f. Other Comments on Proposed
Application Review Proceedings Before
Immigration Judges
Comments: Commenters urged the
Departments to remove the regulatory
language that would permit the
immigration court to reject an asylum
application if proof of payment of the
fee, if required, is not submitted, citing
proposed 8 CFR 1208.3(a)(2).
Commenters asserted that asylum
applications should never require a fee
because seeking safety from persecution
is a fundamental human right and
refusing asylum applicants for the
inability to pay would effectively cause
the United States to abrogate its
international obligations. Stating that
the prior Administration’s fee rule is
enjoined, commenters suggested that the
Departments should not leave open the
possibility for future administrations by
explicitly including the possibility of an
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asylum application fee in this proposed
regulation.
Response: As noted in the NPRM, the
Departments published numerous rules
in recent years that have been vacated,
enjoined, or otherwise delayed. 86 FR
46909 n.24. Two such rules are final
rules regarding application fees issued
by DHS and DOJ, respectively. See U.S.
Citizenship and Immigration Services
Fee Schedule and Changes to Certain
Other Immigration Benefit Request
Requirements, 85 FR 46788 (Aug. 3,
2020) (enjoined by Immigrant Legal Res.
Ctr. v. Wolf, 491 F. Supp. 3d 520 (N.D.
Cal. 2020), and Nw. Immigrant Rts.
Project v. United States Citizenship &
Immigr. Servs., 496 F. Supp. 3d 31
(D.D.C. 2020), appeal dismissed, No.
20–5369, 2021 WL 161666 (DC Cir. Jan.
12, 2021)); Executive Office for
Immigration Review; Fee Review, 85 FR
82750 (Dec. 18, 2020) (partially enjoined
by Cath. Legal Immigr. Network, Inc. v.
Exec. Off. for Immigr. Rev., 513 F. Supp.
3d 154 (D.D.C. 2021)).
Language regarding the submission of
an application fee, if any, for
applications for asylum was included in
the latter rule. 8 CFR 1208.3(c)(3); see
also 85 FR 82765–69 (discussing
commenters’ concerns regarding an
application fee for asylum applications).
The NPRM proposed to amend the
regulations only as necessary to
effectuate the changes related to the
credible fear and asylum adjudication
processes as explained in the NPRM and
this IFR. See, e.g., 86 FR 46914 n.38. As
a result, the NPRM did not include any
proposed edits regarding the asylum
application fee-related language in
§ 1208.3(c)(3).91 The language related to
the payment of an asylum application
fee, if any, was included simply as
surrounding regulatory text that was
reprinted to ensure correct amendments
to the language related to the credible
fear and asylum adjudication processes.
DOJ, however, will be considering
additional changes to the regulations
regarding the applicable fees for
applications and motions during EOIR
proceedings. See Executive Office of the
President, OMB, OIRA, Fall 2021
Unified Agenda of Regulatory and
Deregulatory Actions, https://
www.reginfo.gov/public/do/
eAgendaViewRule?pubId=202110&
RIN=1125-AB19 (last visited Mar. 9,
2022).
Comments: Commenters urged the
Departments to rescind the provisions of
the Global Asylum rule that expressly
91 The commenter is incorrect that the
Department included language regarding an
application fee for applications for asylum at 8 CFR
1208.3(a)(2).
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permit pretermission of asylum claims
and to enact a broad regulatory bar on
the practice. At a minimum,
commenters asked the Departments to
expressly prohibit IJs from pretermitting
asylum applications upon review from
asylum officers’ decisions to not grant
asylum, arguing that allowing IJs to do
so under the proposed system of
minimal process would violate the
Constitution.
Response: As stated above, the NPRM
only proposed to amend provisions of
prior rulemakings to the extent
necessary to implement the proposed
changes related to the credible fear and
asylum adjudication processes. See, e.g.,
86 FR 46914 n.38. The provisions
referenced by commenters at 8 CFR
1208.13(e) regarding pretermission of
applications were added by the
Departments as part of a separate
rulemaking known as the Global
Asylum rule. See 85 FR 80274. Because
this provision is beyond the scope of the
changes needed to effectuate the
credible fear and application review
processes included in the NPRM, the
Departments are not including any
changes to this provision at this point.
However, the Departments will consider
whether to modify or rescind 8 CFR
1208.13(e) and the other remaining
portions of the regulations affected by
enjoined regulations in future
rulemakings. See, e.g., Executive Office
of the President, OMB, OIRA, Fall 2021
Unified Agenda: Department of Justice,
https://www.reginfo.gov/public/do/
eAgendaMain?operation=OPERATION_
GET_AGENCY_RULE_LIST&
currentPub=true&agencyCode=&
showStage=active&agencyCd=1100&
csrf_token=1F5E59171165
D9C756F8D13DB0280F16BF4E61995
A08C2DA5251225495
FD83335EE930292724E7EF24BEB50141
CF0AC59747 (last visited Mar. 1, 2022).
Comments: Commenters urged the
Departments to preserve Federal court
review of asylum cases in any asylum
process, stressing that judicial review
protects refugees from politicized
policies, rushed administrative
decision-making, or discriminatory
factual and legal interpretations and
provides judicial oversight of
administrative adjudications with lifeor-death consequences. Some
commenters argued that the proposed
rule does not provide adequate
appellate protections for asylum
seekers, explaining that the provision of
the NPRM subjecting asylum seekers to
expedited removal under INA 235(b)(1),
8 U.S.C. 1225(b)(1), unless and until
they are granted asylum, could be found
by courts to trigger the INA’s
jurisdiction-stripping provision relating
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to expedited removal. See INA
242(a)(2)(A), 8 U.S.C. 1252(a)(2)(A).
Specifically, commenters expressed
concern that some courts might view a
challenge to the denial of an asylum
application that affirms an expedited
order of removal and denies all relief or
protection as asking the court ‘‘to review
. . . any individual determination or to
entertain any other cause or claim
arising from or relating to the
implementation or operation of an order
of removal pursuant to [INA 235(b)(1),
8 U.S.C. 1225(b)(1)],’’ claims for which
the statute bars jurisdiction. See INA
242(a)(2)(A), 8 U.S.C. 1252(a)(2)(A).
Commenters asserted that the statute
authorizes only two processes for the
issuance of a removal order: (1) An
expedited removal order under INA
235(b)(1), 8 U.S.C. 1225(b)(1), for which
judicial review is barred; and (2) a
removal order entered in proceedings
under INA 240, 8 U.S.C. 1229a, for
which judicial review is available but
which the NPRM expressly proposed
not to use. As such, according to
commenters, the Departments’
simultaneous assertion that INA
235(b)(1), 8 U.S.C. 1225(b)(1) provides
the authority to create the proposed
procedures while at the same time
stating that an order of removal issued
pursuant to those procedures is not ‘‘an
order of removal pursuant to [INA
235(b)(1), 8 U.S.C. 1225(b)(1)]’’ could
raise questions about the availability of
judicial review.
Commenters also expressed concern
that, even if this Administration is
committed to interpreting the proposed
rule as allowing for judicial review, a
future administration could advise
counsel at ICE and DOJ to interpret the
rule more narrowly and argue that
judicial review is not available.
According to commenters, the
possibility that the proposed rule could
inadvertently deprive asylum seekers of
judicial review is another reason to
ensure that those not granted asylum by
an asylum officer after passing a
credible fear screen are referred to
proceedings under INA 240, 8 U.S.C.
1229a.
Finally, some commenters questioned
what items the Federal courts would
review, even if there is no jurisdictional
hurdle to review by a U.S. Court of
Appeals. Asserting that the circuit
courts of appeals are used to reviewing
records that include full immigration
court hearing transcripts, commenters
expressed concern that, under the
proposed rule, courts of appeals would
review a written decision of the BIA,
which reviewed an IJ’s review of an
asylum officer’s decision. Although the
record likely would include a transcript
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of the asylum officer interview,
commenters worried that the transcript
would be two levels removed from the
Federal court review and would not be
in the formal format that Federal courts
are accustomed to reviewing.
Response: As explained above in
Section III of this preamble, the
Departments are not adopting the IJ
review procedure proposed in the
NPRM; instead, under this IFR,
noncitizens whose applications for
asylum are adjudicated but not granted
by an asylum officer will be issued an
NTA and referred to an IJ for further
review of their applications in
streamlined section 240 removal
proceedings. If the IJ in turn denies the
noncitizen’s application for asylum, the
IJ will issue an order of removal, and the
noncitizen may appeal that decision
under the generally applicable
procedures, first to the BIA and then in
a petition for review to the appropriate
U.S. Court of Appeals. 8 CFR 1003.24;
INA 242, 8 U.S.C. 1252. Accordingly,
this change addresses commenters’
concerns regarding the availability of
judicial review.
Regarding commenters’ concerns
about the record for judicial review, the
Departments do not agree that the
nature of the record presents concerns.
As stated in the NPRM, USCIS will
transcribe the Asylum Merits interview
before the asylum officer, and that
verbatim transcript will be included in
the referral package sent to the
immigration court, as finalized in 8 CFR
208.9(f). Because the Departments will
ensure that the transcripts of these
hearings are in a format that is
appropriate for the IJ’s review of the
record, commenters’ concerns that the
transcript will not be sufficiently formal
or otherwise helpful for BIA or Federal
court review is simply speculative. The
noncitizen may then supplement the
record from the hearing by the asylum
officer during the noncitizen’s
proceedings before an IJ, including by
providing statements or evidence
regarding any alleged insufficiency
during the Asylum Merits proceedings.
Further, if the noncitizen appeals the
IJ’s decision, all hearings conducted by
the IJ will be transcribed under standard
EOIR procedures. See 8 CFR 1003.5(a)
(2020).92
92 DOJ amended 8 CFR 1003.5 in 2020 as part of
a final rule that affected EOIR procedures related to
the processing of BIA appeals. Appellate
Procedures and Decisional Finality in Immigration
Proceedings; Administrative Closure, 85 FR 81588
(Dec. 16, 2020). On March 10, 2021, the United
States District Court for the Northern District of
California granted a nationwide preliminary
injunction barring the Department from
implementing or enforcing the 2020 rule or any
portion thereof and stayed the effectiveness of the
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Comments: Some commenters stated
that, although they suggested changes to
strengthen due process protections with
respect to the proposed IJ review
proceedings, the Departments are on
track to usher in a modernized U.S.
asylum system that is orderly, efficient,
and fair.
Another commenter called attention
to what it said is ‘‘the fundamental
defect in our immigration adjudication
system that gives rise to the technocratic
changes proposed’’ in the NPRM: The
lack of an independent immigration
court. The commenter suggested that the
Departments adopt a ‘‘new model’’ in
which an independent court, presided
over by independent judges, would
assertedly ‘‘make rational decisions
based on the facts and the law of the
cases it hears.’’
Commenters also expressed concern
that the proposed appeal process seems
vague, among other flaws, leaving it
unclear what will happen to someone
where an IJ on appeal rules in
contradiction of the lower authority.
Response: Commenters’ assertions
regarding problems with the
immigration court system as a whole are
beyond the scope of this rulemaking.
Nonetheless, the Departments
emphasize that IJs exercise
‘‘independent judgment and discretion’’
in deciding cases, 8 CFR 1003.1(d)(1)(ii)
and 1003.10(b), and are prohibited from
considering political influences in their
decision-making, IJ Ethics and
Professionalism Guide (‘‘An
Immigration Judge should not be
swayed by partisan interests or public
clamor.’’).
Moreover, as noted above and in
Section III of this preamble, the
Departments have not adopted the IJ
review procedure proposed in the
NPRM and instead are providing that if
an asylum officer adjudicates but does
not grant asylum, the noncitizen will be
issued an NTA in streamlined section
240 removal proceedings. Because new
8 CFR 1240.17(a) provides that the same
rules and procedures governing
proceedings under 8 CFR, part 1240,
subpart A, apply unless otherwise
noted, if the IJ in turn denies relief or
protection, a noncitizen may appeal the
IJ’s decision to the BIA under the DOJ
regulations at 8 CFR 1240.15 and may
further petition for review of the BIA’s
decision by a Federal circuit court. The
Departments believe that this revision
addresses commenters’ concerns about
rule. Centro Legal de La Raza v. Exec. Off. for
Immigr. Rev., No. 21–CV–00463–SI, 2021 WL
916804, at *1 (N.D. Cal. Mar. 10, 2021).
Accordingly, the Departments cite to the regulations
in effect prior to publication of the December 16,
2020 rule.
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the alleged vagueness and unfairness of
the proposed appeal process in the
NPRM by providing a clear process for
appeal and incorporating longstanding
protections that ensure fairness in
immigration proceedings.
Comments: Commenters urged the
Departments to ensure that all
noncitizens have access to motions to
reopen protections, asserting that the
NPRM is unclear about whether there
would be an opportunity for the
noncitizen to move to reopen if not
physically removed following a removal
order.
Response: As noted above and in
Section III of this preamble, the
Departments have decided not to adopt
the IJ review procedure proposed in the
NPRM and instead are providing that if
an asylum officer adjudicated but did
not grant asylum, the noncitizen will be
issued an NTA in streamlined section
240 removal proceedings. The standard
rules governing motions to reopen will
continue to apply in those section 240
proceedings. See INA 240(b)(5)(C),
(c)(7), 8 U.S.C. 1229a(b)(5)(C), (c)(7); 8
CFR 1003.2, 1003.23. The Departments
believe this change addresses
commenters’ concerns about the clarity
of rules governing access to motions to
reopen in the NPRM.
Comments: Commenters urged the
Departments to generally end the
practice of expedited removal,
particularly in the case of asylum
seekers, and grant applicants a full
hearing before an IJ when requesting an
appeal on a negative decision by an
asylum officer.
Response: Commenter
recommendations to eliminate
expedited removal are beyond the scope
of this rulemaking. Nevertheless, the
Departments note that expedited
removal is a statutorily provided
procedure. INA 235(b)(1)(A)(i), 8 U.S.C.
1225(b)(1)(A)(i) (‘‘If an immigration
officer determines that [a noncitizen]
. . . who is arriving in the United States
. . . is inadmissible . . . the officer
shall order the [noncitizen] removed
from the United States without further
hearing or review unless the
[noncitizen] indicates either an
intention to apply for asylum . . . or a
fear of persecution.’’); INA
235(b)(1)(B)(iii)(I), 8 U.S.C.
1225(b)(1)(B)(iii)(I) (‘‘[I]f the officer
determines that [a noncitizen] does not
have a credible fear of persecution, the
officer shall order the [noncitizen]
removed from the United States without
further hearing or review.’’).
Comments: Commenters suggested
ways to ensure timely, effective, and fair
immigration court decisions: (1)
Formalize IJ authority to use
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administrative closure to manage their
dockets; (2) establish formal pre-hearing
conferences for DHS attorneys and
noncitizens’ counsel to confer and
identify issues in dispute prior to trial,
stipulate to issues where there is no
dispute, or agree that asylum or
protection is grantable based on the
written submissions; (3) clarify the IJ’s
authority to terminate section 240
removal proceedings to allow a
noncitizen to pursue applications for
permanent status before USCIS if the
noncitizen establishes prima facie
eligibility for such status; and (4) create
a formal mechanism for asylum seekers
and other immigrants to advance
immigration court hearing dates to
ensure that their cases are timely heard
and that hearing slots do not go unused.
Response: Comments suggesting
improvements for immigration court
proceedings generally are outside the
scope of this rulemaking. However, the
Departments briefly explain the current
legal scheme and how it may relate to
this IFR.
First, regarding commenters’ request
that IJs be able to utilize administrative
closure to manage their dockets, the
Attorney General recently issued Matter
of Cruz-Valdez, 28 I&N Dec. 326 (A.G.
2021), finding that, while the process of
rulemaking proceeds, the current
standard for administrative closure is
set out in Matter of Avetisyan, 25 I&N
Dec. 688 (BIA 2012), and Matter of W–
Y–U–, 27 I&N Dec. 17 (BIA 2017).
Parties should refer to the current case
law until further rulemaking is
completed. See Director Memorandum’s
(DM) 22–03, Administrative Closure
(Nov. 22, 2021).
Second, regarding the commenters’
request for a formal pre-hearing
conference, the IFR, in new 8 CFR
1240.17(f), provides that the IJ will hold
a prehearing status conference to narrow
the issues and otherwise simplify the
case.
Third, commenters’ request that the
Departments clarify general IJ authority
to terminate proceedings to allow a
noncitizen to pursue other relief or
protection before USCIS is beyond the
scope of this rulemaking. This IFR
specifically addresses procedures for
noncitizens subject to the expedited
removal process; it does not involve
general IJ authority to terminate
proceedings. Regarding IJs’ general
authority to terminate proceedings,
relevant case law provides that an IJ
may dismiss or terminate section 240
removal proceedings only under the
circumstances identified in the
regulations. See Matter of S–O–G– & F–
D–B–, 27 I&N Dec. 462 (BIA 2018).
Further, parties may agree to dismiss
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18183
proceedings for the noncitizen to pursue
other relief or protection before USCIS.
See Matter of Kagumbas, 28 I&N Dec.
400, 401 n.2 (BIA 2021) (noting that
parties are not prohibited ‘‘from
agreeing to dismiss proceedings so that
a respondent may pursue adjustment of
status before . . . USCIS’’). Fourth,
regarding commenters’ request for EOIR
to create a formal mechanism for
noncitizens to file a motion to advance
hearing dates, the Immigration Court
Practice Manual provides formal
instructions for requests to advance a
hearing date. See EOIR Policy Manual,
Part II.5.10(b). Moreover, EOIR
maintains a formal policy to ensure that
all available blocks of immigration court
time are utilized to the maximum extent
practicable. See EOIR, PM 19–11, No
Dark Courtrooms (May 1, 2019), https://
www.justice.gov/eoir/file/1149286/
download.
E. Other Issues Related to the Proposed
Rulemaking
1. Public and Stakeholder Input
Comments: Several commenters
requested a comment period extension
for various reasons, such as unclear
deadline instructions, insufficient time
to comment, and impacts of the COVID–
19 pandemic. One commenter stated
that commenting on this rule is difficult
without understanding its interaction
with other proposed rulemakings
relating to the asylum system.
Additionally, two commenters
requested that the proposed rule be
rescinded, revised, and reposted for
another comment period opportunity.
One of these commenters said the
agency should reissue a new NPRM
after providing asylum seekers
meaningful opportunities to present
their own recommendations for
reforming the asylum system.
Response: Although the APA does not
require a specific time period for public
comments, Executive Orders 12866, 58
FR 51735 (Sept. 30, 1993), and 13563,
76 FR 3821 (Jan. 18, 2011), recommend
a comment period of at least 60 days.
Here, the Departments have a provided
a 60-day comment period that allowed
for adequate notice, evinced by the over
5200 comments received and addressed
in this rule. In addition, the
Departments are issuing this rulemaking
as an IFR with a request for comment,
thus allowing the public a further
chance to provide input. The
Departments consequently do not agree
with the need for an extension.
Additionally, suggestions to rescind,
revise, and republish the rule upend the
rulemaking process. The NPRM is
designed to provided fair notice and
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allow for public input. Engaging in
continual reworking of such a notice
because of public comment undermines
the methodology of informal rulemaking
under the APA.
Comments: Several commenters urged
USCIS to engage with stakeholders like
immigration advocates, nongovernmental organizations, and asylum
seekers to improve existing processes
prior to publishing the rule. One
commenter provided specific feedback
from its members about improving the
efficiency and accessibility of the
asylum system.
Another commenter similarly
requested that, before any further steps
are taken to finalize the rule, additional
consultations take place. The
commenter ‘‘remind[ed]’’ the
Departments that, in response to a rule
proposed by the prior Administration,
UNHCR emphasized that it was
prepared to offer technical assistance,
and the asylum officers’ union observed
that the current Administration ‘‘must
make sure that the individuals tasked
with implementing policy have a voice
in crafting new regulations.’’ The
commenter stated that, by Executive
order, the President has mandated that
Federal Departments ‘‘shall promptly
begin consultation and planning with
international and non-governmental
organizations to develop policies and
procedures for the safe and orderly
processing of asylum claims at United
States land borders.’’ If the Departments
choose not to engage in such
consultation and planning with experts,
the commenter requested an
explanation of why not.
Response: The Departments
acknowledge commenters’ requests for
further engagement and their
suggestions to improve the asylum
program. Here, the Departments
provided a 60-day comment period in
the NPRM, which provided the
opportunity for members of the public,
including the commenters, public
employee unions, and other
stakeholders, to offer feedback on the
rule. In addition, in this IFR, the
Departments are including another
request for public comments.
Furthermore, the Departments regularly
engage experts from non-governmental
and intergovernmental organizations to
supplement the extensive training
provided to their personnel. The
Departments also note that they
regularly hold public engagement
sessions with stakeholders, allowing
further opportunity for the consultations
the commenters have requested. The
Departments are continually seeking
ways to improve the manner in which
they carry out their duties in service to
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the public and take into account
stakeholder feedback when doing so.
Comments: Some commenters
requested a more specific definition of
‘‘particular social group’’ to better
understand the proposed rule and
provide feedback. Similarly, several
commenters requested a delay in
implementation of the rule until the
‘‘particular social group’’ rule is issued
so that Congress has the opportunity to
comment and, if necessary, to legislate
on who is eligible for asylum.
