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Greg Siskind on Immigration Law and Policy

BAD CUSTOMER SERVICE 101: USCIS ENDS ACCEPTANCE OF PREPAID MAILERS

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Every year at the annual meeting of the American Immigration Lawyers Association the head of USCIS (and before that INS) gets up and tells about the state of the agency. And every year we hear about how USCIS really understands the "service" in its name and is working to improve how it treats customers. Most of the immigration lawyers in the audience who have been around a few years smile and think to themselves - "yeah right." But we try and hope for the bliss of an agency that at least cares about its customers even if it is not perfect.



Will Emilio Gonzalez even bother to go through the motions at the next AILA annual meeting? Just look at some of the recent developments at the agency:



1. Massive fee increases multiple times larger than inflation and with no promise of faster processing times or better training of adjudicators



2. The end of premium processing of I-140 petitions with no promise to bring the service back after August 17th when the July Visa Bulletin cases return



3. Ending e-filing for some types of applications with virtually no expansion of the process since it was rolled out several years ago



4. The removal of a somewhat useful web site and replacing it with a disaster of a home page with no clearance from the head of the agency and with no input from the public.



5. The complete disregard for virtually all suggestions from the USCIS Ombudsman year in, year out.



6. The total lack of any sense of decency in the handling of the Visa Bulletin mess and only fixing the problem with the threat of congressional hearings, multiple lawsuits and a media responding to public outrage.



7. Atrocious adjudications where service centers completely reverse years of accepted policy with no warning to the public and which are often completely unsupported by the law. Okay, that one is not really so recent. 



Today a change was announced again that may not sound like much (and it really is not as serious perhaps as some of the items above), but which is completely symptomatic of how terrible USCIS' customer service mission has faltered.



Until now, one could submit a pre-paid overnight mail receipt for a service like Fedex or the US Post Office so that when a case is approved, the approval notice is sent to the recipient via overnight mail at the applicant's expense. A simple system really.



Sometimes one gets the impression changes like this are just meant to be spiteful. How can USCIS seriously justify increasing filing fees an average of 66% and then say it can't cope with the extra minute or so needed to handle a pre-paid mailer? USCIS says it should not have to cope with dealing with account numbers on the pre-paid mailers that turn out to be invalid. Would that even be a problem if the agency moved in to the 21st century and allowed people to pay for services via credit card thus allowing USCIS to charge the cost back plus a penalty if the number was invalid? And is this really a serious enough problem that it justifies cutting a service across the board? Is this a case of the perfect being the enemy of the good where a few odd cases of bad account numbers justify a complete dumping of a customer service function?



USCIS should be offering this kind of service on its own anyway without customers having to provide their own pre-paid mailers. Customers should simply have the option of including an expedited mail request and pay an extra fee and have this service available. 



When the INS was split up in 2003, a primary justification was to separate the enforcement and the service functions of the agency so that each new agency could do a better job. Enforcement certainly seems to be on the upswing. But the same cannot be said for USCIS when it comes to providing good customer service. Very little has improved in the last four years despite massive increases in funding and staffing and despite the supposed removal of the enforcement personnel from the hierarchy. We should be hearing regular announcements of new customer service initiatives rather than announcements like the one we've seen today. How about spending some of those new fee dollars on your customers?

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Comments

  1. jack's Avatar
    Well... There's no competition, so no incentive to improve. That's the problem with government agencies as opposed to businesses.
  2. jack's Avatar
    Also, I have the feeling that all these people who are allowed to file now until Aug 17 are going to wait in huge backlogs. My lawyer gave me estimated wait times of 4-5 years for EB-3 India and China and up to 3 years for EB-2 India, China and EB-3 World. Also it seems like there are going to be up to 3-4 month waits just to get an I-485 receipt.

    That's really not good. If some Jul 2 filers don't get a receipt by Aug 17, and later it turns out the application was rejected and returned (e.g. delayed in the mail, etc.), I see more lawsuits coming.
  3. USC's Avatar
    Jack:

    Well, INS does have the potential to out do itself. The State Department had this to say about INS' two week visa party:

    "The sudden backlog reduction efforts by Citizenship and Immigration Services Offices during the past month have resulted in the use of almost 60,000 Employment numbers. As a result of this unexpected action......"

    Perhaps, lightening will strick twice and another heroic effort will be made to get you your receipt in short order. But then again, maybe not.
  4. KC's Avatar
    Excellent summary Greg. Thanks.

    You wrote "Sometimes one gets the impression changes like this are just meant to be spiteful"

    I would revise this satement to " these are done because of the spiteful anti-immigrant hostility of USCIS". Feel free to delete vague terminology like impressions, "meant to be" etc!!
  5. garry's Avatar
    Excellent summary, thanks Greg.

    Please add another item to the list: Atlanta PERM processing center, which is turning into a backlog center. Labor certification cases take more than 4 months to get approved, while the California center approves cases in 1-2 days!! There will be at least few thousand cases waiting in Atlanta that will end up being not able to file 485 before August 17.
  6. Greg Siskind's Avatar
    Thanks Garry. For this post I'm focusing on USCIS. There's plenty I'll have say about the DOL soon including what you note in your comment.
  7. bobzibub's Avatar
    It is true that there is no structural incentives for USCIS to improve.
    In England they have quangos (QUAsi Non-Governmental Organization) that reports on things like the London Underground, etc. And their reports are posted in the Tube system. Perhaps it would be good to set up an independent one to report on USCIS quarterly or something. Or at least a "watchdog". We have data from tracckit etc. But it is important to balance criticism with proposals for improvement.

    Being a Canuck with some government experience, I've often seen just regular government mismanagement, so I've been "understanding" (while not appreciative) of this type of behaviour. What I often say to my American friends is : what happens to people living in the US from the Middle East, who is used to corrupt, arbitrary (not just bumbling) governments living in the US? For them, would it not be tempting to think that they are being messed with because of who they are? Foreigners living in the US have weaker social ties to America and stronger bureaucratic ties to USCIS. It is a potent recipe for alienation and it is extremely important that Americans address these issues. Today, it is never good public policy to have a groups of people believing that they are suffering from schadenfreude.

    It is also unfortunate that there appears to be a general morass or funk in the US right now, and not just our pressing issues are being avoided. So we have to compete for political capital.
  8. chicago60607's Avatar
    Greg,

    I think good customer service is too big a task for USCIS. These guys cannot even have a properly setup website, which is a customers first point of contact.

    try visiting http://uscis.gov instead of http://www.uscis.gov, you will see what I am talking about.
  9. Samla's Avatar
    The notion of the USCIS focusing on customer service is a joke. All one has to do is look at their wonderful website where they announce they are "Protecting America". Sounds like enforcement to me. We get a split up of the INS, and get the same poor service and treatment as before, only with new agency patches.
  10. Namgyal 's Avatar
    I am right now on the call for 30 minutes without being connected to the customer service representative. I have been taking day OOF from work to call USCIS. How bad is that!!!!

    Every time I call to request information, they asked me to wait 45 days and after that I call again to hear the same thing again.

    I am totally frustrated with anything to do with USCIS
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