Agency Information Collection Activities; Proposals, Submissions, and Approvals: Medical Examination for Visa or Immigration Benefit

The commenter opposes the requirement in Form DS-3026 to photograph all tattoos, scars, and markings, arguing that these are not medical conditions and do not belong within the scope of a physician's clinical role. They suggest that if such information is needed for administrative or security purposes, it should be collected by the appropriate authorities rather than medical professionals.

The commenter argues against the inclusion of a Metabolic Lipid Panel in the DS-3026 form, stating that it assesses long-term individual cardiovascular risk rather than communicable diseases that pose a public health risk. They contend that the requirement lacks medical necessity and proportionality, as it does not serve the stated objective of protecting public health.

The commenter argues against the requirement for routine HSV-1 and HSV-2 serologic testing for asymptomatic individuals, citing a lack of clinical utility and public health benefit. They request a clear scientific and legal justification for the requirement, noting that it contradicts major medical organization guidelines and may violate principles of necessity and data minimization.

The commenter opposes the requirement in Form DS-3026 to collect records of previous elective gender-affirming surgeries. They argue that such information lacks medical relevance to public health, violates medical ethics regarding privacy and data minimization, and should not be required unless there are specific current medical complications.

The commenter opposes the proposed language requiring the disclosure of previous surgeries, specifically noting that it is overly broad and singles out gender-affirming surgery. They argue that the collection of such sensitive health data lacks medical necessity and violates privacy principles regarding data minimization and proportionality.

A USCIS-designated civil surgeon and physician opposes the proposed information collection because it expands data-sharing to include immigration enforcement, which they argue creates a surveillance mechanism that chills patient participation and undermines public health. The commenter also argues that the notice significantly underestimates the time burden on physicians and requests more specific privacy protections and revised burden estimates.