Response: The Departments
acknowledge the commenters’ interest
in the forthcoming rulemaking
addressing, among other things, the
definition of the term ‘‘particular social
group’’ as used in the INA.93 However,
the Departments disagree that the
implementation of this IFR should be
delayed until the ‘‘particular social
group’’ rule is issued. The Departments
do note, however, that in issuing this
rulemaking as an IFR, they are soliciting
further comment on its provisions. This
rulemaking does not change any of the
criteria for asylum eligibility, but rather
addresses the procedures and
mechanisms by which the asylum
claims of individuals subject to
expedited removal are considered and
processed. By contrast, the ‘‘particular
social group’’ rulemaking would codify
the Departments’ interpretations of
certain Federal statutes they are charged
with implementing. The Administrator
of the Office of Information and
Regulatory Affairs within the Office of
Management of Budget has determined
that this IFR is a ‘‘major rule’’ within the
meaning of Subtitle E of the Small
Business Regulatory Enforcement
Fairness Act of 1996 (also known as the
Congressional Review Act), 5 U.S.C.
804(2). Accordingly, this IFR is effective
60 days after publication, thus allowing
additional time for congressional
review. If Congress deems it necessary
to legislate on asylum eligibility or any
other topic within its authority under
the United States Constitution, it may
certainly do so without regard to any
regulations promulgated by Executive
departments. The Departments will
faithfully execute any laws enacted by
Congress and signed by the President.
2. Severability
Comments: A commenter expressed
concern that, if certain protective
provisions in the proposed rule are
severed, then it ‘‘would fall short of
international standards for fair and
93 See Executive Office of the President, OMB,
OIRA, Spring 2021 Unified Agenda of Regulatory
and Deregulatory Actions, https://www.reginfo.gov/
public/do/eAgendaViewRule?pubId=202104&
RIN=1615-AC65 (last visited Feb. 27, 2022).
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efficient processing of asylum
applications.’’
Response: The Departments
acknowledge the commenter’s concern.
The Departments are committed to
ensuring that the process afforded
applicants meets the requirements of
due process even if certain aspects of
the IFR are enjoined by a court. With
this consideration in mind, the
Departments reiterate the statement on
severability set forth in the NPRM. 86
FR 46921. That is, to the extent that any
portion of the IFR is stayed, enjoined,
not implemented, or otherwise held
invalid by a court, the Departments
intend for all other parts of the rule that
are capable of operating in the absence
of the specific portion that has been
invalidated to remain in effect. Thus,
even if a judicial decision invalidating
a portion of the IFR results in a partial
reversion to the current regulations or to
the statutory language itself, the
Departments intend that the rest of the
IFR continue to operate in tandem with
the reverted provisions, if at all
possible, and subject to the discretion
permitting USCIS to decide to issue
individuals NTAs and refer noncitizens
to ordinary section 240 removal
proceedings.
3. Discretion and Phased
Implementation
a. Discretion
Comments: One commenter expressed
concern about providing DHS with
discretion to determine whether
noncitizens who receive a positive
credible fear determination are issued
NTAs and referred directly to section
240 removal proceedings or instead
have their cases retained by USCIS for
Asylum Merits interviews. The
commenter urged DHS to eliminate the
discretion to place noncitizens in
section 240 removal proceedings rather
than in the new process. This
commenter believes that such discretion
is arbitrary, inconsistent, and will
‘‘exacerbate negative bias’’ in the
decision-making process. Another
commenter urged the Departments to
reconsider the use of discretion because
the commenter believes there is a high
risk of inconsistent treatment among
asylum seekers subject to the new
process and asylum seekers who are
placed in section 240 removal
proceedings in the first instance.
Response: The Departments
acknowledge the commenters’ concerns
but disagree that permitting DHS to
continue to exercise its discretion to
place noncitizens who establish a
credible fear of persecution or torture
directly into ordinary section 240
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removal proceedings before an IJ, as
finalized in new 8 CFR 208.30(b), is
arbitrary, inconsistent, or will
exacerbate negative bias. Such
discretion is needed because there may
be circumstances in which it may be
more appropriate for a noncitizen’s
protection claims to be heard and
considered in the adversarial process
before an IJ in the first instance (for
example, in cases where a noncitizen
may have committed significant
criminal acts, engaged in past acts of
harm to others, or created a public
safety or national security threat). In
addition, the Departments anticipate
that DHS will also need to continue to
place many noncitizens receiving a
positive credible fear determination into
ordinary section 240 removal
proceedings while USCIS takes steps
needed to allow for full implementation
of the new process. Noncitizens who are
placed into section 240 removal
proceedings in the first instance will
have access to the same procedural
protections that have been in place for
asylum adjudications for many years.
Such exercise of discretion is similar to
and in line with DHS’s recognized
prosecutorial discretion to issue an NTA
to a covered noncitizen in expedited
removal proceedings at any time after
the covered noncitizen is referred to
USCIS for a credible fear determination.
See Matter of E–R–M– & L–R–M–, 25 I&N
Dec. at 523. Moreover, USCIS asylum
officers have experience with exercising
discretion in various contexts, including
in the adjudication of the asylum
application itself, and, thus, will be well
suited to exercise discretion in this
context.
b. Phased Implementation
Comments: Some commenters
expressed opposition to the phased rule
implementation approach. One
commenter asserted that a Federal
district court has found that the practice
of expediting cases for a particular
subset of individuals may violate their
rights, citing Las Americas Immigrant
Advocacy Center v. Trump, 475 F.
Supp. 3d 1194 (D. Or. 2020). Another
commenter asserted that there is no
justification for what the commenter
viewed as the rule’s preferential
treatment for non-detained families over
detained individuals and single adult
women and men. Another commenter
suggested a detailed plan for USCIS to
conduct a pilot project allowing asylum
seekers to opt into the new process and
then have USCIS collect evidence about
the fairness and expeditiousness of the
rule before it becomes final.
Alternatively, the commenter suggested
providing a preliminary period during
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which the rule would be in effect
followed by a ‘‘stay’’ of the regulatory
changes to ensure that the new process
is producing fair and expeditious
decisions.
Response: As discussed in greater
detail in the costs and benefits analysis
of this rule and its impacts on USCIS,
as required under Executive Orders
12866 and 13563, USCIS has estimated
that it will need to hire new employees
and spend additional funds to fully
implement the new Asylum Merits
process. If the number of noncitizens
placed into expedited removal and
making successful fear claims increases,
the cost to implement the rule with
staffing levels sufficient to handle the
additional cases in a timely fashion
would be substantially higher. Until
USCIS can support full implementation,
USCIS will need to continue to place a
large percentage of individuals receiving
a positive credible fear determination
into ordinary section 240 removal
proceedings in the first instance.
Current resource constraints will
prevent the Departments from
immediately achieving their ultimate
goal of having the protection claims of
nearly all individuals who receive a
positive credible fear determination
adjudicated by an asylum officer in the
first instance. The Departments are also
accounting for existing and emerging
priorities impacting the workload of the
USCIS Asylum Division, such as the
affirmative asylum caseload and the
streamlined asylum application
processing of certain Afghan parolees as
described in section 2502(a) of the
Extending Government Funding and
Delivering Emergency Assistance Act.94
The Departments believe that, to fully
implement the rule, additional
resources will be required. The
Departments therefore will expand use
of the new Asylum Merits process in
phases, as the necessary staffing and
resources are put into place.
While the Departments acknowledge
the commenters’ recommendations that
the Departments proceed with a pilot
project or have regulatory changes take
effect for a limited time, the
Departments believe that the phased
implementation approach is better
suited for this new process. A phased
implementation will allow the
Departments to begin employing the
new process in an orderly and
controlled manner and for a limited
94 See Public Law 117–43, sec. 2502, 135 Stat.
344, 377 (2021); DHS, DHS Announces Fee
Exemptions, Streamlined Processing for Afghan
Nationals as They Resettle in the U.S. (Nov. 8,
2021), https://www.dhs.gov/news/2021/11/08/dhsannounces-fee-exemptions-streamlined-processingafghan-nationals-they-resettle.
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number of cases, giving USCIS the
opportunity to work through operational
challenges and ensure that each
noncitizen placed into the process is
given a full and fair opportunity to have
protection claims presented, heard, and
properly adjudicated in full
conformance with the law. Phased
implementation will also have an
immediately positive impact in
reducing the number of individuals
arriving at the Southwest border who
are placed into backlogged immigration
court dockets, thus allowing the
Departments to more quickly adjudicate
some cases. Phased implementation will
also ensure that EOIR is able to dedicate
IJs to the streamlined section 240
removal proceedings, which will require
available docket space to meet these
proceedings’ scheduling requirements.
Given limited agency resources, the
Departments anticipate first
implementing this new process for only
a limited number of noncitizens who
receive a positive credible fear
determination after the effective date of
this rule. The Departments believe this
is necessary because USCIS capacity is
currently insufficient to handle all
referrals under this new process. The
Departments also anticipate limiting
referrals under the initial
implementation of this rule to
noncitizens apprehended in certain
Southwest border sectors or stations, as
well as based on the noncitizen’s final
intended destination (e.g., if the
noncitizen is within a predetermined
distance from the potential interview
location). As the USCIS Asylum
Division gains resources and builds
capacity, the Departments anticipate
that additional cases could be
considered for processing pursuant to
this phased implementation.
The Departments also disagree that
the decision in Las Americas precludes
a phased implementation of the IFR.
The relevant part of that decision
addressed only whether the adoption of
a separate policy constituted ‘‘final
agency action’’ that could be challenged
under the APA. 475 F. Supp. 3d at 1216.
The decision did not purport to prohibit
agencies from implementing regulatory
programs in phases.
Overall, the Departments will work
together to ensure that both agencies
have capacity as this rule’s
implementation proceeds. For example,
if EOIR does not have additional
available docket space, USCIS will not
expand the rule’s application at that
point.
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4. Comments on Immigration Court
Inefficiencies and Bottlenecks
Comments: Some commenters
suggested several ways to address
inefficiencies and bottlenecks, such as
quickly filling existing positions,
surging staffing to the courts, and
requesting funding from Congress to
increase the number of immigration
court interpreters, support staff, IJs, BIA
legal and administrative staff, and BIA
members. Additionally, these
commenters suggested pre-hearing
requirements to narrow issues for trial
and to create a process to advance cases
stuck in the court backlog.
Response: The Departments
acknowledge the commenters’
suggestions and recommendations to
help improve the immigration
adjudication process as a whole. The
commenters’ suggestions regarding the
hiring process, staff surges, and
increased funding are beyond the scope
of this rulemaking. However, DOJ has
already implemented or is currently
implementing a number of measures
referenced by the commenters, as
described below. For example, DOJ has
reduced the average IJ hiring process
from 742 days (over 2 years) in 2017 to
8 to 10 months at present. Upon receipt
of qualified applicants from the Office
of Personnel Management (‘‘OPM’’), DOJ
immediately begins assessment of the
applicants. DOJ also consistently meets
its internal deadlines for this process.
As a result of these efforts, as of October
2021, DOJ had hired 65 new IJs in FY
2021, bringing the total number of IJs to
559. See EOIR, Adjudication Statistics:
Immigration Judge (IJ) Hiring (Jan.
2022), https://www.justice.gov/eoir/
page/file/1242156/download. DOJ
continues to focus on filling all
vacancies as expeditiously as possible.
DOJ has consistently requested
increased funding for additional
authorized positions. In its FY 2022
budget request, DOJ requested an
additional 600 authorized positions, to
include 300 attorney positions. Of the
300 attorney positions, DOJ anticipates
hiring 100 new IJs and support staff. See
DOJ, FY 2022 Budget and Performance
Summary: Executive Office for
Immigration Review (Aug. 20, 2021),
https://www.justice.gov/jmd/page/file/
1399026/download. DHS also requested
funding appropriations to meet the
increased workload in the immigration
courts and ameliorate staffing budgetary
shortfalls. For FY 2022, DHS requested
100 additional ICE litigator positions to
prosecute the removal proceedings
initiated by DHS, consistent with 6
U.S.C. 252(c). See DHS, ICE Budget
Overview: FY2022 Congressional
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Justification at ICE–O&S–22, https://
www.dhs.gov/sites/default/files/
publications/u.s._immigration_and_
customs_enforcement.pdf.
In new 8 CFR 1240.17(f)(1)–(3), the
IFR establishes certain pre-hearing
requirements for individuals in
streamlined section 240 proceedings.
Establishing pre-hearing requirements
for all cases, however, is beyond the
scope of this rulemaking. DOJ reiterates
that IJs may issue orders for pre-hearing
statements. 8 CFR 1003.21(b), (c).
Further, EOIR’s case flow processing
model, which applies to certain nondetained cases with representation,
incorporates short matter hearings or
pre-trial conferences for cases that are
not yet ready for trial, as appropriate.
See EOIR, PM 21–18: Revised Case Flow
Processing Before the Immigration
Courts (Apr. 2, 2021), https://
www.justice.gov/eoir/filing-deadlinesnon-detained-cases; see also EOIR, DM
22–04: Filing Deadlines in Non-Detained
Cases (Dec. 16, 2021), https://
www.justice.gov/eoir/book/file/
1456951/download (amending PM 21–
18).
F. Statutory and Regulatory
Requirements
1. Impacts and Benefits (E.O. 12866 and
E.O. 13563)
a. Methodology
Comments: A commenter referenced
the NPRM statement that the agencies
cannot accurately estimate the benefits
to the agencies. Additionally, the
commenter referenced several specific
cost estimates and case numbers from
the NPRM and reasoned that the
numbers are now incorrect because
more cases have been added since then,
causing an increase in cost and resulting
in less financial efficiency for the rule.
Response: USCIS acknowledges the
increasing backlog and agrees that it can
have an impact on credible fear asylum
applicants, their families, and support
networks. As stated in the NPRM, this
rule is expected to slow the growth of
EOIR’s backlog and allow EOIR to work
through its current backlog more
quickly. First, the rule will allow DHS
to process more noncitizens
encountered at or near the border
through expedited removal—rather than
placing them into section 240 removal
proceedings—thereby quickly and
efficiently securing removal orders for
those who do not make a fear claim or
who receive a negative credible fear
determination. Second, this rule is
estimated to reduce EOIR’s overall
credible fear workload by at least 15
percent. This estimate is based on the
average of EOIR asylum grant data over
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the past five years for cases originating
with a credible fear claim.95 Under this
IFR, grants of asylum for such cases
would generally be made by USCIS
without involvement by EOIR (setting
aside those cases in which asylum is
granted after referral to a streamlined
section 240 proceeding). Because the
Departments expect that USCIS’s
asylum grant rate will be approximately
the same as EOIR’s, approximately 15
percent of cases originating in credible
fear interviews will no longer contribute
to EOIR’s workload. Third, the above
calculation sets a lower bound on
EOIR’s expected workload reduction, as
it does not account for efficiencies that
may be realized in cases that are
referred to EOIR for streamlined section
240 proceedings. In these three ways,
the rule will enable IJs to focus efforts
on other high-priority work, including
backlog reduction. Moreover, for
noncitizens who are placed into the
process established by this IFR, the
Departments expect that asylum
decisions will be reached faster than if
they were to go through the current
process with EOIR.
Unfortunately, not all benefits can be
quantified at this time, as the
Departments acknowledged in the
NPRM and affirm in this IFR. Benefits
driven by increased efficiency would
enable some asylum-seeking individuals
to move through the asylum process
more expeditiously than through the
current process, with timelines
potentially decreasing significantly,
thus promoting both human dignity and
equity. Adjudicative efficiency gains
and changes to the regulatory standard
for consideration for parole could lead
to individuals spending less time in
detention, which would benefit the
Government, considering its limited
resources and inability to detain all
those apprehended, as well as the
affected individuals, who would be able
to continue to prepare for and pursue
relief or protection outside the confines
of a detention setting.
b. Population
Comments: A commenter asserted
that the 75,000 to 300,000 range of
95 See supra note 57 (discussing IJs’ and asylum
officers’ similar approval rates on the merits of the
asylum claim). Based on the five-year (FY 2017
through FY 2021) average, an estimated 15 percent
of the total number of EOIR asylum cases completed
originating from credible fear screening were
granted asylum. See EOIR, Adjudications Statistics:
Asylum Decision and Filing Rates in Cases
Originating with a Credible Fear Claim (Jan. 19,
2022), https://www.justice.gov/eoir/page/file/
1062976/download. Calculation: FY 2017 to FY
2021 grant rates (14.02 percent) + (16.48 percent)
+ (15.38 percent) + (16.60 percent) + 14.32 percent)/
5 = 15 percent average (rounded).
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people cited in the NPRM who would
receive credible fear determination does
not include the ‘‘2019 DHS expansion of
the expedited removal process to the
full extent authorized by statute.’’
Response: The Departments disagree
that the population cited in the NPRM
underestimates the number of people
who would receive credible fear
determinations. Although there is no
way to predict exact future filing
volumes, USCIS determined the
population expected to be affected by
this rule to be the average number of
credible fear completions processed
annually by USCIS (71,363, see Table 3).
However, as changes in credible fear
cases and asylum in general can be
driven by multiple factors that are
difficult to predict, USCIS provided
estimates for potential populations
above and beyond the current number of
annual credible fear completions. At
present, the estimated lower bound of
75,000 is greater than current annual
average of completions, and USCIS has
estimated a maximum population of
300,000 people who could be impacted
to account for variations and
uncertainty in the future population.
Although the 2019 DHS expansion of
the expedited removal process is
currently in place, President Biden, in
his E.O. on Migration, has directed DHS
to consider whether to modify, revoke,
or rescind the expansion. It is unknown
when or if the expansion would be
rescinded or what other factors outside
of this rulemaking may impact the size
of this population. Therefore, the
Departments have done their best to
provide estimates at varying potential
population levels.
c. Costs or Transfers
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i. Impacts on the Credible Fear Asylum
Population and Support Networks
Fees
Comments: Several commenters
stated that the United States has a legal
obligation to protect those seeking
asylum, and some stated that asylum
applications should never require a fee.
Additionally, many commenters said fee
increases disproportionately impact
low-income immigrants and vulnerable
populations, including gender-based
violence survivors. Other commenters
stated that increased fees would
financially harm noncitizens seeking
asylum and create a barrier for many
applicants. An individual commenter
suggested that the fee-based services of
USCIS would endanger the freedoms of
U.S. citizens.
Response: USCIS currently does not
charge a fee to apply for asylum. This
rule is not requiring low-income
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noncitizens or other vulnerable
populations to pay a fee for their asylum
application to be adjudicated.
Additionally, fee waivers are currently
available for an applicant who cannot
afford to pay to apply for an
immigration benefit that requires a fee.
The provisions of this IFR are not
expected to impact any applicant who
entered the United States legally and is
seeking to obtain immigration benefits
through the appropriate processes or
any natural-born or naturalized U.S.
citizen not part of an asylum applicant’s
support network.
Comments: Several commenters
referenced the rule’s statement that a
significant investment of resources will
be necessary to build up the capacity of
USCIS to make this new rule fully
operational. Several commenters urged
DHS to secure the necessary resources
from Congress to the extent possible,
rather than through increased fees for
applicants.
Response: The Departments
acknowledge these comments and the
concern they show for the funding of
this rule. As the commenters state, fees
are necessary for USCIS to collect to pay
for the work USCIS performs in
adjudicating applications and petitions
for immigration benefits. USCIS
acknowledged in the NPRM that, if this
rule were to be funded through a future
fee rule, it would increase fees by an
estimated weighted average between 13
percent and 26 percent, depending on
volume of applicants. 86 FR 46937. This
estimated increase would be attributable
to the implementation of the asylum
officer portions of the proposed rule
only. USCIS conducts notice-andcomment rulemaking to raise fees and
increase revenue for such staffing
actions. Although the substance of the
future fee rule is outside of the scope of
this rule, USCIS currently does not
charge a fee to apply for asylum. USCIS
is exploring all options to provide
funding for this rule.
Other Impacts
Comments: A commenter expressed
concern that the potential for more
expedited denials of applications risks
making some asylum seekers less likely
to receive employment authorization
while their cases are pending.
Response: This rule is intended to
improve the Departments’ ability to
consider the asylum claims of
individuals encountered at or near the
border more promptly while ensuring
fundamental fairness. Faster processing
will lead to timelier case completions
for asylum claims, including both
approvals and denials. Employment
authorization is a discretionary benefit
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that USCIS may grant to those who
qualify. This rule does not change the
requirements for employment
authorization or for asylum, but it may
change the amount of time some
applicants’ cases remain pending.
Applicants whose asylum claims are
approved can work immediately.
Comments: Multiple commenters
asserted that the proposed rule will do
little to address the backlog of cases or
improve efficiency. Other commenters
argued that the rule would divert
already scarce agency resources away
from noncitizens who submit
affirmative asylum applications in
addition to unaccompanied noncitizen
minors, over whose asylum claims
USCIS has initial jurisdiction. Another
commenter expressed concern that, if
USCIS shifted experienced asylum
officers into this new role, it would slow
down existing caseloads due to less
experienced new hires.
Response: The Departments disagree
with the criticisms from these
commenters. This rule will allow EOIR
to focus efforts on high-priority work
and will likely contribute to EOIR’s
efforts to reduce its substantial current
backlog over time. Ultimately, EOIR will
not see the cases in which USCIS grants
asylum, which the Departments
estimate as at least a 15 percent
reduction in EOIR’s overall credible fear
workload. Over time, this rule stands to
reduce the backlog of cases pending in
immigration courts and will enable
faster processing of cases originating in
credible fear screening—whether
asylum is granted or denied—than if
they were to go through the current
process with EOIR. USCIS has estimated
that it will need to hire approximately
800 new employees to fully implement
the proposed asylum officer interview
and adjudication process to handle
approximately 75,000 cases annually.
