Comment Submitted by Access Living

As a social service provider for the Illinois statewide Comprehensive Class Member Transition Program, I specifically assist individuals with various physical and psychiatric disabilities transition out of long-term care facilities into independent or community living setting after they have rehabilitated and adapted to their new disabilities and/or medical conditions. Many of our clients we work with come with various immigration levels and issues to which we often strive to help resolve as timely as possible so our clients are able to have full access to social and disability-related services that can significantly improve their overall health, safety and independence, which includes having access to quality medical care, home and community-based services, employment services and education. For our clients with cognitive and psychiatric impairments, we aim to assist them in pursuing the citizenship route so they no longer have to worry about keeping up with their immigration status and remember to renew their LPR cards every 10 years. For many of our clients, the immigration process is often an anxiety-provoking, exhausting and confusing process which significantly derail their medical progress and reignite former and new mental symptoms, such as panic attacks. Hence, we have discovered, when we assist clients on their journey towards US citizenship, it creates another level of safety, security and longevity, as well as significant improvement in their physical and mental wellness to the point that enables and motivates them to become positive contributors of society (whether through the American workforce or civic engagement). Overall, the citizenship process has not been quite an easy path for many of our clients with cognitive, intellectual and psychiatric disabilities, given the process oftne requires them to process complex directions and recall detailed personal information. For majority of these clients, our care teams often have to resort to investigate the accuracy and validity of the information, (that clients are able to recall) by requesting information through various state and federal agencies, including the Social Security Administration, Department of Human Services and USCIS themselves. It is important to note that majority of our immigrant clients previously experience chronic homelessness or extensive socioeconomic instability, as well as chronic health challenges, that has led to their hospitalizations and transfer to long-term care facilities (i.e. nursing homes and SMHFs). At one point or another, our immigrant clients often lose or misplace, more times than not, one or all of their personal documents, including identification and green cards, which often delays the US citizenship process. Despite having various cognitive and psychiatric diagnoses, our immigrant clients often do not have access to adequate medical care or competent medical providers while residing in these facilities. Many of these in-house providers have not been able to fully and accurately complete the N-648 medical exemption form due to poor medical and cultural training. Our immigrant clients experience additional barriers when attempting to access external medical or psychiatric providers (outside of the facility). These barriers often include facility policies and restrictions to access outside providers, poor health insurance and other health-related challenges. As a result, our clients often have to wait to be transition out of the facility or be transferred to another facility in order to access these services, without constantly encountering unnecessary restrictions and barriers. It is critical for USCIS and the Department of Homeland Security strives to improve and maintain a smooth, streamlined and compassionate process for our immigrant clients with disabilities who, a large percent of them, do not have any family or social supports (other than our state services). We strongly urge DHS and USCIS to reconsider current and any future policy changes impacting the N-648 application process that may further exacerbate an already difficult and complicated process for our clients living with various disabilities and socioeconomic challenges.