Comment Submitted by Makita Thatcher

Re: DHS Docket No. USCIS-2023-0011 OMB Control No. 1615-0160 E-Verify+ Information Collection My comment addresses the E-Verify+ information collection and the systems used to collect, verify, preserve, and act upon identity and employment-authorization information. E-Verify+ may serve compliance purposes, but expanded identity and work-authorization infrastructure requires safeguards. When a federal system affects a person's ability to work, the process must include meaningful notice, correction procedures, privacy limits, auditability, and records sufficient to show what happened. A verification result should not become an employment consequence before the affected person can see, understand, and correct the record. 1. Meaningful notice. USCIS should ensure that workers receive clear, plain-language notice whenever E-Verify+ produces a mismatch, tentative nonconfirmation, final nonconfirmation, unresolved result, case closure, identity issue, document issue, or work-authorization issue. The notice should identify the specific issue, the record source, the deadline to respond, the steps required to correct or contest the result, and what the employer may and may not do while the process is pending. 2. Correction before consequence. USCIS should provide meaningful correction procedures before an E-Verify+ result becomes a final employment consequence. The process should address errors involving name changes, transliteration, date of birth, document numbers, Social Security records, DHS records, status records, renewed or expired documents, identity verification, duplicate cases, and data-entry mistakes. A person should not lose work because the correction pathway was unclear, inaccessible, or split across multiple systems. 3. Preservation of the record. USCIS should preserve records sufficient to reconstruct each E-Verify+ case, including information entered by the worker or employer, system responses, timestamps, notices generated, referrals, worker responses, employer actions, case closures, final determinations, corrections, and any reopening or later agency action. If an E-Verify+ result later affects employment, immigration eligibility, benefits, enforcement, or adjudication, the affected person and reviewing authorities should be able to trace the record. 4. Employer obligations. USCIS should make employer obligations explicit in collection instruments, training materials, memoranda of understanding, and user screens. Employers should be clearly instructed that they may not terminate, suspend, reduce hours, delay training, withhold pay, or otherwise penalize a worker solely because of a tentative, unresolved, or contested E-Verify+ result. Employers should preserve proof that notices were provided and workers had a meaningful opportunity to correct or contest the result. 5. Privacy and limits on secondary use. USCIS should clearly describe what information is collected, how long it is retained, who may access it, whether it may be shared with other agencies, and what limits apply to secondary use. Information collected for employment verification should not become an open-ended data pipeline for unrelated enforcement, benefits, or adjudicatory uses without clear legal authority, notice, record preservation, and review. 6. Language access and digital access. E-Verify+ notices, instructions, and correction pathways should be available in languages commonly used by affected workers. The system should also account for workers with limited digital access, limited English proficiency, disabilities, unstable housing, limited documentation access, or difficulty navigating multiple agencies. A verification system is not meaningful if the correction process is practically unavailable. 7. Burden and cost. USCIS should consider the burden on workers, not only employers or system users. Workers may need to read notices, contact agencies, gather identity or immigration records, travel, take time away from work, obtain assistance, resolve records in multiple systems, or follow up repeatedly. The burden estimate should include the real-world time and cost imposed on workers who must correct or contest E-Verify+ results. 8. Aggregate auditability. USCIS should maintain aggregate data on mismatches, tentative nonconfirmations, final nonconfirmations, contested cases, corrections, case closures, reopened cases, employer compliance findings, known error patterns, language-access needs, average resolution times, and outcomes after correction. This data should be available for oversight so that E-Verify+ can be evaluated for accuracy, fairness, privacy, and burden. Where federal verification systems affect a person's ability to work, notice must be specific, correction must be meaningful, privacy limits must be clear, employer duties must be enforceable, and the record must be preserved. Respectfully submitted, Makita Thatcher Georgia