USCIS will not shift asylum officer
resources from their current workload to
implement this program but has
explained how it will hire, train, and
deploy staff specifically dedicated to
this program in Section IV.B.1.b of this
preamble.
Although addressing the affirmative
asylum backlog is outside the scope of
the rulemaking, the Departments
acknowledge the importance of doing so
and note that USCIS has taken other
actions to address this priority. These
include expanding facilities; hiring and
training new asylum officers;
implementing operational changes to
increase interviews and case
completions and reduce backlog growth;
establishing a centralized vetting center;
and working closely with technology
partners to develop several tools that
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streamline case processing and
strengthen integrity of the asylum
process.96 In addition, on September 30,
2021, Congress passed the Extending
Government Funding and Delivering
Emergency Assistance Act, which
provides dedicated backlog elimination
funding to USCIS for ‘‘application
processing, the reduction of backlogs
within asylum, field, and service center
offices, and support of the refugee
program.’’ Public Law 117–43, sec. 132,
135 Stat. at 351.
Comment: A commenter asserted that
biometric information collection for
both EAD submissions and asylum
applications is duplicative, timeconsuming, and costly due to the
relatively low number of asylum offices
throughout the country.
Response: Biometrics information is
collected on every individual associated
with a Form I–589 filing, and for the
Form I–765(c)(8) category, USCIS
started collecting biometrics, and the
associated $85 biometrics service fee, in
October 2020. This rule does not change
biometric collection requirements
related to Form I–589 or Form I–765.
USCIS may still have to require
applicants to attend an ASC
appointment or otherwise obtain their
biometrics in support of the asylum
application following a positive credible
fear determination but is working to
obtain the ability to reuse the biometrics
already captured by other DHS entities
for the asylum application before
USCIS.
Comments: One commenter said that
DHS failed to consider the long-term
financial and procedural impact on feepaying legal immigrants who pay USCIS
petition fees and that this proposed rule
unfairly shifts the financial burden from
the U.S. taxpayer (DOJ) to lawful
immigrants (USCIS). The commenter
asserted that it is in the best interest of
those who pay fees to have the money
mostly spent on adjudicating their
petitions, not on humanitarian interests.
The commenter argued that the United
States should have funded the
operation, not lawful immigrants, and
that funding could have been used on
projects such as e-filing systems and
process improvements instead. The
commenter asserted that the proposal
harms fee-paying immigrants, such as
those with master’s and doctoral degrees
in the STEM (science, technology,
engineering, and mathematics) fields
who are needed for the United States’
96 See USCIS, Backlog Reduction of Pending
Affirmative Asylum Cases: Fiscal Year 2021 Report
to Congress (Oct. 20, 2021), https://www.dhs.gov/
sites/default/files/2021-12/USCIS%20-%20Backlog
%20Reduction%20of%20Pending%20Affirmative
%20Asylum%20Cases.pdf.
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international competitiveness. The
commenter suggested that DOJ hire
more IJs or that funding should come
from Congress or by charging asylum
seekers in expedited removal a fee that
fully covers the cost to adjudicate their
case.
Response: USCIS already performs
humanitarian work through credible
and reasonable fear screenings, asylum
interviews, and refugee processing for
which the costs are covered through fees
paid by applicants and petitioners.
Should this rule be funded through a
future fee rule, the financing would be
no different. This rule is not requiring
fee-paying immigrants with master’s
and doctoral degrees in the STEM field
to take on the full burden of this new
program. Although some applicants
who fall into these categories may face
increased fees under a future fee rule,
historically, changes to fees are spread
across a variety of applicants and
petitioners and are fully outlined in a
notice-and-comment rulemaking.
Comment: A commenter asserted that
the NPRM would cause significant harm
to its mission and programming and to
the clients it serves. It stated that it will
need to make significant changes in its
programming to provide meaningful
representation and pro bono services
and may have to divert more resources
to represent asylum seekers in appeals.
Additionally, the commenter asserted,
the fast-tracking of interviews and the
limitations on attorney representation
during the interviews would
significantly hinder its ability to provide
legal services in a timely and
meaningful manner. As a result, it
would have a smaller population it
could represent in the United States.
Without access to counsel, it asserted,
asylum seekers would be less likely to
prevail on the merits of their claims.
The commenter alleged that the
consequences of these proposed changes
would be devastating for tens of
thousands of refugees whom the United
States has committed to protecting.
Response: The Departments
acknowledge the commenter’s concern
but disagree that this rule will
negatively impact asylum seekers in the
manner the commenter predicts. This
rule is intended to improve the
Departments’ ability to consider the
asylum claims of individuals
encountered at or near the border more
promptly while ensuring fundamental
fairness. This rule does not change the
requirements for asylum applicants or
the evaluation criteria that are used
during adjudication.
Prompt adjudication of these claims
will benefit asylum seekers, the
Departments, and the public. The
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Departments understand that applicants
will need time to review their
applications and supporting
documentation, consult with
representatives, and prepare for their
Asylum Merits interviews before USCIS
asylum officers. At the same time, the
underlying purpose of this rulemaking
is to establish a process for promptly
adjudicating cases that heretofore have
been drawn out for months or even
years before EOIR. To balance the
efficiency goals of the present rule with
the fairness and due process concerns
raised by commenters and shared by the
Departments, the Departments are
clarifying at 8 CFR 208.9(a)(1) that there
will be a minimum of 21 days between
the service of the positive credible fear
determination on the applicant and the
date of the scheduled Asylum Merits
interview. This time frame mirrors the
time frame provided to applicants in the
affirmative asylum process, where
asylum interviews are generally
scheduled, and interview notices are
mailed to applicants, 21 days in
advance of the asylum interview date.
This rule does not limit access to
counsel for asylum applicants. To the
contrary, 8 CFR 208.9(b) provides that
‘‘[t]he applicant may have counsel or a
representative present’’ at the asylum
interview, and 8 CFR 208.9(d)(1)
provides the applicant’s representative
an opportunity to make a statement,
comment on the evidence presented,
and ask follow-up questions.
Moreover, the Departments are
forgoing the IJ review procedure
proposed by the NPRM. Rather,
applicants who are not granted asylum
after a hearing conducted by the asylum
officer will be placed in streamlined
section 240 removal proceedings.
Although these proceedings will be
substantially streamlined relative to
ordinary section 240 proceedings, the
Departments have designed a process
that is intended to facilitate and
preserve access to counsel and ensure
that noncitizens receive a full and fair
hearing.
First, noncitizens subject to these
procedures who have not secured
counsel by the time of their Asylum
Merits interview will continue to have
a meaningful opportunity to secure
counsel during removal proceedings.
The IFR provides for a 30-day gap
between the asylum officer’s decision
not to grant asylum and the noncitizen’s
master calendar hearing in immigration
court, during which time the noncitizen
may seek counsel. At the master
calendar hearing, IJs must advise
unrepresented noncitizens of their
rights in removal section 240 removal
proceedings, including their right to
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representation and the availability of
pro bono legal services, and provide a
list of pro bono legal service providers.
INA 240(b)(4), 8 U.S.C. 1229a(b)(4); 8
CFR 1240.10. The noncitizen will have
an additional 30 days before the status
conference to seek counsel without
needing to request a continuance. A
noncitizen who remains unrepresented
at the status conference may request a
continuance for good cause shown to
secure counsel and may receive such
continuances for up to an additional 30
days. Matter of C–B–, 25 I&N Dec. at 889
(‘‘In order to meaningfully effectuate the
statutory and regulatory privilege of
legal representation . . . , the [IJ] must
grant a reasonable and realistic period of
time to provide a fair opportunity for a
respondent to seek, speak with, and
retain counsel.’’). The IFR permits
further continuances to secure counsel
in appropriate circumstances even
under the rule’s heightened continuance
requirements, which apply after 30 days
of continuances have been granted. See,
e.g., Usubakunov, 16 F.4th at 1305
(denial of a noncitizen’s motion for a
continuance to permit his attorney to be
present at his merits hearing amounted
to violation of his statutory right to
counsel). Accordingly, the IFR provides
a significant and reasonable amount of
time for noncitizens to obtain counsel
and allows for continuances to secure
representation in appropriate
circumstances.
Second, the IFR recognizes that a
noncitizen might not obtain counsel
before the beginning of proceedings and
therefore allows for continuances or
extensions of filing deadlines where
counsel needs additional time to
prepare, so long as counsel
demonstrates that the need for the
continuance or extension satisfies the
applicable standard. The rule also
provides flexibility to counsel by
allowing noncitizens to file additional
documents and supporting evidence
after the filing deadline when certain
conditions are met.
Third, the rule provides a meaningful
opportunity for both represented and
unrepresented noncitizens to present
their claims during streamlined section
240 removal proceedings. The rule is
consistent with IJs’ duty to develop the
record, and various provisions of the
rule particularly enable IJs to do so in
cases involving pro se respondents. In
cases where the noncitizen is
represented, the IFR is designed to
streamline proceedings by narrowing
the issues to be adjudicated, which the
Departments anticipate will benefit all
parties and their counsels as well as
EOIR.
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ii. Impacts on U.S. Workers, Companies,
Economy
Approximately five commenters
provided specific feedback about the
impacts on U.S. workers, companies,
and the economy.
Comments: A commenter expressed
concern about the fiscal impact on
American taxpayers and stated that the
proposed rule is not clear about how
USCIS will cover the costs related to the
rule. Another commenter requested that
DHS provide estimates of the proposal’s
impact on the number of immigrants
and asylum seekers intending to enter
the country and the costs associated
with any increased immigration. The
commenter also requested an estimate of
how much the humanitarian effort of
accepting asylees would cost the
average U.S. citizen and expressed
concern about immigration’s impact on
the country’s limited financial
resources.
Response: The work performed by
USCIS is primarily paid for through fees
collected from applicants or petitioners
requesting immigration or naturalization
benefits.97 USCIS acknowledged in the
NPRM that, if this rule were to be
funded through a future fee rule, it
would increase fees by an estimated
weighted average of between 13 percent
and 26 percent, depending on volumes
of applicants. 86 FR 46937. USCIS
conducts notice-and-comment
rulemaking to raise fees and increase
revenue for such staffing actions.
Although speculating on future fees is
outside of the scope of this rule, USCIS
currently does not charge a fee to apply
for asylum. USCIS is exploring all
options to provide funding for this rule.
The population expected to be
affected by this rule is the average
number of credible fear completions
processed annually by USCIS (71,363,
see Table 3), split between an average of
59,280 positive-screen cases and 12,083
negative-screen cases. This can be
considered the maximum
‘‘encompassing’’ population that could
be impacted. However, the Departments
take into consideration larger
populations to account for variations
and uncertainty in the future
population. Regarding the costs
associated with increased immigration,
this rule focuses on the direct costs to
USCIS related to staffing needs to absorb
the new workload it will take on from
EOIR. Further, the Departments
recognize the role of support networks,
which could include public and private
entities and family and personal friends,
97 See USCIS, Budget, Planning and Performance
(May 28, 2021), https://www.uscis.gov/about-us/
budget-planning-and-performance.
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legal services providers and advisors,
religious and charity organizations,
State and local public institutions,
educational providers, and nongovernmental organizations (‘‘NGOs’’),
but it is not possible to place a monetary
value on such support. The rule does
not change the substantive eligibility
standard for asylum or the evidentiary
requirements. Therefore, USCIS has no
reason to expect that the rule will have
a significant effect on the number of
individuals who may be granted
asylum. Additionally, individuals
whose asylum claims are pending are
not provided any special humanitarian
aid funded by U.S. taxpayers.
Comments: Several commenters
speculated that, in the current economic
situation of high inflation and low jobgrowth, the influx of working-age
immigrants may create wage decreases
impacting low-wage American workers.
Another commenter cited a study and
the testimony of a former member of
Congress indicating that immigrants
with low education and skills may
compete with the most vulnerable
Americans, which would assertedly
lower wages and benefit businesses.
Response: The commenters suggesting
that increased immigration, particularly
of low-skilled immigrants, to the United
States may adversely impact the wages
of low-income Americans provide no
evidence indicating such an impact
would be the most likely outcome of
this rulemaking. Furthermore, these
comments blur the distinction between
legal and illegal immigration and
provide little evidence on the impact of
asylum seekers in particular on wages.98
Faster adjudications for applicants
who receive a positive credible fear
determination mean they may enter the
labor market sooner under this rule than
they would currently. Conversely, some
asylum seekers that currently enter the
labor market with a pending asylum
application will no longer enter the
labor market under this rule if they
receive a negative decision on their
asylum claim at an earlier date.
Therefore, at this time, it is unknown
exactly how this rule will impact
employment authorization for this
population or what impacts such
authorizations would have on the labor
market. Because the ‘‘(c)(8)’’ EAD does
not include or require, at the initial or
98 Economic research indicates that immigration
in general has had little effect on the distribution
of wages in the United States in recent decades. See
Jane G. Gravelle, Cong. Research Serv., R46212,
Wage Inequality and the Stagnation of Earnings of
Low-Wage Workers: Contributing Factors and Policy
Options (Feb. 5, 2020), https://crsreports.
congress.gov/product/pdf/R/R46212/3 (last visited
Mar. 5, 2022).
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renewal stage, any data on employment,
and since it does not involve an
associated labor condition application,
we have no information on wages,
occupations, industries, or businesses
that may employ such workers.
Therefore, USCIS cannot confirm the
type of work that asylum seekers obtain
or the wages they earn.
The Bureau of Labor Statistics
(‘‘BLS’’) publishes statistics on
employment that can provide insight
into the current economic situation.
Total nonfarm payroll employment rose
by 210,000 in November 2021, while the
unemployment rate fell to 4.2 percent
and the number of unemployed persons
fell by 542,000 to 6.9 million.99 BLS also
publishes job openings, a measure of the
unmet demand for labor. In November
2021, there were 10.6 million job
openings.100 Meanwhile, BLS’ quarterly
employment cost index shows that
wages and salaries increased for
civilian, private industry, and State and
local government workers in September
2021.101 The arguments that low job
growth or the influx of working-age
immigrants may create wage decreases
impacting low-wage American workers
are speculative and not supported by
the data.
iii. Impacts on Federal Government
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Impacts on U.S. Citizenship and
Immigration Services
Approximately 15 submissions
provided feedback about the impacts to
USCIS.
Comments: Many commenters
asserted that the proposed rule will do
little to address case backlogs at either
EOIR or USCIS and will require
extensive resources from USCIS. Several
commenters argued that the financial
and administrative burden will shift
from EOIR to USCIS. Multiple
commenters expressed concern that
resources will be drawn away from the
current process in order to conduct
training for and implement the new
process, which will increase backlogs.
Another commenter suggested that that
newly hired asylum officers should be
deployed to the existing asylum offices
to reduce the already existing backlogs.
Response: EOIR’s caseload includes a
wide range of immigration and removal
99 BLS, The Employment Situation—November
2021 (Dec. 3, 2021), https://www.bls.gov/news.
release/archives/empsit_12032021.pdf (last visited
Feb. 27, 2022).
100 BLS, Job Openings and Labor Turnover—
November 2021 (Jan. 4, 2022), https://www.bls.gov/
news.release/archives/jolts_01042022.pdf (last
visited Feb. 27, 2022).
101 BLS, Employment Cost Index—September
2021 (Oct. 29, 2021), https://www.bls.gov/news.
release/archives/eci_10292021.pdf (last visited Feb.
27, 2022).
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cases. Allowing asylum officers to take
on cases originating in the credible fear
process is expected to reduce delays
across all of EOIR’s docket, as well as
reduce the time it takes to adjudicate
these protection claims. By shifting that
caseload to USCIS, the rule will enable
IJs to focus efforts on other high-priority
work.
USCIS acknowledges that it will take
time and money to hire and train new
asylum officers, but it does not
anticipate shifting current resources to
do so. Hiring and training asylum
officers is already a part of regular
USCIS operations. USCIS does not
anticipate increased backlogs as a direct
result of this rule. As stated in the
NPRM and in this IFR, there is the
potential for backlogs to be mitigated,
though USCIS cannot predict the timing
and scope of such potential changes
with accuracy. Staffing levels and
priorities across the agency are
continuously monitored and actions are
taken as needed.
Comments: Several commenters
asserted that training asylum officers
would increase financial burden on
USCIS. Additionally, multiple
commenters reasoned that, since USCIS
funds itself based on fees, and because
fees will not be charged for this new
process, USCIS will not have enough
funding to cover training and
implementation of the new rule. Several
commenters expressed concern that the
proposed rule’s economic analysis did
not state USCIS’s ability to pay for the
additional costs or address other
impacts to USCIS, such as appeals or
accessibility issues due to the limited
number of asylum offices and the need
for expanded teleconferencing
technology for remote hearings.
Response: As outlined in the NPRM
and affirmed in this IFR, this rule does
have associated costs, but it also has
benefits (see Table 1). As previously
stated, if the medium- and high-volume
bands of 150,000 and 300,000 asylum
applicants were to be funded through a
future fee rule, it would increase fees by
an estimated weighted average of 13
percent and 26 percent respectively.
This estimated increase would be
attributable to the implementation of the
asylum officer portions of the proposed
rule only. USCIS conducts notice-andcomment rulemaking to raise fees and
increase revenue for such staffing
actions. USCIS is exploring all options
to provide funding for this rule.
The Departments do not expect this
rule to result in an increase in appeals
or the number of individuals requiring
access to an asylum office, but they do
recognize that the timing of appeals and
asylum interviews may change because
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of this rule. As part of the estimated
USCIS FY 2022 and FY 2023 funding
requirements by volume of credible fear
referrals (see Tables 7 and 8), USCIS
included estimated costs associated
with needs such as interpreter and
transcription services, facilities, IT case
management, and other contracts,
supplies, and equipment. The
Departments agree with the commenters
that there will be expanded technology
needs to implement this rule.
Comments: A commenter stated that
moving the funding type from an
appropriations-funded model to a feebased enterprise model would result in
USCIS’s dependency on high fees to
generate revenue.
Response: USCIS agrees generally
that, if funding is sourced to fees, higher
fees over time are necessary to generate
revenue in line with costs, but disagrees
that fee-based funding would generate a
harmful dependency. USCIS relies on
fees to fund almost all the work the
agency performs. USCIS is exploring all
options to provide funding for this rule.
However, if the rule is to be funded
through a future fee rule, it would
increase fees by an estimated weighted
average between 13 percent and 26
percent, depending on volumes of
applicants.
Comments: A commenter stated that
the rule does not make an appropriate
comparison for the proposed new
procedures. Specifically, the NPRM
stated that USCIS would have to hire
approximately 800 new employees and
spend approximately $180 million to
handle approximately 75,000 cases per
year if the rule was implemented. The
commenter said the rule improperly
compares whether the proposed rule,
backed with $180 million in new
funding, would provide more fair and
expeditious decisions than the existing
system that receives no additional
funding. The commenter said the
appropriate comparison is whether the
proposed rule, backed with $180
million in new funding, would provide
more fair and expeditious decisions
when compared with the existing
system if the existing system were
backed with $180 million in new
funding.
Response: The Departments have
determined that important procedural
changes are needed to improve the
system of asylum adjudication for cases
originating in credible fear screening,
and that simply adding more money to
the existing procedures would not yield
the same benefits in fairness and
reduced delays. Implementing these
important procedural changes will
involve costs for, among other things,
personnel and training. It is not possible
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to place a monetary value on fairness
and expeditiousness in the process of
adjudicating the protection claims of
noncitizens arriving at the border.
However, to the extent that the $180
million amount referenced above would
facilitate the implementation of the rule,
the Departments believe that it will
enable greater benefits in terms of fair
and expeditious decisions than the same
amount applied to the existing system.
Impacts on the Executive Office for
Immigration Review
Approximately four submissions
provided feedback about the impacts on
EOIR.
Comments: A commenter worried that
the proposed rule will do little address
case backlogs and will require extensive
resources from EOIR. Another
commenter asserted that the proposed
rule will further burden the immigration
courts and create delays. A commenter
argued that, although the proposed rule
may limit the growth of the IJ docket, it
does not offer any relief to IJs, and it
merely moves some cases to USCIS,
which already has a backlog of cases. A
commenter was concerned that there is
no reason to believe that conducting
interviews in detention centers would
be quicker than the EOIR process
because doing so does not eliminate
duplicative hearings and eliminates
access to the courts.
Response: The rule will not directly
change how cases that are already
pending before EOIR are adjudicated.
However, as stated in the NPRM, this
rule is expected to slow the growth of
EOIR’s backlog and allow EOIR to work
through its current backlog more
quickly. First, the rule will allow DHS
to process more noncitizens
encountered at or near the border
through expedited removal—rather than
placing them into section 240 removal
proceedings—thereby quickly and
efficiently securing removal orders for
those who do not make a fear claim or
who receive a negative credible fear
determination. Second, as explained
above at Section IV.F.1.a of this
preamble, this rule is estimated to
reduce EOIR’s overall credible fear
workload by at least 15 percent. Third,
the calculation described above sets a
lower bound on EOIR’s expected
workload reduction, as it does not
account for efficiencies that may be
realized in cases that are referred to
EOIR for streamlined section 240
proceedings. In these three ways, the
rule will enable IJs to focus efforts on
other high-priority work, including
backlog reduction. The Departments
agree that the interviews themselves
may not take less time; however, the
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overall process for asylum applicants to
apply, interview, and receive a decision
will take less time. Adjudicative
efficiency gains and revised parole
guidelines for case-by-case
consideration could lead to individuals
spending less time overall in detention,
which would benefit the Government,
considering its limited resources and
inability to detain all those
apprehended, and the affected
individuals, who would be able to
continue to prepare for and pursue relief
or protection outside the confines of a
detention setting. Thus, as stated in the
NPRM and in this IFR, there is the
potential for backlogs to be mitigated,
though we cannot predict the timing
and scope of such potential changes
with accuracy.
Comments: A commenter stated that,
in the four months since the NPRM was
drafted, the EOIR backlog grew by more
than 100,000 cases, which is already
larger than the number of cases (75,000)
the proposed rule is intended to
address. Further, the commenter argued
that this expansion of duties would
address only 5 percent of the overall
immigration backlog and would require
27 percent of EOIR’s overall budget.
Response: The Departments recognize
the need to address the growing EOIR
backlog, which is one of the catalysts for
this rule. The NPRM developed three
population bounds for credible fear
screenings, ranging from 75,000 as a
lower bound to 300,000 as an upper
bound to account for possible variations
in future years. 86 FR 46923. As stated,
EOIR would not see the cases in which
USCIS grants asylum, which the
Departments estimate will result in at
least a 15 percent reduction in the
number of cases that would normally
arrive at EOIR after a positive credible
fear determination. Such efficiency
improvements, in conjunction with
streamlined review, could benefit
applicants and the Government, though
we cannot make exact predictions
germane to these changes.
Other Comments on Impacts on the
Federal Government
Approximately four submissions
provided other comments on impacts on
the Federal Government.
Comments: A commenter asserted
that the emphasis on expedited removal
and accompanying detention is likely to
maintain or increase extremely high
levels of unnecessary spending on
detention.
Response: As stated in the NPRM and
affirmed in this IFR, DHS will consider
paroling detained individuals in the
expedited removal process, on a caseby-case basis, consistent with the INA
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and relevant regulations and policies.
Having considered all comments
received on the issues of detention and
parole, the Departments have
determined that the current narrow
standard should be replaced not with
the standard proposed in the NPRM but
with the standard of 8 CFR 212.5(b).
That provision describes five categories
of noncitizens who may meet the parole
standard of INA 212(d)(5), 8 U.S.C.
1182(d)(5), based on a case-by-case
determination, provided they present
neither a security risk nor a risk of
absconding: (1) Noncitizens who have
serious medical conditions for which
continued detention would not be
appropriate; (2) women who have been
medically certified as pregnant; (3)
certain juveniles; (4) noncitizens who
will be witnesses in proceedings being,
or to be, conducted by judicial,
administrative, or legislative bodies in
the United States; and (5) noncitizens
whose continued detention is not in the
public interest. Expanding the potential
for parole out of custody for this
population is expected to improve the
Departments’ ability to utilize expedited
removal for a greater number and more
diverse category of noncitizens, mitigate
associated detention costs, and promote
the dignity of asylum applicants.
iv. Other Comments on Costs or
Transfers
Approximately three submissions
provided other comments on costs or
transfers.
Comments: A commenter stated that
the proposed rule will be costly to
noncitizens; ICE attorneys; judges and
staff of the immigration courts and the
BIA; the Office of Immigration Litigation
in the Department of Justice, which will
have to defend the denials of asylum
and protection appeals in Federal
courts; and judges and staff of the U.S.
Courts of Appeals. Further, the
commenter asserted that the proposed
rule’s economic analysis did not reflect
costs to the Federal judiciary.
Response: The Departments do not
expect this rule to be the cause of an
increase in the number of appeals to the
BIA or petitions for review before a U.S.
Court of Appeals. Noncitizens who
receive a negative credible fear
determination may seek a de novo
review of that determination by an IJ but
otherwise have no opportunity for
further appeal. See 8 U.S.C.
1225(b)(1)(B)(iii). The IFR does not
change that. An applicant whose asylum
claim is denied and who is ordered
removed may appeal the decision to the
BIA and further petition for review by
a U.S. Court of Appeals. This rule does
not change the current appeals process,
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nor is it expected to result in a greater
number of BIA appeals or U.S. Court of
Appeals petitions for review than would
occur otherwise.
Comments: A commenter asserted
that the rule would increase costs and
time frames for various reasons:
interview length will increase; asylum
officers will be required to write a
justification for the decision in cases
where they do not grant asylum;
transcripts of hearings will take longer
to make; asylum officers will be
required to read lengthy transcripts;
applicants may unfairly be denied a
chance to appeal if they have to
understand and file a notice of appeal;
IJs will have more paperwork; and
counsel will routinely appeal cases in
which the IJ denied a motion to allow
for additional testimony and evidence.
Response: The Departments estimated
the costs of transcription services,
which are included in Table 8 as their
own line item. USCIS does not currently
estimate asylum interview times
because each case is unique, and there
are a variety of factors outside of this
rulemaking that may impact the length
of an interview. Asylum officers are
already required to review all
documentation submitted by and
pertinent to an asylum applicant prior
to an interview. Likewise, regardless of
the decision being made, an asylum
officer provides a justification for the
decision, which is then reviewed. This
rule does not change the requirements
for asylum applicants or the evaluation
criteria that are used during
adjudication.
Comment: Several commenters said
the proposed rule would create a
‘‘massive new USCIS infrastructure,’’
the cost of which would be borne by
other applicants for USCIS benefits.
Response: USCIS has estimated the
staffing resources it will need to
implement this rule at somewhere
between 794 and 4,647 total new
positions. USCIS acknowledged in the
NPRM that if this rule were to be funded
through a future fee rule, it would
increase fees by an estimated weighted
average between 13 percent and 26
percent, depending on volumes of
applicants. USCIS is exploring all
options to provide funding for this rule
and will consider the overall costs borne
by applicants for USCIS benefits in
doing so.
Comments: A commenter requested
that the proposed rule be funded by
taxpayers.
Response: USCIS is exploring all
options to provide funding for this rule.
USCIS acknowledged in the NPRM that,
if this rule were to be funded through
a future fee rule, it would increase fees
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by an estimated weighted average
between 13 percent and 26 percent,
depending on volumes of applicants.
That estimate, however, does not
preclude USCIS from considering other
sources of funding, such as funding
from taxpayers.
d. Other Comments on Impacts and
Benefits of the Proposed Rulemaking
Comments: Several commenters said
the Departments did not analyze or
discuss the likelihood that the proposed
rule’s revisions to the asylum process
would encourage more noncitizens to
seek asylum. For example, the
Departments considered the
administrative efficiencies expected to
be gained from the rule and the
expected benefits conferred upon noncitizens availing themselves of the
asylum process through quicker
adjudication timelines. But the
Departments allegedly failed to analyze
or discuss whether these changes to the
asylum process would in fact encourage
more noncitizens living abroad to make
their way to the United States. The
commenters asserted that an increase in
noncitizens seeking to enter the United
States will further drive up enforcement
actions at the Southwest border and
increase the statistical likelihood of
non-meritorious asylum claims and
illegal entry overall. The commenter
argued that MPP, for example, achieved
concrete results in managing asylum
seekers attempting to cross the
Southwest border, but claimed it was
unclear whether the proposed rule
would achieve even remotely the same
results because the Departments failed
to analyze this issue. At a minimum, the
commenter said, the Departments
should have addressed with specificity
whether the proposed rule would be
expected to decrease or increase the
number of noncitizens attempting to
travel to the United States to seek
asylum and explain the basis for their
conclusions.
Response: The Departments do not
expect this rule to encourage or cause an
increase in the number of individuals
seeking asylum in the United States. As
explained above, this rule is not
expected to create any significant new
incentives that would drive increased
irregular migration. To the contrary, by
reducing the amount of time a
noncitizen can expect to remain in the
United States with a pending asylum
claim that originated in credible fear
screening, the rule dramatically reduces
a critical incentive for noncitizens not
in need of protection to exploit the
system. Although eligible individuals
may be granted asylum sooner,
ineligible individuals may be identified
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and ordered removed more quickly.
This rule does not change the
substantive standard for asylum
eligibility, and commenters have not
identified any evident causal
mechanism by which the rule as a
whole, in context, would systematically
and substantially incentivize more
individuals to seek to enter the United
States and pursue asylum.
2. Paperwork Reduction Act
Comments: A commenter requested
eliminating Form I–589 in order to
prevent asylum applicants from facing
rejection, delays, or missing the
deadline because the form was not
correctly completed. The commenter
argued that Form I–589 is burdensome
for applicants to complete because it is
technical and is written in and must be
completed in English (although most
asylum seekers have limited English
proficiency). The commenter also stated
that many asylum seekers do not have
legal representation while filling out the
form, often causing applicants to make
mistakes and leave required questions
blank, which could result in rejection of
the application.
Response: The rule addresses the
commenter’s concern in that applicants
with a positive credible fear
determination who are placed into the
Asylum Merits process will not have to
file a Form I–589. Rather, such an
applicant’s credible fear record will
serve as the asylum application. This
process will also ensure applicants can
apply for an EAD as soon as possible
once the requisite time period has been
met based on the date of service of a
positive credible fear determination that
serves as the date of filing of an asylum
application. This streamlined process
will not only promote efficiency but
will also serve the interests of fairness
and human dignity while
simultaneously reducing the burden on
asylum support networks and the public
by ensuring asylum seekers have access
to employment authorization as quickly
as possible. Additionally, the rule will
promote equity and due process by
ensuring that individuals who are
allowed to remain in the United States
for the express purpose of having their
asylum claims adjudicated after
receiving a positive credible fear
determination do not inadvertently miss
the one-year filing deadline for asylum
after being placed into section 240
removal proceedings and failing to
defensively file their Form I–589 within
the first 12 months. The requirement for
affirmative asylum applicants and
defensive asylum applicants in
traditional section 240 removal
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proceedings to submit a Form I–589 is
outside the scope of this rulemaking.
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3. Other Comments on Statutory and
Regulatory Requirements
Approximately four submissions
provided other feedback on statutory
and regulatory requirements.
National Environmental Policy Act
(‘‘NEPA’’)
Comments: Two commenters
expressed concerns that the
Departments have not adequately
complied with NEPA, 42 U.S.C. 4321 et
seq., by failing to specifically consider
certain potential environmental impacts
of this rule. The comments focused
primarily on population growth
impacts. Commenters also raised
broader concerns about the adequacy of
DHS’s NEPA compliance procedures as
set forth in the relevant DHS
implementing directive and instruction
manual.
Response: Even assuming that such
impacts are amenable to meaningful
analysis in some contexts, any such
analysis with respect to this rule would
be fundamentally speculative in nature.
This rule will not alter immigration
eligibility criteria or result in an
increase in the number of individuals
who may be admitted or paroled into
the United States. Rather, this rule
changes specific procedures for
adjudicating certain asylum claims
pursuant to existing standards and shifts
certain adjudicative responsibilities
from DOJ to DHS. The commenters
offered no basis to conclude that such
changes would result in environmental
impacts susceptible to meaningful
analysis. This rule will not result in any
major Federal action that will
significantly affect the human
environment and is not part of a larger
action. As discussed in the NPRM and
in the NEPA section below, the rule falls
squarely within Categorical Exclusions
A3(a) and A3(d) in DHS Instruction
Manual 023–01–001–01. See DHS,
Instruction Manual 023–01–001–01,
Revision 01, Implementation of the
National Environmental Policy Act
(NEPA) A–1, A–2 (Nov. 6, 2014), https://
www.dhs.gov/sites/default/files/
publications/DHS_
Instruction%20Manual%20023-01-00101%20Rev%2001_
508%20Admin%20Rev.pdf (Instruction
Manual 023–01). Commenters’ broader
concerns about the adequacy of DHS’s
NEPA compliance procedures are
outside the scope of this rulemaking.
Federalism
Comments: Commenters asserted that
the proposed rule failed to properly
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consider and analyze federalism
concerns. The commenters stated that,
contrary to the Departments’ conclusion
that the proposed rule insubstantially
impacts States and presents no
substantial federalism concerns, the
proposed rule would have wide-ranging
effects on States’ finances and resources.
Finally, the commenters argued that the
Departments should reassess federalism
implications and republish the
proposed rule.
In contrast, another commenter
asserted that the proposed rule does not
have sufficient federalism implications
to require a federalism summary impact
statement. The commenter referenced
section 6 of Executive Order 13132 and
stated that the proposed rule would not
have direct effect on the States, the
relationship between the National
Government and the States, or the
distribution of power and
responsibilities among the different
levels of government.
Response: The Departments did
consider federalism concerns and
determined that the rule would not have
a substantial direct effect on the States,
on the relationship between the Federal
Government and the States, or on the
distribution of power and
responsibilities among the various
levels of government. 86 FR 46939. The
Departments also determined the rule is
within the purview and authority of the
Departments and does not directly affect
States. Id. As detailed above, the rule’s
primary consequences are to authorize a
new procedure by which asylum claims
originating in credible fear screening
may be adjudicated and to authorize a
revision to the regulations governing
parole of noncitizens in expedited
removal. The latter change will enable
DHS to place more noncitizens
encountered at or near the border into
expedited removal, allowing such
noncitizens who do not make a fear
claim or who are determined not to have
a credible fear of persecution or torture
to be ordered removed more swiftly.
The Departments further note that
immigration generally is an area of
Federal regulation in which the Federal
Government, rather than the States, has
the preeminent role. See, e.g., Toll v.
Moreno, 458 U.S. 1, 10–12 (1982) (‘‘Our
cases have long recognized the
preeminent role of the Federal
Government with respect to the
regulation of aliens within our
borders.’’); Truax v. Raich, 239 U.S. 33,
42 (1915) (‘‘The authority to control
immigration—to admit or exclude
aliens—is vested solely in the Federal
government.’’); accord Sure-Tan, Inc. v.
NLRB, 467 U.S. 883, 897 (1984)
(explaining that third parties lack a
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cognizable interest ‘‘in procuring
enforcement of the immigration laws’’
against third parties in particular ways).
Unfunded Mandate Reform Act
(‘‘UMRA’’)
Comments: Several commenters
asserted that the proposed rule failed to
analyze whether an unfunded mandate
was being imposed on the States. The
commenters wrote that the Departments
addressed the requirements of the
UMRA by denying any impact.
However, the commenters raised
concerns and provided examples of how
States may incur costs associated with
undocumented noncitizens or
noncitizens who have been granted
asylum. Further, the commenters said
that, contrary to the requirements of the
UMRA, the Departments failed to allow
elected leaders in State, local, and
Tribal government to provide input on
the proposed rule.
Response: The Departments disagree
with these comments. The UMRA is
intended, among other things, to curb
the practice of imposing unfunded
Federal mandates on State, local, and
Tribal governments. As stated in the
NPRM, although this rule is expected to
exceed the $100 million expenditure in
any one year when adjusted for inflation
($169.8 million in 2020 dollars based on
the Consumer Price Index for All Urban
Consumers (‘‘CPI–U’’)),102 the
Departments do not believe this rule
would impose any unfunded Federal
mandates on State, local, or Tribal
governments, in the aggregate, or on the
private sector. The term ‘‘Federal
mandate’’ means a Federal
intergovernmental mandate or a Federal
private sector mandate. See 2 U.S.C.
1502(1), 658(6). The term ‘‘Federal
intergovernmental mandate’’ means, in
relevant part, a provision that would
impose an enforceable duty upon State,
local, or Tribal governments (except as
a condition of Federal assistance or a
duty arising from participation in a
voluntary Federal program). See 2
102 See BLS, Historical Consumer Price Index for
All Urban Consumers (CPI–U): U.S. City Average,
All Items, By Month, https://www.bls.gov/cpi/
tables/supplemental-files/historical-cpi-u202103.pdf (last visited Feb. 28, 2022). Calculation
of inflation: (1) Calculate the average monthly CPI–
U for the reference year (1995) and the most recent
current year available (2020); (2) Subtract reference
year CPI–U from current year CPI–U; (3) Divide the
difference of the reference year CPI–U and current
year CPI–U by the reference year CPI–U; (4)
Multiply by 100 = [(Average monthly CPI–U for
2020¥Average monthly CPI–U for 1995)/(Average
monthly CPI–U for 1995)] * 100 =
[(258.811¥152.383)/152.383] * 100 = (106.428/
152.383) *100 = 0.6984 * 100 = 69.84 percent = 69.8
percent (rounded). Calculation of inflation-adjusted
value: $100 million in 1995 dollars * 1.698 = $169.8
million in 2020 dollars.
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U.S.C. 658(5). The term ‘‘Federal private
sector mandate’’ means, in relevant part,
a provision that would impose an
enforceable duty upon the private sector
(except as a condition of Federal
assistance or a duty arising from
participation in a voluntary Federal
program). See 2 U.S.C. 658(7).
This rule does not contain such a
mandate because it does not impose any
enforceable duty upon any other level of
government or private-sector entity. Any
downstream effects on such entities
would arise solely due to their
voluntary choices and would not be a
consequence of an enforceable duty.
Similarly, any costs or transfer effects
on State and local governments would
not result from a Federal mandate as
that term is defined under the
UMRA.103 The requirements of the
UMRA, therefore, do not apply to this
rule; accordingly, the Departments have
not prepared an UMRA statement.
Comments: Several States asserted
that States and local communities
‘‘disproportionately bear the social and
economic costs of illegal immigration’’
because immigrants may arrive with
‘‘little to no warning,’’ a criminal record,
and little to no resources, with States
ultimately bearing the cost of providing
assistance for such individuals.
Additionally, two commenters stated
that noncitizens granted the legal status
of asylee are entitled to certain public
benefits, such as Social Security
Income, Medicaid, welfare, food stamps,
employment authorization, a driver’s
license, education, and healthcare,
which Americans rely on.
Response: To the extent that States
and local communities bear social or
economic costs associated with what the
commenters term ‘‘illegal immigration,’’
or with noncitizens entering the United
States without documentation and
seeking asylum, those are not costs
associated with this rule. As explained
above, this rule is not expected to create
any significant new incentives that
would drive increased irregular
migration. To the contrary, by reducing
the amount of time a noncitizen can
expect to remain in the United States
with a pending asylum claim, the rule
dramatically reduces a critical incentive
for noncitizens not in need of protection
to exploit the system.
Moreover, with regard to the asserted
‘‘social cost,’’ commenters cited figures
associated with noncitizens within the
United States who are taken into ICE
custody and thus improperly conflated
the characteristics of such noncitizens
with the characteristics of noncitizens
encountered at or near the border
103 See
2 U.S.C. 1502(1), 658(6).
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seeking asylum.104 The commenters’
assumptions and generalizations about
the characteristics of noncitizens
seeking asylum in the United States,
including their assumptions about the
extent to which this population relies
on public services or support rather
than private support networks, are not
supported by evidence.
With regard to the asserted economic
or fiscal cost, commenters referenced
public benefits and public services, as
well as State expenditures on border
security and policing. However, as
explained in more detail above,
estimating the net fiscal impact of
immigration is a complex calculation
that requires consideration of not only
Government expenditures on public
benefits and services but also the
various tax contributions the
noncitizens in question make to public
finances. Commenters did not provide
information or data that would allow for
a reliable estimation of the net fiscal
impact associated with relevant
populations or associated with any
marginal change in relevant
populations.105
The Departments have acknowledged
the role of support networks in
supporting noncitizens affected by this
rule. Notably, this rule’s reduction in
adjudication delays may allow some
noncitizens to become eligible for
employment authorization—and enter
the labor market—sooner under this rule
than they currently would, which could
104 For example, commenters cited ICE’s FY 2020
Enforcement and Removal Operations Report for
the proposition that 90 percent of the noncitizens
administratively arrested by ICE in FY 2020 had
either criminal convictions or criminal charges
pending. But, as that report makes clear, in FY
2020, due to the COVID–19 pandemic, ICE
‘‘narrowly focus[ed] enforcement efforts on public
safety risks and individuals subject to mandatory
detention based on criminal grounds.’’ See ICE, U.S.
Immigration and Customs Enforcement Fiscal Year
2020 Enforcement and Removal Operations Report
4 (2020), https://www.ice.gov/doclib/news/library/
reports/annual-report/eroReportFY2020.pdf.
105 Much of the information commenters did cite,
moreover, was not specific to recently arrived
noncitizens pursuing asylum claims but instead
attempted to estimate—for example—total
education costs associated with students with
limited English proficiency, total education costs
associated with all children living in a household
with an undocumented person, or total costs certain
States have incurred for law enforcement agencies
conducting public safety and security activities near
the Southwest border. See Marc Ferris and Spencer
Raley, The Elephant in the Classroom: Mass
Immigration’s Impact on Education, Federation for
American Immigration Reform 6 (Sept. 2016),
https://www.fairus.org/sites/default/files/2017-08/
FAIR-Education-Report-2016.pdf (last visited Feb.
28, 2022); Matthew O’Brien, Spencer Raley, and
Jack Martin, The Fiscal Burden of Immigration on
United States Taxpayers, Federation for American
Immigration Reform 1 (2017), https://
www.fairus.org/sites/default/files/2017-09/FiscalBurden-of-Illegal-Immigration-2017.pdf (last visited
Feb. 28, 2022).
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lead to less reliance on those support
networks. Individuals granted asylum
may work immediately.
Executive Order 13990
Comments: A commenter stated that
the proposed rule does not mention
Executive Order 13990, which requires
agencies to use an interim estimate of
the social costs of greenhouse gases
when monetizing the value of changes
regulations. The commenter said it is
clear that the Departments did not refer
to the Executive order during
rulemaking, and that it is arbitrary and
capricious for agencies to follow the
Executive order only when the Biden
Administration dislikes a policy.
Response: Executive Order 13990
seeks to protect public health and the
environment and restore science to
tackle the climate crisis. The
Departments agree with the commenter
that they did not mention or refer to
E.O. 13990 for this rulemaking. This
rule establishes a new procedure by
which individuals who receive a
positive credible fear determination may
have their claims for asylum
adjudicated by USCIS in the first
instance, rather than EOIR bearing the
full responsibility for adjudicating such
claims. The changes made through this
rule are within the purview and
authority of the Departments and do not
have any direct or substantial link to
greenhouse gas emissions. Moreover,
the rule does not otherwise relate to the
subject matter of E.O. 13990.106
G. Comments Outside of the Scope of
This Rulemaking
The Departments received many
comments outside of the scope of this
rulemaking. Because these comments
are outside of the relevant scope, the
Departments are not providing
responses to these comments or
addressing the issues raised in these
comments. Comments from the public
outside of the scope of this rulemaking
concerned the following issues: USCIS
maintaining its ‘‘Last In, First Out’’
affirmative asylum scheduling process
to reduce incentives for applicants to
file only for the purpose of obtaining an
EAD; termination of the Deferred Action
for Childhood Arrivals (‘‘DACA’’)
program; a recommendation that
individuals seeking protection due to
climate change should receive positive
credible fear determinations and be
granted asylum; policies relating to
Afghan evacuees; the title 42 order
106 In addition, a district court has enjoined
certain agencies from implementing Section 5 of
E.O. 13990. See Louisiana v. Biden, No. 2:21–cv–
1074, 2022 WL 438313 (W.D. La. Feb. 11, 2022),
appeal filed, No. 22–30087 (5th Cir. Feb. 19, 2022).
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issued by the Centers for Disease
Control and Prevention; policies relating
to immigration vetting and background
checks; and other immigration and
border management policies.
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V. Statutory and Regulatory
Requirements
A. Administrative Procedure Act
The APA generally requires agencies
to publish notice of a proposed
rulemaking in the Federal Register and
allow for a period of public comment.
5 U.S.C. 553(b). The Departments
published an NPRM on August 20,
2021, and allowed for a 60-day
comment period. As detailed
previously, in response to comments,
the Departments have altered the rule in
multiple ways. The Departments are in
compliance with the APA’s notice-andcomment requirements with respect to
these changes because each change is a
logical outgrowth of the proposals set
forth in the NPRM, or a rule of agency
procedure to which the notice-andcomment requirements do not apply, or
both.
To satisfy the APA’s notice-andcomment requirements, generally, the
final rule an agency adopts must either
meet an exception to the notice-andcomment requirements or be a logical
outgrowth of the NPRM. Long Island
Care at Home, Ltd. v. Coke, 551 U.S.
158, 174 (2007). The logical outgrowth
test asks whether the purposes of notice
and comment have been adequately
served, such that there was ‘‘fair
notice.’’ See id. ‘‘In most cases, if the
agency . . . alters its course in response
to the comments it receives, little
purpose would be served by a second
round of comment.’’ Am. Water Works
Ass’n v. EPA, 40 F.3d 1266, 1274 (D.C.
Cir. 1994). Accordingly, the ‘‘logical
outgrowth’’ test normally is applied to
consider ‘‘whether a new round of
notice and comment would provide the
first opportunity for interested parties to
offer comments that could persuade the
agency to modify its rule.’’ Id. The
changes made in this IFR were adopted
in response to comments received and
build logically on the NPRM. Thus, in
these circumstances, ‘‘interested parties
should have anticipated that the change
was possible, and thus reasonably
should have filed their comments on the
subject during the notice-and-comment
period.’’ CSX Transp., Inc. v. Surface
Transp. Bd., 584 F.3d 1076, 1079–80
(D.C. Cir. 2009) (quotation marks
omitted).
Moreover, the APA’s notice-andcomment requirements do not apply to
‘‘rules of agency . . . procedure.’’ 5
U.S.C. 553(b)(A). A ‘‘ ‘critical feature’ of
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the procedural exception ‘is that it
covers agency actions that do not
themselves alter the rights or interests of
parties, although it may alter the
manner in which the parties present
themselves or their viewpoints to the
agency.’ ’’ JEM Broad. Co., Inc. v. FCC,
22 F.3d 320, 326 (D.C. Cir. 1994)
(quoting Batterton v. Marshall, 648 F.2d
694, 707 (D.C. Cir. 1980)); cf. Texas v.
United States, 809 F.3d 134, 176 (5th
Cir. 2015) (holding that a rule is not
procedural when it ‘‘modifies
substantive rights and interests’’
(quoting U.S. Dep’t of Lab. v. Kast
Metals Corp., 744 F.2d 1145, 1153 (5th
Cir. 1984)). ‘‘In determining whether a
rule is substantive, [a court] must look
at [the rule’s] effect on those interests
ultimately at stake in the agency
proceeding.’’ Neighborhood TV Co., Inc.
v. FCC, 742 F.2d 629, 637 (D.C. Cir.
1984). ‘‘Hence, agency rules that impose
‘derivative,’ ‘incidental,’ or ‘mechanical’
burdens upon regulated individuals are
considered procedural, rather than
substantive.’’ Nat’l Sec. Couns. v. CIA,
931 F. Supp. 2d 77, 107 (D.D.C. 2013);
see Am. Hosp. Ass’n v. Bowen, 834 F.2d
1037, 1051 (D.C. Cir. 1987). Moreover,
‘‘an otherwise-procedural rule does not
become a substantive one, for noticeand-comment purposes, simply because
it imposes a burden on regulated
parties.’’ James V. Hurson Assocs., Inc.
v. Glickman, 229 F.3d 277, 281 (D.C.
Cir. 2000). Finally, although a
procedural rule generally may not
‘‘encode[ ] a substantive value judgment
or put[ ] a stamp of approval or
disapproval on a given type of
behavior,’’ Bowen, 834 F.2d at 1047,
‘‘the fact that the agency’s decision was
based on a value judgment about
procedural efficiency does not convert
the resulting rule into a substantive
one,’’ Glickman, 229 F.3d at 282.
Notably, many of the revisions to the
proposed rule do not alter individuals’
rights or interests. See JEM Broad., 22
F.3d at 326. Instead, the revisions relate
to the procedure by which such claims
shall be presented before the agencies,
see id., without encoding a substantive
value judgment, see Bowen, 834 F.2d at
1047, other than the need for procedural
efficiency, see Glickman, 229 F.3d at
282; see also Lamoille Valley R. Co. v.
I.C.C., 711 F.2d 295, 328 (D.C. Cir. 1983)
(holding that an order changing the
schedule for an adjudication, including
when parties were to submit briefing,
was a procedural rule); Elec. Priv. Info.
Ctr. v. U.S. Dep’t of Homeland Sec., 653
F.3d 1, 5 (D.C. Cir. 2011) (even ‘‘a rule
with a ‘substantial impact’ upon the
persons subject to it is not necessarily
a substantive rule’’ (citing Pub. Citizen
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v. Dep’t of State, 276 F.3d 634, 640–41
(D.C. Cir. 2002)); Ranger v. FCC, 294
F.2d 240, 244 (D.C. Cir. 1961) (while
holding that a rule was procedural,
noting that ‘‘no substantive rights were
actually involved by the regulation
itself’’ even if ‘‘failure to observe it
might cause the loss of substantive
rights’’).
Although additional notice and
comment are not required, the
Departments acknowledge that they
would benefit from the public’s input
on the provisions in this IFR as well as
the IFR’s implementation. However, the
Departments also believe that the
immigration system would benefit from
rapid implementation of the rule, which
is lawful given that the rule is a logical
outgrowth of the NPRM and because the
changes relate to procedural issues. The
benefits of rapid implementation
include the ability to begin allocating
resources to implement the new
process, including hiring asylum
officers, which can take many months.
Further, the benefit of additional public
comment alongside practical experience
with gradual implementation will aid
the Departments in promulgating a
future final rule. For these reasons, the
Departments have decided to follow the
NPRM with this IFR.
B. Executive Order 12866 (Regulatory
Planning and Review) and Executive
Order 13563 (Improving Regulation and
Regulatory Review)
Executive Orders 12866 and 13563
direct agencies to assess the costs and
benefits of available regulatory
alternatives and, to the extent permitted
by law, to proceed only if the benefits
justify the costs. They also direct
agencies to select regulatory approaches
that maximize net benefits while giving
consideration, to the extent appropriate
and consistent with law, to values that
are difficult or impossible to quantify,
including equity, human dignity,
fairness, and distributive impacts. In
particular, E.O. 13563 emphasizes the
importance of not only quantifying both
costs and benefits, reducing costs,
harmonizing rules, and promoting
flexibility, but also considering equity,
fairness, distributive impacts, and
human dignity. All of these
considerations are relevant here. OIRA
within OMB has designated this IFR an
economically significant regulatory
action under sec. 3(f)(1) of E.O. 12866.
Accordingly, OIRA has reviewed this
regulation.
1. Summary of the Rule and Its Potential
Impacts
As detailed previously, in response to
comments, the Departments have
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altered the rule in multiple ways from
the NPRM. None of the revisions
outlined in Section II.C of this preamble
has led to revisions in the overall cost
benefit analysis, which remains
unchanged from the NPRM. However,
relative to the NPRM, the changes in
this IFR, such as the use of streamlined
section 240 removal proceedings in
place of the NPRM’s IJ review
procedure, may result in smaller overall
operational efficiencies, as discussed
below.
This rule changes and streamlines the
overall adjudicatory process for asylum
applications arising out of the expedited
removal process. By reducing undue
delays in the system, and by providing
a variety of procedural safeguards, the
rule protects equity, human dignity, and
fairness.
A central feature of the rule changes
the respective roles of an IJ and an
asylum officer during proceedings for
further consideration of asylum
applications after a positive credible
fear determination. Notably, IJs will
retain their existing authority to review
de novo the negative determinations
made by asylum officers in a credible
fear proceeding. In making credible fear
determinations, asylum officers will
return to evaluating whether there is a
significant possibility that the
noncitizen could establish eligibility for
asylum, withholding of removal, or CAT
protection for possible referral to a full
hearing of the claim, and the noncitizen
will still be able to seek review of that
negative credible fear determination
before the IJ.
Asylum officers will take on a new
role of adjudicating the merits of
protection claims made by some
noncitizens who have received a
positive credible fear determination, a
role previously carried out only by IJs as
part of a proceeding under section 240
of the INA. Noncitizens whose claims
are not granted by an asylum officer will
be referred to an IJ for a streamlined
section 240 removal proceeding.
The population of individuals likely
to be affected by this rule’s provisions
are individuals for whom USCIS
completes a credible fear screening. The
average annual number of credible fear
screenings for FY 2016 through 2020
completed by USCIS is broken out as
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59,280 positive credible fear
determinations and 12,083 negative
credible fear determinations, for a total
of 71,363 individuals with credible fear
determinations. DHS expects that this
population will be affected by the rule
in a number of ways, which may vary
from person to person depending on (1)
whether the individual receives a
positive credible fear determination,
and (2) whether the individual’s asylum
claim is granted by an asylum officer. In
addition, because of data constraints
and conceptual and empirical
challenges, we can provide only a
partial monetization of the impacts on
individuals. For example, asylum
seekers who establish credible fear may
benefit from having their asylum claims
adjudicated potentially sooner than they
otherwise would. Those who are
granted asylum sooner receive
humanitarian protection from the
persecution they faced in their country
of origin on account of their race,
religion, nationality, membership in a
particular social group, or political
opinion, and they have a possible path
to citizenship in the United States.
These outcomes obviously constitute a
benefit in terms of human dignity and
equity, but it is a benefit that is not
readily monetized. Asylum seekers who
establish credible fear may also benefit
from cost savings associated with not
having to incur filing expenses, as well
as earlier labor force entry. The
Departments have estimated this impact
on a per-person workday basis.
As it relates to the Government and
USCIS costs, the planned human
resource and information-related
expenditures required to implement this
rule are monetized as real resource
costs. These estimates are developed
along three population bounds, ranging
from 75,000 to 300,000 credible fear
screenings to account for possible
variations in future years. Furthermore,
the possibility of parole for more
individuals—applied on a case-by-case
basis—could lower the cost to the
Government per person processed. The
Departments have also estimated
potential employment tax impacts
germane to earlier labor force entry,
likewise on a per-person workday basis.
Such estimates made on a per-person
basis reflect a range of wages that the
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impacted individuals could earn. The
per-person per-workday estimates are
not extended to broader monetized
impacts due to data constraints.
An important caveat for the possible
benefits to asylum applicants who
establish a credible fear introduced
above and discussed more thoroughly in
this analysis is that it is expected to take
time to implement this rule. Foremost,
the Departments expect the resourcing
of this rule to be implemented in a
phased approach. Further, although upfront expenditures to support the
changes from this rule based on
planning models are high, the logistical
and operational requirements of this
rule may take time to fully implement.
For instance, once USCIS meets its
staffing requirements, time will be
required for the new asylum staff to be
trained for their positions, which may
occur over several months. As a result,
the benefits to applicants and the
Government may not be realized
immediately.
To develop the monetized costs of the
rule, the Departments relied on a low,
midrange, and high population bound to
reflect future uncertainty in the
population. In addition, resources are
partially phased in over FYs 2022 and
2023, as a full phasing in of resources,
potentially up to FY 2026, is not
possible at this time because of budget
constraints and timing of hiring, and
because the Departments do not have
fully developed resource projections
applicable to this rule stretching past FY
2023. The average annualized cost of
this rule ranges from $180.4 million to
$1.0 billion, at a 3 percent discount rate,
and from $179.5 million to $995.8
million, at a 7 percent discount rate. At
a 3 percent discount rate, the total 10year costs could range from $1.5 billion
to $8.6 billion, with a midpoint of $3.9
billion. At a 7 percent discount rate, the
total 10-year costs could range from $1.3
billion to $7.0 billion, with a midpoint
of $3.2 billion.
A summary of the potential impacts of
this IFR are presented in Table 1 and are
discussed in more detail more in the
following analysis. Where quantitative
estimates are provided, they apply to
the midpoint figure (applicable to the
wage range or the population range).
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TABLE 1—SUMMARY OF THE EXPECTED IMPACTS OF THE INTERIM FINAL RULE
Entities impacted
Individuals who receive a positive credible fear determination.
Individuals who receive a negative credible fear determination.
DHS–USCIS ..............................
EOIR ..........................................
Support networks for asylum
applicants who receive a
positive credible fear determination.
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Other ..........................................
Annual population estimate
USCIS provides a range from
75,000 to 300,000 total individuals who receive credible
fear determinations. In recent
years (see Table 3), approximately 83.1 percent of individuals screened have received a positive credible fear
determination.
USCIS provides a range from
75,000 to 300,000 total individuals who receive credible
fear determinations. In recent
years (see Table 3), approximately 16.9 percent of individuals screened have received a negative credible
fear determination.
N/A ............................................
• Potential early labor earnings for asylum applicants who obtain an EAD of $225.44 per person
per workday. This impact could potentially constitute a transfer from workers in the U.S. labor
force to certain asylum applicants. We identified two factors that could drive this impact of
early entry to the labor force: (i) More expeditious grants of asylum, thereby authorizing work
incident to status; and (ii) a change in timing apropos to the ‘‘start’’ time for filing for employment authorization—the ‘‘EAD-clock’’ duration is not impacted, but it ‘‘shifts’’ to an earlier starting point. On the other hand, some individuals who would have reached the ‘‘EAD-clock’’ duration for a pending asylum application and obtained employment authorization under the current regulations may not obtain employment authorization if their asylum claims are promptly
denied.
• The impacts involving compensation to individuals may be overstated because of potential
value of non-paid work such as childcare or housework.
• Individuals might not have to wait lengthy times for a decision on their protection claims. This
is a benefit in terms of equity, human dignity, and fairness.
• Some individuals could benefit from de novo review by an IJ of the asylum officer’s decision
not to grant their asylum claims.
• Some individuals may benefit in terms of human dignity if paroled from detention while awaiting their credible fear interviews and determinations.
• Parole may result in more individuals failing to appear for hearings.
• At a 7 percent discount rate, the resource costs could be $451.2 million annually, based on
up-front and continuing expenditures.
• It is reasonable to assume that there could be a reduction in Form I–765 filings due to more
expeditious adjudication of asylum claims, but there could also be countervailing influences;
hence, the volume of Form I–765 filings (writ large or for specific classes related to asylum)
could decrease, remain the same, or increase—these reasons are elucidated in the analysis.
A net change in Form I–765 volumes overall could impact the incumbent volume of biometrics
and biometrics services fees collected; however, based on the structure of the USCIS ASC
biometrics processing contract, it would take a significant change in such volumes for a particular service district to generate marginal cost increases or savings per biometrics submission.
555 current IJs as well as sup- • After implementation is fully phased in, EOIR no longer adjudicates asylum claims raised in
port staff and other personnel.
expedited removal in the first instance. EOIR would conduct streamlined section 240 removal
proceedings for individuals not granted asylum.
• Allows EOIR to focus efforts on other high-priority work and reduce its substantial current
backlog.
• There could be non-budget related cost savings if the actual time worked on a credible fear
case decreases in the transfer of credible fear cases to USCIS.
Unknown ................................... • To the extent that some applicants may be able to earn income earlier than they otherwise
could currently, burdens on the support network of the applicant may be lessened. This network could include public and private entities and family and personal friends, legal services
providers and advisors, religious and charitable organizations, State and local public institutions, educational providers, and NGOs.
Unknown ................................... • There could be familiarization costs associated with this IFR; for example, if attorneys representing each asylum client reviewed the rule, based on average reading speed, the cost
would be about $76.3 million, which would potentially be incurred during the first year the rule
is effective.
• There may be some labor market impacts as some asylum seekers who currently enter the
labor market with a pending asylum application would no longer be entering the labor market
under this IFR if they receive negative decisions on their asylum claims sooner. Applicants
with a positive credible fear determination may enter the labor market sooner under this IFR
than they would currently.
• Tax impacts: Employees and employers would pay their respective portion of Medicare and
Social Security taxes as a result of the earlier entry of some individuals into the labor market.
We estimate employment tax impacts could be $34.49 per person on a workday basis.
In addition to the impacts
summarized above, and as required by
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Expected impacts
• Maximum potential cost-savings to applicants of Form I–589 of $364.86 per person.
• Potential cost savings to applicants of Form I–765 of $370.28 per person.
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prepared accounting statement showing
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the costs and benefits associated with
this regulation.
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TABLE 2—OMB A–4 ACCOUNTING STATEMENT
[$ millions, FY 2020]
Time period: FY 2022 through FY 2031
Category
Primary estimate
Minimum
estimate
Maximum
estimate
Source citation
Benefits
Monetized benefits ................................................................................
Not estimated
Not estimated
Not estimated
Annualized quantified, but un-monetized, benefits ...............................
N/A
N/A
N/A
Unquantified benefits .............................................................................
Some individuals may benefit from filing cost savings
related to Forms I–589 and I–765. Early labor market
entry would be beneficial in terms of labor earnings to
the applicant, but also because it could reduce burdens
on the applicants’ support networks.
Benefits driven by increased efficiency would enable
some asylum-seeking individuals to move through the
asylum process more expeditiously than through the
current process, with timelines potentially decreasing
significantly, thus promoting both human dignity and
equity. Adjudicative efficiency gains and expanded
possibility of parole on a case-by-case basis could lead
to individuals spending less time in detention, which
would benefit the Government and the affected
individuals.
Another, potentially very significant, benefit is that EOIR
would not see the cases in which USCIS grants asylum,
which we estimate as at least a 15 percent reduction in
its overall credible fear workload. This could help
mitigate the backlog of cases pending in immigration
courts. Additionally, this benefit would extend to
individuals granted or not granted asylum faster than if
they were to go through the current process with EOIR.
Depending on the individual case circumstances, this
IFR would mean that such noncitizens would likely not
remain in the United States—for years, potentially—
pending resolution of their claims, and those who qualify
for asylum would be granted asylum several years
earlier than under the present process.
The anticipated operational efficiencies from this IFR
may provide for prompt grant of relief or protection to
qualifying noncitizens and ensure that those who do not
qualify for relief or protection may be removed sooner
than under current rules. Relative to the NPRM, the
changes in this IFR may result in smaller operational
efficiencies to DHS because the ICE Office of the
Principal Legal Advisor will need to play a more
significant role because noncitizens not approved for
asylum will now be placed into streamlined section 240
removal proceedings.
Regulatory
(‘‘RIA’’).
Costs
Annualized monetized costs for 10-year period between 2021 and
2030 (discount rate in parentheses).
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Annualized quantified, but un-monetized, costs ....................................
(3 percent)
$453.8
$180.4
$1,002.4
(7 percent)
$451.2
$179.5
$995.8
• Potential cost-savings applicable to Form I–589 of
$338.86 per person.
RIA.
• Potential cost-savings applicable to Form I–765 of
$377.32 per person.
• Familiarization costs of about $76.3 million (in 2022).
• The transfer of cases from EOIR to USCIS would
allow resources at EOIR to be directed to other work,
and there is a potential for cost savings to be realized for
credible fear processing specifically if the average cost
of worktime spent on cases by USCIS asylum officers
would be lower than at EOIR currently. These would not
be budgetary cost savings, and USCIS has not made a
one-to-one time- and cost-specific comparison between
worktime actually spent on a case at EOIR and USCIS.
RIA.
Qualitative (unquantified) costs .............................................................
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Impact
Analysis
Federal Register / Vol. 87, No. 60 / Tuesday, March 29, 2022 / Rules and Regulations
18199
TABLE 2—OMB A–4 ACCOUNTING STATEMENT—Continued
[$ millions, FY 2020]
Time period: FY 2022 through FY 2031
Category
Primary estimate
Minimum
estimate
Maximum
estimate
Source citation
Transfers
Annualized transfers: .............................................................................
Potential transfers include labor earnings that would
accrue to credible fear asylum applicants who enter the
labor market earlier than they would currently. The
impact accruing to labor earnings developed in this rule
has the potential to include both distributional effects
(which are transfers) and indirect benefits to employers.
The distributional impacts would accrue to asylum
applicants who enter the U.S. labor force earlier than
under current regulations, in the form of increased
compensation (wages and benefits) and to the
Government in the form of tax impacts. A portion of this
compensation gain and tax payment might be
transferred to asylum applicants from others who are
currently in the U.S. labor force or eligible to work
lawfully.
From whom to whom? ...........................................................................
Potential transfers include a distributional economic
impact in the form of a transfer to asylum applicants who
enter the labor force earlier than they would currently if
they take on work performed by others already in the
U.S. workforce.
Miscellaneous analyses/category ..........................................................
N/A
Effects on State, local, or Tribal governments ......................................
N/A
Effects on small businesses ..................................................................
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This IFR does not directly regulate small entities, but
rather individuals.
Effects on wages ...................................................................................
None
Effects on growth ...................................................................................
None
2. Background and Purpose of the Rule
The purpose of this rule is to address
the rising number of apprehensions at or
near the Southwest border and the
ability of the U.S. asylum system to
fairly and efficiently handle protection
claims made by those encountered. The
rule streamlines and simplifies the
adjudication process for certain
individuals who are encountered at or
near the border, placed into expedited
removal, and determined to have a
credible fear of persecution or torture,
with the aim of adjudicating
applications for asylum, statutory
withholding of removal, and CAT
protection in a timelier fashion and with
appropriate procedural protections
against error. A principal feature of the
rule is to transfer the initial
responsibility for adjudicating asylum,
statutory withholding of removal, and
CAT protection applications from IJs to
USCIS asylum officers for individuals
within expedited removal proceedings
who receive a positive credible fear
determination.
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The IFR may broaden the
circumstances in which individuals
making a fear claim during the
expedited removal process could be
considered for parole on a case-by-case
basis prior to a positive credible fear
determination being made. For such
individuals, parole could be granted as
an exercise of discretion consistent with
INA section 212(d)(5)(A), 8 U.S.C.
1182(d)(5)(A), when continued
detention is not in the public interest.
This rule applies only to recentlyarrived individuals who are subject to
expedited removal—i.e., adults and
families. The rule does not apply to
unaccompanied children, as they are
statutorily exempt from being placed
into expedited removal. It also does not
apply to individuals already residing in
the United States and whose presence in
the United States is outside the coverage
of noncitizens designated by the
Secretary as subject to expedited
removal. The rule also does not apply to
(1) stowaways or (2) noncitizens who
are physically present in or arriving in
the CNMI. Those classes of noncitizens
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RFA.
will continue to be referred to asylum/
withholding-only hearings before an IJ
under 8 CFR 208.2(c). Finally, this rule
does not require that a noncitizen
amenable to expedited removal after the
effective date of the rule be placed in
the nonadversarial merits adjudication
process described in this IFR. Rather,
DHS generally, and USCIS in particular,
retain discretion to issue an NTA to a
covered noncitizen in expedited
removal proceedings to instead place
them in ordinary section 240 removal
proceedings at any time after they are
referred to USCIS for a credible fear
determination. See Matter of E–R–M– &
L–R–M–, 25 I&N Dec. at 523; see also 8
CFR 1208.2(c).
In this section we provide some data
and information relevant to the ensuing
discussion and analysis of the potential
impacts of the rule. We first present
USCIS data followed by EOIR data.
Table 3 shows USCIS data for the Form
I–589 and credible fear cases for the
five-year span from FY 2016 through FY
2020.
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TABLE 3—USCIS FORM I–589, APPLICATION FOR ASYLUM AND FOR WITHHOLDING OF REMOVAL, AND CREDIBLE FEAR
DATA
[FY 2016 through FY 2020] 107
Form I–589 receipts
FY
2016
2017
2018
2019
2020
Initial
receipts
Credible fear completions
Pending
receipts
Positive
screen
Negative
screen
All
completions
Total
credible fear
cases 108
.........................................................................
.........................................................................
.........................................................................
.........................................................................
.........................................................................
115,888
142,760
106,041
96,861
93,134
194,986
289,835
319,202
349,158
386,014
73,081
60,566
74,677
75,252
12,824
9,697
8,245
9,659
16,679
16,134
82,778
68,811
84,336
91,931
28,958
94,048
79,842
99,035
102,204
30,839
5-year Total .......................................................
554,684
N/A
296,400
60,414
356,814
405,968
5-year Average ..........................................
110,937
307,839
59,280
12,083
71,363
81,194
Source: USCIS Office of Performance and Quality (‘‘OPQ’’), and USCIS Refugee, Asylum, and International Operations (‘‘RAIO’’) Directorate,
CLAIMS 3 database, global (received May 11, 2021).
As can be seen from Table 3, the Form
I–589 pending case number has grown
steadily since 2016, and, as of the fourth
quarter of FY 2021, was 412,796,109
which is well above the five-year
average of 307,839. Over that same
period, the majority, 83.1 percent, of
completed credible fear screenings were
positive, while 16.9 percent were
negative.
In addition to the credible fear case
data presented in Table 3, USCIS data
and analysis can provide some insight
concerning how long it has taken for the
credible fear screening process to be
completed. As detailed in this preamble,
although this rule’s primary concern is
the length of time before incoming
asylum claims are expected to be
adjudicated by EOIR, changes to USCIS
processes enabled by this rule
(including, for example, improved
systems for conducting credible fear
interviews for individuals who are not
in detention facilities) are also expected
to reduce processing times for credible
fear cases. Table 4 provides credible fear
processing durations at USCIS.
TABLE 4—CREDIBLE FEAR TIME DURATIONS FOR DETAINED AND NON-DETAINED CASES
[In average and median days, FY 2016 through FY 2021]
Detained
FY
Non-detained
Screen
Average
2016 ..................................................
2017 ..................................................
2018 ..................................................
2019 ..................................................
2020 ..................................................
2021 ..................................................
Positive .............................................
Negative ...........................................
Positive .............................................
Negative ...........................................
Positive .............................................
Negative ...........................................
Positive .............................................
Negative ...........................................
Positive .............................................
Negative ...........................................
Positive .............................................
Negative ...........................................
Median
23.3
34
23.3
34.2
22.6
32.3
35.6
44.7
37.2
30.3
25.6
29.8
Average
13
26
13
25
16
25
24
33
20
16
15
17
290.6
197.1
570.1
496.1
816.2
811.7
1,230.9
1,067.3
1,252.7
1,311.2
955.3
1,174.0
Median
163.0
80.5
407.0
354.0
671.0
668.0
1,082.0
959.0
1,065.0
1,247.0
919.0
1,109.0
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Source: Data and analysis provided by USCIS, RAIO Directorate, SAS Predictive Modeling Environment and data-bricks databases, received
May 11, 2021. FY 2021 includes partial fiscal year data as of May 2021.
Table 4 reports the ‘‘durations,’’
defined as the elapsed days from date of
apprehension to forwarding of the
credible fear screening process at
USCIS, in both averages and medians.
USCIS has included data through May
11, 2021. The total time for cases from
apprehension to adjudication by EOIR
can be found by adding the times in
107 In FY 2020, the credible fear filings are
captured in Form I–870, Record of Determination/
Credible Fear Worksheet. As part of the credible
fear screening adjudication, USCIS asylum officers
prepare Form I–870, Record of Determination/
Credible Fear Worksheet. This worksheet includes
biographical information about the applicant,
including the applicant’s name, date of birth,
gender, country of birth, nationality, ethnicity,
religion, language, and information about the
applicant’s entry into the United States and place
of detention. Additionally, Form I–870 collects
sufficient information about the applicant’s marital
status, spouse, and children to determine whether
they may be included in the determination. Form
I–870 also documents the interpreter identification
number of the interpreter used during the credible
fear interview and collects information about
relatives or sponsors in the United States, including
their relationships to the applicant and contact
information. In previous years credible fear filings
included Form I–867, Credible Fear Referral. Prior
to FY 2020, the USCIS Asylum Division
electronically received information about credible
fear determinations through referral documentation
provided by CBP. The referral documentation
includes a form containing information about the
applicant: Form I–867, Credible Fear Referral.
108 The credible fear total receipts are larger than
the sum of positive and negative determinations
because the latter apply to ‘‘completions,’’ referring
to cases forwarded to EOIR, and thus exclude cases
that were administratively closed.
109 USCIS, Immigration and Citizenship Data,
https://www.uscis.gov/tools/reports-and-studies/
immigration-and-citizenship-data (filter by Asylum
Category to search for file ‘‘All USCIS Application
and Petition Form Types (Fiscal Year 2021, 4th Qtr,
July 1–September 30, 2021) (Dec. 15, 2021)’’).
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Table 4 with the times in Table 6,
below.
The data in Table 4 are not utilized
to develop quantitative impacts, but
rather are intended to build context and
situational awareness. There are several
key observations from the information
presented. Foremost, there is a
substantial difference between durations
for the detained and the non-detained
populations. The existence of a gap is
expected because USCIS can interface
with detained individuals rapidly.
However, the gap has grown over time;
in 2016 the duration for positivescreened processing was 12.5 times
greater, but by 2021 it had grown to a
factor of nearly 40. Second, and
relatedly, there was a substantial
duration rise through 2019 for both
detained and non-detained screenings,
although there has been a recent
pullback. Furthermore, the duration for
negative screenings is lower across the
board than for positive screenings—as of
the most recent data point, the duration
was about 19 percent lower for negative
screened cases. It is also seen that the
FY 2021 average durations for detained
cases are relatively close to FY 2016
through FY 2018 levels, with this series
witnessing a spike in 2019.
Because some of the EOIR data are
presented in medians, we note that the
median durations are lower than the
means for both screened types. This
indicates that a small number of cases
take an exceptionally long time to
resolve, resulting in large outlier data
points that skew the mean upwards. For
non-detained cases, the gap between
median and mean duration is relatively
18201
consistent up to FY 2021, but the mean
and median converge toward the end of
the period; this feature of the data could
indicate that fewer outlier durations
were represented in the data.
It is possible that the rule may impact
the volume and timing of employment
authorization applications and
approvals. Although we cannot predict
the net change in filings for the Form
I–765 categories, we present data on
initial filings and approvals for three
asylum-related categories in Table 5. As
a result of the rule, there could be
substitutions in Form I–765 categories
from the (c)(8), Applicant for Asylum/
Pending Asylum, into the (a)(5), Granted
Asylum Under Section 208, and (a)(10)
Granted Withholding of Removal/243
(H) categories, in Table 5.
TABLE 5—USCIS FORM I–765 APPLICATION FOR EMPLOYMENT AUTHORIZATION INITIAL RECEIPTS AND APPROVALS
RELATED TO ASYLEE CATEGORIES
[FY 2016 through FY 2020]
EAD category (a)(5)
Granted asylum under section 208
FY
Initial
receipts
2016
2017
2018
2019
2020
Approvals
EAD category (c)(8)
applicant for
asylum/pending asylum
EAD category (a)(10)
granted withholding of
removal/243 (H)
Initial
receipts
Initial
receipts
Approvals
Approvals
.................................................................................
.................................................................................
.................................................................................
.................................................................................
.................................................................................
29,887
32,673
38,743
47,761
31,931
27,139
29,648
39,598
41,288
36,334
169,970
261,782
262,965
216,038
233,864
152,269
234,053
246,525
177,520
183,820
2,008
1,936
1,733
2,402
3,318
1,621
1,076
1,556
2,101
2,554
5-year total ................................................................
180,995
174,007
1,144,619
994,187
11,397
8,908
5-year Average ..................................................
36,199
34,801
228,924
198,837
2,279
1,782
Source: OPQ, USCIS, Form I–765 Application for Employment Authorization: All Receipts, Approvals, Denials Grouped by Eligibility Category
and Filing Type (May 11, 2021), https://www.uscis.gov/sites/default/files/document/reports/I-765_Application_for_Employment_FY03-20.pdf.
Across the three relevant employment
authorization categories, the total of the
averages is 267,402 initial EADs, with a
total of 235,420 approved EADs.
Having presented information and
data applicable to USCIS specifically,
we now turn to EOIR data and
information. Table 6 presents average
and median processing times for EOIR
to complete cases originating from the
credible fear screening process, positive
and negative, and detained and nondetained. The processing time
represents that time between when a
case is lodged in EOIR systems and a
final decision. Note that the ‘‘initial case
completions’’ are not directly
comparable to USCIS completions (see
Table 3) in terms of annual volumes for
two primary reasons. First, there can be
timing differences in terms of when a
credible fear case is sent to EOIR and
when it is lodged in its processing
systems. Second, not all individuals
determined to have a credible fear
follow up with their cases with EOIR,
and some filed cases are
administratively closed. Therefore, as a
rule, case completions by EOIR would
be necessarily lower than
‘‘completions’’ at USCIS.
TABLE 6—EOIR TIME DURATION METRICS, DAYS, AND COMPLETIONS FOR CASES WITH A CREDIBLE FEAR ORIGIN
Average
processing time
FY
Median
processing time
Initial case
completions
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6A. Average and Median Processing Times (in Days) for Form I–862 Initial Case Completions with a Credible Fear Origin
2016 .................................................................................................................................
2017 .................................................................................................................................
2018 .................................................................................................................................
2019 .................................................................................................................................
2020 .................................................................................................................................
2021–March 31, 2021 (years) .........................................................................................
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413
447
648
669
712
1,078 (2.95)
E:\FR\FM\29MRR2.SGM
214
252
512
455
502
857 (2.35)
29MRR2
16,794
26,531
33,634
55,404
33,517
6,646
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TABLE 6—EOIR TIME DURATION METRICS, DAYS, AND COMPLETIONS FOR CASES WITH A CREDIBLE FEAR ORIGIN—
Continued
Average
processing time
FY
Median
processing time
Initial case
completions
6B. Average and Median Processing Times (in Days) for Form I–862 Initial Case Completions with a Credible Fear Origin and Only an
Application for Asylum, Statutory Withholding of Removal, and Withholding and Deferral of Removal Under the CAT
2016 .................................................................................................................................
2017 .................................................................................................................................
2018 .................................................................................................................................
2019 .................................................................................................................................
2020 .................................................................................................................................
2021–March 31, 2021 (years) .........................................................................................
514
551
787
822
828
1,283 (3.52)
300
378
690
792
678
1,316 (3.61)
7,519
13,463
19,293
30,052
21,058
3,730
Source: EOIR, Planning, Analysis, and Statistics Division (‘‘PASD’’), data obtained April 19, 2021. The row for FY 2021 reflects data through
March 31, 2021.
The FY 2021 data point reflects data
through the start of FY 2021 to March
31, 2021, and we have included the
current processing times in years for
situational awareness. As Table 6
shows, there was an across-the-board
jump in processing times in FY 2018,
followed by a leveling off until FY 2021,
when the processing times surged again.
3. Population
The population expected to be
affected by this rule is the total number
of credible fear completions processed
annually by USCIS (71,363, see Table 3),
split between an average of 59,280
positive-screen cases and 12,083
negative-screen cases. This can be
considered the maximum,
‘‘encompassing,’’ population that could
be impacted. However, we take into
consideration larger populations to
account for variations and uncertainty
in the future population.
4. Impacts of the Rule
This section is divided into three
subsections. The first (a) focuses on
impacts on asylum seekers, presented
on a per-person basis. The second (b)
discusses costs to the Federal
Government, and the third (c) discusses
other, possible impacts, including
benefits.
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a. Impacts on the Credible Fear Asylum
Population
Under the new procedure established
by this rule, asylum applicants who
have established a credible fear of
persecution or torture would not be
required to file Form I–589 with USCIS.
Individuals in this population could
accrue cost savings because of this
change. There is no filing fee for Form
I–589, and the time burden is currently
estimated at 12.0 hours per response,
including the time for reviewing
instructions and completing and
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submitting the form.110 Regarding cost
savings, DHS believes the minimum
wage is appropriate to rely on as a lower
bound, as the applicants would be new
to the U.S. labor market. The Federal
minimum wage is $7.25 per hour;
however, in this rule, we rely on the
‘‘effective’’ minimum wage of $11.80.
As The New York Times reported,
‘‘[t]wenty-nine states and the District of
Columbia have state-level minimum
hourly wages higher than the federal
[minimum wage],’’ as do many city and
county governments. This New York
Times report estimates that ‘‘the
effective minimum wage in the United
States [was] $11.80 an hour in 2019.’’ 111
Therefore, USCIS uses the ‘‘effective’’
minimum hourly wage rate of $11.80 to
estimate a lower bound. USCIS uses a
national average wage rate across
occupations of $27.07 112 to take into
consideration the variance in average
wages across States as an upper bound.
DHS accounts for worker benefits by
calculating a benefits-to-wage multiplier
using the most recent BLS report
detailing the average employer costs for
employee compensation for all civilian
workers in major occupational groups
and industries. DHS relies on a benefitsto-wage multiplier of 1.45 and,
therefore, is able to estimate the full
opportunity cost per applicant,
110 See USCIS, Form I–589, Application for
Asylum and for Withholding of Removal:
Instructions, OMB No. 1615–0067, at 14 (expires
July 31, 2022), https://www.uscis.gov/sites/default/
files/document/forms/i-589instr.pdf.
111 Ernie Tedeschi, Americans Are Seeing Highest
Minimum Wage in History (Without Federal Help),
The New York Times (Apr. 24, 2019), https://
www.nytimes.com/2019/04/24/upshot/whyamerica-may-already-have-its-highest-minimumwage.html (last visited Mar. 5, 2022). We note that,
with the wage level dated to 2019, we do not make
an inflationary adjustment because the Federal
minimum wage has not changed since then.
112 For the average wage for all occupations, the
Departments rely on BLS statistics. See BLS, May
2020 National Occupational Employment and Wage
Estimates, https://www.bls.gov/oes/2020/may/oes_
nat.htm#00-0000 (last visited Feb. 28, 2022).
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including employee wages and salaries
and the full cost of benefits such as paid
leave, insurance, retirement, and other
benefits.113 The total rate of
compensation for the effective
minimum hourly wage is $17.11 ($11.80
× benefits burden of 1.45), which is 62.8
percent higher than the Federal
minimum wage.114 The total rate of
compensation for the average wage is
$39.25 ($27.07 × benefits burden of
1.45).
For applicants who have established a
credible fear, the opportunity cost of 12
hours to file Form I–589 at the lower
and upper bound wage rates is $205.32
(12 hours × $17.11) and $471.00 (12
hours × $39.25), respectively, with a
midrange average of $338.16. In
addition, form instructions require a
passport-style photograph for each
family member associated with the
Form I–589 filing. The Departments
obtained an estimate of the number of
additional family members applicable
via data on biometrics collections for
the Form I–589. Biometrics information
is collected on every individual
associated with a Form I–589 filing, and
the tracking of collections is captured in
the USCIS Customer Profile
Management System (‘‘CPMS’’)
database. A query of this system reveals
that for the five-year period of FY 2016
through FY 2020, an average of 296,072
biometrics collections accrued for the
Form I–589 annually. Dividing this
113 The benefits-to-wage multiplier is calculated
as follows: (Total Employee Compensation per
hour)/(Wages and Salaries per hour) ($38.60 Total
Employee Compensation per hour)/($26.53 Wages
and Salaries per hour) = 1.454957 = 1.45 (rounded).
See BLS, Employer Cost for Employee
Compensation—December 2020, Table 1. Employer
Costs for Employee Compensation by Ownership
(Dec. 2020), https://www.bls.gov/news.release/
archives/ecec_03182021.pdf (last visited Feb. 28,
2022).
114 The Federal minimum wage is $7.25 hourly,
which burdened at 1.45 yields $10.51. It follows
that: (($17.11 wage¥$10.51 wage)/$10.51)) wage =
0.628, which rounded and multiplied by 100 = 62.8
percent.
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figure by the same five-year period
average of 110,937 initial filings (Table
3) yields a multiplier of 2.67
(rounded).115 Under the supposition
that each photo causes applicants to
incur a cost of $10,116 there could be
$26.70 in additional cost-savings at
either wage bound.117 The resulting cost
savings per applicant from no longer
having to file Form I–589 could range
from $232.02 to $497.70, with a
midrange of $364.86.118
Though these applicants would no
longer be required to file Form I–589,
DHS recognizes that applicants would
likely expend some time and effort to
prepare for their asylum interviews and
provide documentation for their asylum
claims under this rule as well. DHS does
not know exactly how long, on average,
individuals may spend preparing for
their credible fear interviews under the
rule, and how that amount of time and
effort would compare to the time
individuals currently spend preparing
for the credible fear interviews. If the
increased time were substantial—i.e.,
above and beyond that currently
earmarked for the asylum application
process—lower cost savings could
result.
Under the rule, asylum applicants
who established a credible fear would
be able to file for employment
authorization via the Form I–765,
Application for Employment
Authorization (‘‘EAD’’), while their
asylum applications are being
adjudicated. We cannot say, however,
whether the volume of Form I–765
EADs filed would increase or decrease
in upcoming years due to this rule.
Currently, asylum applicants can file for
an EAD under the asylum (c)(8) category
while their asylum applications are
pending. Such applications are subject
to a waiting period that commences
when their completed Form I–589s are
filed. Asylum applicants who establish
a credible fear would still be subject to
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115 Calculation:
Average Form I–589 biometrics
collections 296,072/110,937 average initial Form I–
589 filings = 2.67 (rounded). Data were obtained
from the USCIS Immigration Records and Identity
Services (‘‘IRIS’’) Directorate, via the CPMS
database (data obtained May 7, 2021).
116 The U.S. Department of State estimates an
average cost of $10 per passport photo in its
supporting statement for its Paperwork Reduction
Act submission for the Application for a U.S.
Passport, OMB #1405–0004 (DS–11) (Feb. 8, 2011),
https://www.reginfo.gov/public/do/
PRAViewDocument?ref_nbr=201102–1405–001
(last visited Feb. 28, 2022) (see question #13 of the
Supporting Statement).
117 Calculation: $10 per photo cost × 2.67 photos
per Form I–589 = $26.70.
118 Calculation: $205.32 + $26.70 = $232.02;
$338.16 + $26.70 = $364.86; $471.00 + $26.70 =
$497.70.
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the waiting period.119 Applicants would
still be able to file for their EADs under
the (c)(8) category. We analyze the
impacts regarding the EAD filing in two
steps, explaining first why filing
volumes might decline and the impacts
related to that decline, and then why
countervailing factors might mitigate
such a decline.
One result of this rule is that asylum
applications for some individuals
pursuant to this rule could be granted
asylum earlier than they would be
under current conditions. Because an
asylum approval grants employment
authorization incident to status, and
because USCIS automatically provides
an asylum granted EAD ((a)(5)) after a
grant of asylum by USCIS, some
applicants may choose not to file for an
EAD based on the pending asylum
application under the expectation that
asylum would be granted earlier than
the EAD approval. This could result in
cost savings to some applicants.
There is currently no filing fee for the
initial (c)(8) EAD Form I–765
application, and the time burden is
currently estimated at 4.75 hours, which
includes the time associated with
submitting two passport-style photos
along with the application.120 As stated
earlier, the Department of State
estimates that each passport photo costs
about $10 each. Submitting two
passport photos results in an estimated
cost of $20 per Form I–765 application.
Because the (c)(8) EAD does not include
or require, at the initial or renewal stage,
any data on employment, and since it
does not involve an associated labor
condition application, we have no
information on wages, occupations,
industries, or businesses that may
employ such workers. Hence, we
continue to rely on the wage bounds
119 On February 7, 2022, in AsylumWorks v.
Mayorkas, No. 20-cv-3815 (BAH), 2022 WL 355213,
at *12 (D.D.C. Feb. 7, 2022), the U.S. District Court
for the District of Columbia vacated two DHS
employment authorization-related rules entitled
‘‘Asylum Application, Interview, and Employment
Authorization for Applicants,’’ 85 FR 38532 (June
26, 2020), and ‘‘Removal of 30-Day Processing
Provision for Asylum Applicant-Related Form
I–765 Employment Authorization Applications,’’ 85
FR 37502, (June 22, 2020), that addressed waiting
periods. Separately, a partial preliminary injunction
was issued on September 11, 2020, in Casa de
Maryland, Inc. v. Wolf, 486 F. Supp. 3d 928, 935
(D. Md. 2020), that exempts certain individuals
from a 365-day waiting period and certain other
eligibility criteria, but retains a 180-day waiting
period. Although the duration of time required for
the waiting period varies based on application of
these rules and the related vacaturs and injunctions,
a required waiting period remains in effect
notwithstanding these rules, vacaturs, or
injunctions.
120 See USCIS, Instructions for Application for
Employment Authorization, OMB No. 1615–0040,
at 31 (expires July 31, 2022), https://www.uscis.gov/
sites/default/files/document/forms/i-765instr.pdf.
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18203
(effective minimum and national
average) developed earlier. At the wage
bounds relied upon, the opportunitycost savings are $81.27 (4.75 hours ×
$17.11 per hour), and $186.44 (4.75
hours × $39.25). When the $20 photo
cost is included, the cost savings would
be $101.27 and $206.44 per applicant,
respectively. However, some might
choose to file for an EAD even if they
hope that asylum will be granted earlier
than the EAD approval because they
want to have documentation that
reflects that they are employment
authorized.
In the discussion of the possible file
volume decline for the Form I–589,
above, we noted that applicants and
family members would continue to
submit biometrics as part of their
asylum claims, and that, as a result,
there would not be changes in costs or
cost savings germane to biometrics. For
the Form I–765(c)(8) category, USCIS
started collecting biometrics, and the
associated $85 biometrics service fee, in
October 2020.121
The submission of biometrics
involves travel to an ASC for the
biometric services appointment. In past
rulemakings, DHS estimated that the
average round-trip distance to an ASC is
50 miles, and that the average travel
time for the trip is 2.5 hours.122 The cost
of travel also includes a mileage charge
based on the estimated 50-mile round
trip at the 2021 General Services
Administration (‘‘GSA’’) rate of $0.56
per mile.123 Because an individual
would spend an average of 1 hour and
10 minutes (1.17 hours) at an ASC to
submit biometrics,124 adding the ASC
time and travel time yields 3.67 hours.
At the low- and high-wage bounds, the
opportunity costs of time are $62.79 and
$144.05.125 The travel cost is $28, which
is the per mileage reimbursement rate of
0.56 multiplied by 50-mile travel
distance. Adding the time-related and
travel costs generates a per-person
121 USCIS collects biometrics for Form I–765
(c)(8) submissions, but a preliminary injunction in
Casa de Maryland, 486 F. Supp. at 935, currently
exempts members of certain organizations from this
biometrics collection.
122 See Provisional Unlawful Presence Waivers of
Inadmissibility for Certain Immediate Relatives, 78
FR 536, 572 (Jan. 3, 2013).
123 See GSA, POV Mileage Rates (Archived),
https://www.gsa.gov/travel/plan-book/
transportation-airfare-pov-etc/privately-ownedvehicle-mileage-rates/pov-mileage-rates-archived
(last visited Feb. 28, 2022).
124 See USCIS, Instructions for Application for
Employment Authorization, OMB No. 1615–0040,
at 31 (expires July 31, 2022), https://www.uscis.gov/
sites/default/files/document/forms/i-765instr.pdf.
125 Calculations: Total time burden of 3.67 hours
× total rate of compensation for the effective wage
$17.11 = $62.79; total time burden of 3.67 hours ×
total rate of compensation for the average wage
$39.25 = $144.05.
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biometrics submission cost of $90.79, at
the low-wage bound and $172.05 at the
high-wage bound.126 Although the
biometrics collection includes the $85
service fee, fee waivers and exemptions
are granted on a case-by-case basis
(across all forms) that are immaterial to
this IFR. Accordingly, not all
individuals pay the fee. When the
opportunity costs of time for filing Form
I–765 ($101.27 and $206.44,
respectively) are added to the
opportunity costs of time and travel for
biometrics submissions ($90.79 and
172.05), the total opportunity costs of
time to file Form I–765 and submitting
biometrics are $192.07 and $378.49,
respectively. For those who pay the
biometrics service fee, the total costs are
$277.07 and $463.49, respectively, with
a midpoint of $370.28.127 These figures
represent the maximum per-person cost
savings for those who choose not to file
for an EAD.128
Having developed the cost savings for
applicants who do not file for an EAD,
we now turn to factors that could
counteract a potential decline in Form
I–765 volumes. First, applicants will
benefit from a timing change relevant to
the EAD waiting period as it relates to
the ‘‘filing date’’ of their asylum
applications that will allow an EAD to
be filed earlier than it could be
currently. USCIS allows for an EAD to
be filed under 8 CFR 208.7 and
274a.12(c)(8) when an asylum
application is pending and certain other
conditions are met. Here, an asylum
application would be pending when the
credible fear determination is served on
the individual as opposed to current
practice under which the asylum
application is pending when lodged in
immigration court. This change in
126 Calculations: Opportunity cost of time,
effective wage $62.79 + travel cost of $28 = $90.79;
Opportunity cost of time, average wage $144.05 +
travel cost of $28 = $172.05.
127 Calculations: $192.07 + biometrics services fee
of $85 = $277.07; $378.49 + biometrics services fee
of $85 = $463.49. Although we have the overall
count for biometrics for the period from October 1,
2020, through May 1, 2021, we do not know how
many biometrics service fees were collected with
these biometrics’ submissions; the fee data are
retained by the USCIS Office of the Chief Financial
Officer (‘‘OCFO’’), but the Form I–765 fee payments
are not captured by eligibility class.
128 There is a scenario that the Departments have
considered, though it is not likely to occur often.
Currently, an asylum applicant might file for an
EAD and have the EAD approved prior to the grant
of asylum. It is possible that, under this rule,
asylum may be approved more expeditiously. At
the time of the asylum grant, the individual will
automatically receive a category (a)(5) EAD based
on the grant of asylum; if the applicant did already
file for an EAD, then the filing costs associated with
the EAD would be sunk costs, since the (c)(8) EAD
does not actually provide any benefit over the (a)(5)
EAD. Because this scenario is likely to be rare, DHS
has not attempted to quantify its impact.
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timing could allow some EADs to be
approved earlier for those who file for
an EAD with a pending asylum
application. In this sense, the EAD
waiting period remains the same in
duration, but the starting point shifts to
an earlier position for asylum applicants
who will file for an initial EAD under
the (c)(8) category.
DHS would begin to consider for
parole on a case-by-case basis all
noncitizens who have been referred to
USCIS for a credible fear screening
under the broader standard adopted by
this IFR during the relatively short
period between being referred to USCIS
for a credible fear screening interview
and the issuance of a credible fear
determination. A parole grant does not
constitute employment authorization,
however, and the rule provides, in 8
CFR 235.3(b)(2)(iii) and (b)(4)(ii), that
noncitizens paroled pending credible
fear screening will not be eligible for
employment authorization based on that
grant of parole from custody. Currently
there are two Form I–765 classes, (a)(5),
‘‘Granted Asylum Sec. 208,’’ and (a)(10),
‘‘Granted Withholding of Removal/243
(H),’’ that could apply to noncitizens
whose asylum applications are
considered under the procedure
established by this IFR. In the past,
some parolees under these categories
have been able to obtain EADs sooner
than they would if they were explicitly
subject to the filing clock that applies to
a pending Form I–589.
Given the two changes discussed
above related to the EAD filings—(1) the
change in timing for when an EAD can
be filed; and (2) the broadening of the
standard under which certain
noncitizens placed in expedited
removal may be considered for parole
before receiving a credible fear
determination—some applicants may
file for an EAD, even under the
expectation that their asylum could be
granted earlier, if they expect to receive
an (a)(5) asylum granted EAD even
sooner. In this sense, the potential for
more rapid approvals of an EAD claim
may be expected to provide a net
pecuniary benefit, even considering a
more expeditious asylum claim.
Coupled with the expectation that some
individuals may seek an EAD for the
non-pecuniary benefit associated with
its documentary value, we cannot
determine if these countervailing
influences might limit, or even
completely absorb, any reductions in
EAD filing for credible fear asylum
applicants.
Regardless of whether, under the rule,
it is the more expeditious asylum grant
or EAD approval that results in
employment authorization, individuals
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Sfmt 4700
who enter the labor force earlier are able
to earn income earlier. The assessments
of possible impacts rely on the implicit
assumption that credible fear asylum
seekers who receive employment
authorization will enter and be
embedded in the U.S. labor force. This
assumption is justifiable for those
whose labor force entry was effectuated
by the EAD approval, as opposed to the
grant of asylum. We believe this
assumption is justifiable because
applicants would generally not have
expended the direct costs and
opportunity costs of applying for an
EAD if they did not expect to recoup an
economic benefit. We also take the extra
step of assuming these entrants to the
labor force are employed. It is possible
that some applicants who are eventually
denied asylum are currently able to
obtain employment authorizations—
approved while their asylum
application was pending. We do not
know what the annual or current scale
of this population is, but it is an
expected consequence of this IFR that
such individuals would not obtain
employment authorizations in the
future.
The impact is attributable to the
difference in days between when
asylum would be granted under the rule
and the current baseline. USCIS
describes this distributional impact in
more detail. Since a typical workweek is
5 days, the total day difference (‘‘D’’)
can be scaled by 0.714 (5 days/7 days)
and then multiplied by the average wage
(‘‘W’’) and the number of hours in a
typical workday (8) to obtain the
impact, as in the formula: D × 0.714 ×
W × 8. In terms of each actual workday,
the daily distributional impacts at the
wage bounds are $136.88 ($17.11 × 8
hours) and $314.00 ($39.25 × 8 hours),
respectively, on a per-person basis, with
a midrange average of $225.44.
USCIS cannot expand the per-person
per-day quantified impacts to a broader
monetized estimate. Foremost, although
Table 5 provides filing volumes for the
asylum relevant EADs, we cannot
determine how many individuals within
this population would be affected. In
addition, we cannot determine what the
average day difference would be for any
individual who could be impacted. To
quantify the day difference, the
Departments would need to
simultaneously analyze the current and
future interaction between the asylum
grant and EAD approvals. Doing so for
the current system is conceptually
possible with a significant devotion of
time and resources, but it is not possible
to conduct a similar analysis for future
cases without relying on several
assumptions that may not be accurate.
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As a result, we cannot extend the perperson cost (in terms of earnings) to an
aggregate monetized cost, even if we
knew either the population impacted or
the day-difference average because an
estimate of the costs would require both
data points. The impact on labor
earnings developed above has the
potential to include both distributional
effects (which are transfers) and indirect
benefits to employers.129 The
distributional impacts would be felt by
asylum applicants who enter the U.S.
labor force earlier than under current
regulations in the form of increased
compensation (wages and benefits). A
portion of this compensation gain might
be transferred to asylum applicants from
others who are currently in the U.S.
labor force or eligible to work lawfully.
Alternatively, employers that need
workers in the U.S. labor market may
benefit from those asylum applicants
who receive their employment
authorizations earlier as a result of the
IFR, gaining productivity and potential
profits that the asylum applicants’
earlier starts would provide. Companies
may also benefit by not incurring
opportunity costs associated with the
next-best alternative to the immediate
labor the asylum applicant would
provide, such as having to pay existing
workers to work overtime hours. To the
extent that overtime pay could be
reduced, some portion of this pay could
be transferred from the workers to the
companies.
We do not know what the next-best
alternative may be for those companies.
As a result, the Departments do not
know the portion of overall impacts of
this IFR that are transfers or benefits,
but the Departments estimate the
maximum monetized impact of this IFR
in terms of a daily, per-person basis
compensation. The extent to which the
portion of impacts would constitute
benefits or transfers is difficult to
discern and would depend on multiple
labor market factors. However, we think
it is reasonable to posit that the portion
of impacts attributable to transfers
would mainly be benefits, for the
following reason: If there are both
workers who obtain employment
authorization under this rule and other
workers who are available for a specific
position, an employer would be
expected to consider any two candidates
to be substitutable to a high degree.
129 Transfer payments are monetary payments
from one group to another that do not affect total
resources available to society. See OMB, Circular
A–4 at 14, 38 (Sept. 17, 2003), https://
www.whitehouse.gov/wp-content/uploads/legacy_
drupal_files/omb/circulars/A4/a-4.pdf (last visited
Feb. 28, 2022) (providing further discussion of
transfer payments and distributional effects).
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There is an important caveat, however.
There could be costs involved in hiring
asylum seekers that are not captured in
this discussion. As the U.S. economy
recovers from the effects of the COVID–
19 pandemic, there may be structural
changes to the general labor market and
to specific job positions that could
impact the next-best alternatives that
employers face. The Departments
cannot speculate on how such changes
in relation to the earlier labor market
entry of some asylum applicants could
mitigate the beneficial impacts for
employers.
The early possible entry into the labor
force of some positive-screened credible
fear asylum applicants is not expected
to change the composition of the labor
market, as it would affect only the
timing under which some individuals
could enter the market. The
Departments do not have reason to
believe the overall U.S. labor market
would be affected, given the relatively
small population that is expected to be
impacted. Moreover, some asylum
seekers who currently enter the labor
market with a pending asylum
application may no longer be entering
the labor market under this IFR if they
receive a negative decision sooner on
their asylum claim. Specifically, there
could be individuals who receive
positive credible fear determinations,
but whose asylum applications are
ultimately denied within 180 days of
filing. Under this rule and the resultant
shortened adjudication time frame,
these individuals who otherwise would
have been eligible to receive (c)(8) EADs
no longer will be eligible because their
asylum claims will have been
adjudicated (and thus their asylum
applications will no longer be pending)
prior to the expiration of the waiting
period required for (c)(8) filings. The
lost compensation to these individuals
could constitute a transfer to others in
the U.S. workforce. Because we cannot
predict how many people would be
impacted in such a way, we are not able
to quantify this impact.
Furthermore, there may be tax
impacts for the Government. It is
difficult to quantify income tax impacts
of earlier entry of some asylum seekers
in the labor market because individual
tax situations vary widely, but the
Departments considered the effect of
Social Security and Medicare taxes,
which have a combined tax rate of 7.65
percent (6.2 percent and 1.45 percent,
respectively), with a portion paid by the
employer and the same amount
withheld from the employee’s wages.130
130 See Internal Revenue Service, Publication 15
(Circular E), Employer’s Tax Guide (Dec. 16, 2021),
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18205
With both the employee and employer
paying their respective portions of
Medicare and Social Security taxes, the
total estimated accretion in tax transfer
payments from employees and
employers to Medicare and Social
Security is 15.3 percent.131 The
Departments will rely on this total tax
rate where applicable. The Departments
are unable to quantify other tax transfer
payments, such as for Federal income
taxes and State and local taxes. As noted
above, the Departments do not know
how many individuals with a positive
credible fear determination will be
affected, and what the average daydifference would be, and therefore the
Departments cannot make an informed
monetized estimate of the potential
impact. It accordingly follows that the
Departments cannot monetize the
potential tax impacts of the IFR.
However, the Departments can provide
partial quantitative information by
focusing on the workday earnings
presented earlier. The workday
earnings, at the wage bounds of $136.88
and $314.00, are multiplied by 0.153 to
obtain $20.94 and $48.04, respectively,
with a midpoint of $34.49. These values
represent the daily employment tax
impacts per individual. The tax impacts
per person would amount to the total
day-difference in earnings scaled by
0.714, to reflect a five-day workweek.
Conversely, to the extent that this rule
prevents a person from obtaining an
EAD, there may be losses in tax revenue.
Having developed partial (based on an
individual basis) monetized impacts of
this IFR, there are two important caveats
applicable to the population of asylum
applicants who have received a positive
credible fear determination. First, as we
detail extensively in the following
subsection, there will be resource
requirements and associated costs
needed to make this IFR operational and
effective. These changes will not occur
instantaneously and may require
months or even a year or more to fully
implement. Although existing USCIS
resources will be able to effectuate
changes for some individuals rather
quickly, others (and thus the entire
population from an average perspective)
will face delay in realizing the impacts.
These individuals thus may face a delay
in realizing benefits such as earlier
https://www.irs.gov/pub/irs-pdf/p15.pdf (last
visited Feb. 28, 2022); see also Market Watch, More
Than 44 Percent of Americans Pay No Federal
Income Tax (Sept. 16, 2018), https://
www.marketwatch.com/story/81-million-americanswont-pay-any-federal-income-taxes-this-year-hereswhy-2018-04-16 (last visited Mar. 5, 2022).
131 Calculation: (6.2 percent Social Security +
1.45 percent Medicare) × 2 employee and employer
losses = 15.3 percent total estimated tax loss to
Government.
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asylum determinations, income gains,
and possible filing cost savings. Second,
despite the possibility that some
baseline EAD filers may choose not to
file in the future, there could be
mitigating effects that would reduce the
volume decline for Form I–765(c)(8)
submissions.
In closing, we have noted that the
impacts developed in this section apply
to the population that receives a
positive credible fear determination.
Additionally, for the subset of this
population that receives a negative
asylum determination from USCIS, the
possibility of de novo review of their
claims by IJs may benefit some
applicants by affording another
opportunity for review and approval of
their asylum claims.
It is possible that the earnings impact
described could overstate the quantified
benefits directly attributable to receiving
earlier employment authorization. For
those who entered the labor market after
receiving employment authorization
and began to receive paid compensation
from an employer, counting the entire
amount received by the employer as a
benefit may result in an overestimate.
Even without working for wages, the
time spent by an individual has value.
For example, if someone performs
childcare, housework, or other activities
without paid compensation, that time
still has value. Consequently, a more
accurate estimate of the net benefits of
receiving employment authorization
under the proposed rule would attempt
to account for the value of time of the
individual before receiving employment
authorization. For example, the
individual and the economy would gain
the benefit of the worker entering the
workforce and receiving paid
compensation but would lose the value
of the worker’s time spent performing
non-paid activities. Due to the wide
variety of non-paid activities an
individual could pursue without
employment authorization, it is difficult
to estimate the value of that time. As an
example, if 50 percent of wages were a
suitable proxy of the value for this nonpaid time, the day-impacts per person
would be scaled by half accordingly.
b. Impacts to USCIS
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i. Total Quantified Estimated Costs of
Regulatory Changes
In this subsection, the Departments
discuss impacts on the Federal
Government. Where possible, cost
estimates have been quantified;
otherwise they are discussed
qualitatively. The total annual costs are
provided only for those quantified costs
that can be applied to a population.
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Costs of Staffing to USCIS
USCIS will need additional staffing to
implement the provisions presented in
this rule. The staffing requirement will
largely depend on the volume of
credible fear referrals. In addition to
asylum officers, USCIS will require
additional supervisory staff and
operational personnel commensurate
with the number of asylum officers
needed. USCIS anticipates an increased
need for higher-graded field
adjudicators and supervisors to
implement the provisions of this IFR.
Approximately 92 percent of the field
asylum officers are currently employed
at the GS–12 pay level or lower.132
Under this model, USCIS will be
assuming work normally performed by
an IJ. EOIR data indicate that the
weighted average salary was $155,089 in
FY 2021 for IJs; $71,925 for Judicial Law
Clerks (‘‘JLCs’’); $58,394 for Legal
Assistants; $132,132 for DHS Attorneys;
and $98.51 per hour for interpreters.133
Notably, entry-level IJs are required to
adjudicate a wider array of immigration
applications than asylum officers, and
their decisions, unlike those of current
USCIS asylum officers, are not subject to
100 percent supervisory review. As
such, under this IFR, USCIS asylum
officers making determinations on
statutory withholding of removal and
CAT protection cases would be
performing work at a GS–13 minimum
level, considering they will be
conducting adjudications traditionally
performed only by IJs.134 In addition,
first-line Supervisory Asylum Officers
(‘‘SAOs’’) reviewing these decisions
would be graded at a GS–14.135
Currently, not all SAOs are at a grade
GS–14. Aligning all first line SAOs to a
GS–14 ensures operational flexibility
and makes this position consistent with
the similar work processes and
functions performed by the first-line
Supervisory Refugee Officer position.
Currently, USCIS refers all
individuals who receive a positive
credible fear determination to IJs at
132 In 2021, the base salary for a GS–12 ranged
from $66,829, at step 1, up to $86,881, at step 10.
See OPM, Salary Table 2021–GS Incorporating the
1% General Schedule Increase Effective January
2021, https://www.opm.gov/policy-data-oversight/
pay-leave/salaries-wages/salary-tables/pdf/2021/
GS.pdf (last visited Mar. 1, 2022) (‘‘OPM Salary
Table’’).
133 Weighted average base salaries across position,
FY, and location are drawn from DOJ EOIR PASD
analysis. Interpreter wages are presented hourly
here because these positions are paid differently
and not always on an annual basis. In 2021, the
base salary for a GS–15 step 3 was $117,824 and
step 4 was $121,506. See OPM Salary Table.
134 In 2021, the base salary for a GS–13 step 1 was
$79,468. See OPM Salary Table.
135 In 2021, the base salary for a GS–14 step 1 was
$93,907. See OPM Salary Table.
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Fmt 4701
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EOIR for consideration of the
individuals’ asylum claims. Based on
historical EOIR data on the amount of
time required to complete a typical
hearing with a credible fear origin and
only an application for asylum, the
median duration for credible fear merit
plus master hearings from FY 2016
through FY 2020 was about 97 minutes,
or 1.6 hours. Factoring in the EOIR
weighted average salaries for the IJs,
JLCs, DHS Attorneys, and interpreters
required for EOIR to complete these
hearings, we estimate the median cost to
be $470.62 136 per hearing over the same
time frame.
USCIS analyzes a range of credible
fear cases to estimate staffing
requirement costs. At a lower bound
volume of 75,000 credible fear cases,
USCIS assumes it would receive fewer
credible fear cases compared to prior
years (apart from FY 2020, which had a
lower number of credible fear cases due
to the COVID–19 pandemic and
resulting border closures). A volume of
300,000 credible fear cases is an upper
bound, based on the assumption that
nearly all individuals apprehended will
be placed into expedited removal for
USCIS to process. As shown in Table 3,
the lowest number of credible fear cases
received for FY 2016 through FY 2019
was 79,842 in FY 2017, while the
highest was 102,204 in FY 2019. DHS
recognizes that the estimated volume of
300,000 is nearly three times the highest
annual number of credible fear cases
received, but DHS presents this as an
upper bound estimate to reflect the
uncertainty concerning an operational
limit on how many credible fear cases
could be handled by the agency in the
future. Inclusion of this unlikely upper
bound scenario is intended only to
present information concerning the
potential costs should the agency
consider an intervention at the highest
end of the range. USCIS expects
volumes to fall within the lower and
upper bounds and therefore we also
provide a primary estimate of 150,000
credible fear cases.137
136 Estimate were based on analysis provided by
EOIR on May 19, 2021, of median digital audio
recording length data from all merits and master
asylum hearings between FY 2016 and FY 2020.
The five-year average estimated cost of hearings is
based on 2,087 assumed hours per year for the IJ,
JLC, and DHS attorneys at the annual salaries
shown, plus the hourly cost per interpreter. These
annual values were multiplied by the respective
sums of the annual median lengths of master and
merits hearings for corresponding years to produce
the five-year average cost per hearing of $470.62.
137 The primary estimate of 150,000 is not equal
to the average of the lower volume of 75,000
credible fear cases and the upper volume of 300,000
credible fear cases. Rather, this primary estimate,
based on OCFO modeling, represents the number of
cases that the agency may reasonably expect. The
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USCIS has estimated the staffing
resources it will need to implement this
rule. At the three volume levels of
credible fear cases, USCIS plans to hire
between 794 and 4,647 total new
positions, with a primary estimate of
2,035 total new positions.138 The
estimated costs associated with payroll,
non-payroll, and other general
expenses—including interpreter
services, transcription services,
facilities, physical security, information
technology (‘‘IT’’) case management,
and other contract, supplies, and
equipment—are anticipated to begin in
FY 2022.
The costs of this rule are likely to
include initial costs associated with the
hiring and training of staff, and those
costs would continue in future years.
Additionally, as was explained in
Section G of the NPRM, the
Departments expect a phased approach
to implementation due to budgetary and
logistical factors. 86 FR 46922. The cost
estimates developed below focus on
three volume bands and are based on
initial data and staffing models that
captured initial implementation costs
accruing to FY 2022 and FY 2023. These
estimates therefore partially capture the
likely phasing of resourcing and costs,
but not the full phasing that could
extend into further years. The
Departments do not currently have the
appropriate data to include an
implementation of the IFR in their
estimates of quantified resource costs.
However, we do not believe a partial
implementation significantly skews the
expected costs of this rule. We offer
some additional comments concerning
this phased implementation as it relates
to costs at the conclusion of this
analysis.
The Departments recognize that initial
costs are likely to spill into future years
depending on the pace of hiring;
employee retention; obtaining and
signing contracts (for interpreters,
transcription, and facilities); and
training. For the remainder of FY 2022,
18207
DHS will finalize job descriptions, post
new positions, and begin the hiring
process to onboard some new Federal
employees, and DHS will work to
procure new contracts for interpreters,
transcription, facilities, and security
staff as its current fiscal situation
allows. In FY 2022, the implementation
costs are expected to range between
$179.8 million and $952.4 million with
a primary cost estimate of $438.2
million, assuming all staff is hired and
corresponding equipment needs are
fulfilled in the fiscal year. DHS
recognizes that, operationally, it may
take more time to attain the necessary
staffing and equipment. However, we
are not able to reliably predict those
timelines due to the uncertain nature of
the recruitment and onboarding
processes. Any delay in hiring would
reduce the first-year costs of
implementation, as explained further
below. The itemized planned resources
are presented in Table 7.
TABLE 7—ESTIMATED USCIS FY 2022 FUNDING REQUIREMENTS BY VOLUME OF CREDIBLE FEAR REFERRALS
[$ in thousands]
75k cases
150k cases
300k cases
(A) Staffing ...................................................................................................................................
Payroll * .................................................................................................................................
Non-Payroll ...........................................................................................................................
(B) General Expenses .................................................................................................................
Interpreter Services ..............................................................................................................
Transcription Services ..........................................................................................................
Facilities ................................................................................................................................
Physical Security ..................................................................................................................
IT Case Management ...........................................................................................................
Other Contract/Supplies/Equipment .....................................................................................
$140,507
113,602
26,905
39,313
6,615
9,366
6,635
623
12,500
3,574
$355,175
285,983
69,192
83,025
19,136
26,697
17,606
1,654
12,500
5,432
$806,697
648,257
158,440
145,682
44,179
37,362
40,865
3,839
12,500
6,937
Total ......................................................................................................................................
179,820
438,200
952,379
Source: USCIS Analysis from RAIO and USCIS OCFO, May 19, 2021.
In FY 2023, USCIS estimates costs
between $164.7 million and $907.4
million, with a primary estimate of
$413.6 million, as shown in Table 8.
The reductions as compared to FY 2022
are mostly attributable to non-recurring,
one-time costs for new staff and
upgrades to IT case management
systems, although a decline in costs
pertaining to other contracts, supplies,
and equipment is also expected. The
largest expected cost decrease is for IT
case management, which is estimated to
decline from $12.5 million in FY 2022
down to $4.375 million in FY 2023.
Meanwhile, costs for interpreter and
transcription services, facilities, and
physical security are expected to rise in
FY 2023 because of resource cost
increases. For FY 2024 through FY 2031
of implementation, DHS expects
resource costs to stabilize.
TABLE 8—ESTIMATED USCIS FY 2023 FUNDING REQUIREMENTS BY VOLUME OF CREDIBLE FEAR REFERRALS
[$ in thousands]
75k cases
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(A) Staffing ...................................................................................................................................
Payroll* .................................................................................................................................
OCFO volume levels were developed as a guide for
several possible ranges that could be realized in the
future, taking into account variations in the
populations. The actual volume levels could be
above or below these levels.
138 The primary estimate of 2,035 total new
positions is not equal to the average of the lower-
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794 and upper-bound 4,647 estimates. Rather, this
primary estimate, based on a staffing allocation
model, represents the number of staff in a mix of
occupations at a mix of grade levels that the agency
may need to hire to handle the volume of credible
fear cases. The staffing is commensurate with OCFO
model volume levels, which were developed as a
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Fmt 4701
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$133,427
122,753
150k cases
$337,047
309,758
300k cases
$766,159
703,852
guide for several possible ranges that could be
realized in the future, taking into account variations
in the populations. Actual volume levels and hence
actual staffing levels could be above or below these
levels.
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TABLE 8—ESTIMATED USCIS FY 2023 FUNDING REQUIREMENTS BY VOLUME OF CREDIBLE FEAR REFERRALS—
Continued
[$ in thousands]
75k cases
150k cases
300k cases
Non-Payroll ...........................................................................................................................
(B) General Expenses .................................................................................................................
Interpreter Services ..............................................................................................................
Transcription Services ..........................................................................................................
Facilities ................................................................................................................................
Physical Security ..................................................................................................................
IT Case Management ...........................................................................................................
Other Contract/Supplies/Equipment .....................................................................................
10,674
31,267
6,813
9,647
6,834
642
4,375
2,956
27,289
76,554
19,710
27,498
18,134
1,704
4,375
5,133
62,307
141,249
45,504
38,483
42,091
3,954
4,375
6,842
Total ......................................................................................................................................
164,694
413,601
907,408
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Source: USCIS Analysis from RAIO and OCFO, May 19, 2021.
To estimate the costs for each category
itemized in Tables 7 and 8, USCIS
considered the inputs for each. USCIS
expects to hire most new staff at the GS–
13, step 1 level, on average, and most of
those hired will serve as asylum
officers. As stated, these officers will be
making determinations on statutory
withholding of removal and
withholding and deferral of removal
under the CAT, so their pay will be
higher than the current asylum officer
pay, which is at a GS–12 level.
Additionally, USCIS assumes step 1
because these employees are expected to
be new to the position. See 5 U.S.C.
5333 (providing that new appointments
generally ‘‘shall be made at the
minimum rate of the appropriate
grade’’). Payroll costs also include
Government contributions to non-pay
benefits, such as healthcare and
retirement. Although payroll is the
greatest estimated cost to hiring staff,
non-payroll costs include training,
equipping, and setting staff up with
resources such as laptops, cell phones,
and office supplies. For example,
asylum officers have been required to
attend and successfully complete a
multi-week residential training at a
Federal Law Enforcement Training
Center (‘‘FLETC’’) as a condition of their
continued employment. The estimated
cost per student (including FLETC
enrollment costs, travel, etc.) was
approximately $7,000. However, USCIS
is currently engaging a virtual training
that is approximately $5,000 per
student. Although the training is
expected to shift back to in-person
training in the future, we currently do
not have a projected date for this shift.
To fully furnish and equip new
employees, USCIS estimates a cost of
$3,319 per asylum employee. Costs for
new equipment would be largely
commensurate with the increase in
staffing levels.
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In addition to costs associated with
hiring new staff, DHS anticipates that it
will need to both increase funding on
existing contracts and procure new
ones. As a result of this IFR, the need
for interpretation services will increase
as the number of asylum interviews
USCIS performs rises. Current
interpreter contracts cannot absorb this
expected increase. Using current
contracts, USCIS applied the current
cost model to the estimated increase in
case volumes in order to estimate costs.
The facilities and physical security
estimates were similarly based on
current cost models that were expanded
to account for additional employees.
Additional contract support will also be
needed for transcription services to
create a written record of the asylum
hearing because such staff are not
currently employed by USCIS. To create
transcription service estimates, USCIS
applied EOIR’s current cost model to
USCIS’s estimated increase in case
volumes. DHS also anticipates costs
associated with general expenses
associated with miscellaneous contract,
supplies, and equipment commensurate
with the increase in staff. The timing of
these costs will depend on the hiring
timeline but are expected to commence
in the first year. DHS recognizes that if
it takes more than one year to hire and
equip asylum employees, costs may
instead be experienced in later years.
Costs of IT Upgrades for USCIS
DHS is planning upgrades to internal
management systems and databases as a
requirement to implement this IFR. The
estimated cost of these upgrades in FY
2022 is a one-time cost of $12.5 million
that will impact virtually all processing
and record-keeping systems at USCIS.
This cost embodies funds for
enhancements and refurbishment to the
USCIS global case management system
that would support features such as
ensuring transition of positive credible
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Sfmt 4700
fear screening cases to the hearing
process currently provided for
affirmative asylum cases; support for
withholding of removal and CAT
adjudication features; non-detained
scheduling enhancements; and
capabilities to accept and provide
review for electronic documents. The
one-time cost also includes funds
earmarked for teams that support
integrations with other internal and
external-facing systems, such as recordkeeping; identity management and
matching; reporting and analytics;
applicant-facing interfaces; and other
key USCIS systems, as well as external
systems at ICE, CBP, and DOJ.139
Included in these $12.5 million in
costs are the costs to pay staff to make
these upgrades. DHS estimates between
30 and 40 individuals, with a little over
half being contract personnel and the
rest being Federal employees, would be
involved (either part- or full-time) in the
implementation of these enhancements
through FY 2022. The Federal personnel
would mainly comprise GS–14 and GS–
15 level personnel and supervisory and
management staff.
IT costs are expected to decline in FY
2023 and remain flat into the future at
$4.375 million. This amount accounts
for ongoing operations and maintenance
costs. New features or upgrades are not
expected at this time, but if they were
to be needed in the future, those
enhancements would result in
additional costs not included here.
At present, DHS does not envision its
planned IT upgrades requiring new
facilities or additional structures.
139 Although this plan tracks the FY 2022 time
frame, variations in the pace of Federal and
contractor hiring and retention during the
performance period, unforeseen legal or other
policy challenges to any electronic process, and the
ability of relevant offices to truly operationalize
minimal functionality given their own staffing
constraints to handle manually any additional
process automations, could delay some
implementation into FY 2023.
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Importantly, DHS’s upgrades are
expected to coincide with the first
electronic processing of the Form I–589.
Since this will be a significant change
for processing asylum applications,
unexpected errors or system changes
could have impacts on this project as
well. Completion of the upgrades is also
dependent on the availability of ICE,
CBP, and DOJ systems to integrate with
USCIS systems to provide for
streamlined implementation. However,
because this plan was developed
outside the scope of this rule, we do not
attribute costs to it.
As described earlier in this analysis,
we expect no net change regarding
biometrics collection germane to asylum
applications for individuals with a
positive credible fear determination. We
also detailed how factors concomitant to
more expeditious EAD approvals make
it impossible to estimate the magnitude
or even direction of the net change in
Form I–765 filing volumes (related to
asylum or withholding of removal), and,
hence, commensurate biometrics
collections (and fee payments).
Given the parameters of this rule,
however, any net change in biometrics
would not impose new costs on the
Federal Government. The maximum
monthly volume of biometrics
submissions allowed by the current ASC
contract is 1,633,968 and the maximum
annual volume is 19,607,616.140 The
average number of individuals that
submitted biometrics annually across all
USCIS forms for the period FY 2016
through FY 2020 was 3,911,857.141
Given that the average positive-screened
credible fear population is 59,280 (Table
3), which is 1.52 percent of the
biometrics volume, a volume change
would not encroach on the ASC contract
bounds.
To better illustrate the limited impact
of biometrics collection on USCIS, one
scenario that we do account for relates
to costs for a particular USCIS–ASC
district. The DHS–ASC contract was
designed to be flexible to reflect
variations in benefit request volumes.
18209
The pricing mechanism within this
contract embodies such flexibility.
Specifically, the ASC contract is
aggregated by USCIS district, and each
district has five volume bands with its
pricing mechanism. The incumbent
pricing strategy takes advantage of
economies of scale because larger
biometrics processing volumes have
smaller corresponding biometrics
processing prices.142 For example, Table
9 provides an example of the pricing
mechanism for a particular USCIS
district. This district incurs a monthly
fixed cost of $25,477.79, which will
cover all biometrics submissions under
a volume of 8,564. However, the price
per biometrics submission decreases
from an average cost of $6.66 for
volumes between a range of 8,565 and
20,524 to an average of $5.19 once the
total monthly volume exceeds 63,503. In
other words, the average cost decreases
when the biometrics submissions
volume increases (jumps to a higher
volume band).
TABLE 9—EXAMPLE OF PRICING MECHANISM FOR A USCIS DISTRICT PROCESSING BIOMETRICS APPOINTMENTS, FY 2021
District X
Volume band
Baseline: Fixed price per month .......................................................................
Fixed price per person processed ....................................................................
Fixed price per person processed ....................................................................
Fixed price per person processed ....................................................................
Fixed price per person processed ....................................................................
AA
AB
AC
AD
AE
Minimum
volume
................
................
................
................
................
Maximum
volume
0
8,565
20,525
31,753
63,505
8,564
20,524
31,752
63,504
95,256
Costs
$25,477.79
6.66
5.94
5.53
5.19
Source: USCIS, IRIS Directorate, received May 10, 2021.
At the district level, since there are
small marginal changes to costs in terms
of volumes, it would take a substantial
change in volumes for a particular
district to experience a significant
change in costs for that district. If
biometrics volumes increase on net,
there could be small marginal, and
hence, average, cost declines; in
contrast, if volumes decline, some of
those marginal costs might not be
realized.
Having developed the costs for USCIS
to implement the rule, this section
brings the total costs together as annual
inputs that are discounted over a 10year horizon. At the three population
bounds, the inputs are captured in Table
10. The FY 2022 and FY 2023 costs are
from Tables 7 and 8. For FY 2024
through FY 2031, human resources cost
increases. As stated earlier, USCIS
expects positions to be filled at step 1
for each GS level, so in years where
employees remain at the same step for
more than one year, these estimates
account only for human resource cost
increases (FYs 2026, 2028 and 2030).
The general non-IT cost increases
account for expected contract pricing
increases. Finally, IT costs are expected
to remain flat at $4.375 million into the
future, which accounts for ongoing
operations and maintenance costs.
TABLE 10—MONETIZED COSTS OF THE INTERIM FINAL RULE TO USCIS
[In undiscounted 2020 dollars]
Time Period: FYs 2022 through 2031
FY
Human resources
General (non-IT)
cost
IT expenditure
Annual total
lotter on DSK11XQN23PROD with RULES2
10A. Low Population Bound (75k Annual Cases)
2022 .................................................................................
140 Data and information were provided by the
USCIS IRIS Directorate. The average annual
biometrics volumes were obtained through the
CPMS database. The cost of the contract reflects the
most recent contract update, dated June 18, 2020.
VerDate Sep<11>2014
17:37 Mar 28, 2022
Jkt 256001
$140,507,000
$26,813,000
141 Data and information were provided by USCIS
IRIS Directorate, utilizing the CPMS database.
142 ‘‘Economies of scale’’ refers to a scenario
where a greater quantity of output produced (in this
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Frm 00133
Fmt 4701
Sfmt 4700
$12,500,000
$179,820,000
case, more biometric service appointments) results
in a lower per-unit fixed cost or per-unit variable
cost to produce that output.
E:\FR\FM\29MRR2.SGM
29MRR2
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Federal Register / Vol. 87, No. 60 / Tuesday, March 29, 2022 / Rules and Regulations
TABLE 10—MONETIZED COSTS OF THE INTERIM FINAL RULE TO USCIS—Continued
[In undiscounted 2020 dollars]
Time Period: FYs 2022 through 2031
FY
2023
2024
2025
2026
2027
2028
2029
2030
2031
Human resources
General (non-IT)
cost
IT expenditure
Annual total
.................................................................................
.................................................................................
.................................................................................
.................................................................................
.................................................................................
.................................................................................
.................................................................................
.................................................................................
.................................................................................
133,427,000
137,429,810
141,552,704
142,968,231
147,257,278
148,729,851
153,191,747
154,723,664
159,365,374
26,892,000
27,698,760
28,529,723
29,385,614
30,267,183
31,175,198
32,110,454
33,073,768
34,065,981
4,375,000
4,375,000
4,375,000
4,375,000