**SUPPORTING STATEMENT**

**Document Verification Request and Supplement**

**(Form G-845 and G-845 Supplement)**

**OMB No. 1615-0101**

**A. Justification.**

1.  Section 121 of Public Law 99-603 (Immigration Reform and Control
    Act), authorized the verification of immigration status of aliens
    applying for benefits under certain programs. The entitlement
    benefits include Food stamps, Unemployment Insurance, Medicaid, Aid
    to Families with Dependent Children, Student Loans, Work Study, and
    Pell Grant Funds.

2.  In the verification process, as an alien makes application for
    entitlement benefits, the benefit-granting agency checks the
    validity of the document presented and the immigration status of the
    alien applicant by accessing the automated Alien Status Verification
    Index (ASVI). If the information provided by the ASVI correlates
    and/or no material discrepancies are apparent, the verification
    process is complete. If a discrepancy is revealed or if the ASVI
    returns a response to institute additional verification, the Form
    G-845 is completed by the benefit-granting agency. It is then
    forwarded to an U.S. Citizenship and Immigration Services (USCIS)
    for official verification and processed by an immigration status
    verifier and returned to the benefit-granting agency with an
    eligibility statement.

> Agencies that do not participate in the automated Systematic Alien
> Verification for Entitlements (SAVE) system may query the USCIS by
> filing Form G-845S with copies of immigration documents. USCIS
> responds by completing the appropriate boxes and returning the form to
> the requesting entitlement worker. This form was developed to
> facilitate communication between benefit-granting agencies and USCIS
> immigration status verifiers in light of welfare reform.

3.  The use of this form provides the most efficient means for
    collecting and processing the required data. In this case the U.S.
    Citizenship and Immigration Services does not employ the use of
    information technology in collecting and processing information.
    Currently, the USCIS does not have the automated capability in place
    to accept electronic submission of this form. However, this form has
    been designated for e-filing as part of the Business Transformation
    project.

4.  A review of the USCIS Forms Inventory Report revealed no duplication
    of efforts. There is no similar information currently available that
    can be used for this purpose.

5.  This collection of information does not have an impact on small
    businesses or other small entities.

6.  The use of this information collection provides several benefits to
    both the applicant for entitlements and the USCIS. This form allows
    the USCIS to quickly and uniformly respond to benefit-granting
    agencies nationwide with a document that can be used as a record of
    the transaction. The costly and often-criticized personal interview
    process can be alleviated. Illegal or un-entitled aliens, even those
    utilizing counterfeit documentation, will not be granted benefits.
    Additionally, USCIS is provided another check for updating its
    database.

7.  There are no special circumstances applicable to this information
    collection.

8.  USCIS will address any comments in it's second submission..

9.  The USCIS does not provide payment or gifts to respondents in
    exchange for a benefit sought.

10. There is no assurance of confidentiality.

11. There are no questions of a sensitive nature.

12. [Annual Reporting Burden]{.underline}:

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a.  Number of Respondents 500,000

b.  Number of Responses per Respondent 1

c.  Total Annual Responses 500,000

d.  Hours per Response .083

e.  Total Annual Reporting Burden 41,500

The collection of information is estimated to average 5 minutes per
response, including the time for reviewing instructions, searching
existing data sources, gathering and maintaining the data needed, and
completing and reviewing the information collection.

**Total Annual Reporting Burden**

> **Total annual reporting burden hours is 41,500.** This figure was
> derived by multiplying the number of respondents (500,000) x frequency
> of response (1) x 5 minutes per response (.083).

13. There are no capital or start-up costs associated with this
    information collection. Any cost burdens to respondents as a result
    of this information collection are identified in Item 14. *There is
    no fee charge associated with this information collection.*

14. [Annualized Cost Analysis]{.underline}:

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a.  Printing Cost \$ 45,000

b.  Collection and Processing Cost 20,000,000

c.  Total Cost to Program 20,045,000

d.  Fee Charge 0

e.  Total Cost to Government 20,045,000

##### Government Cost 

> **The estimated cost to the Government is** **\$20,045,000**. This
> figure is calculated by using the estimated number of respondents
> 500,000 x 1 hour (USCIS time required to collect and process
> information) x \$40 (suggested average hourly rate for clerical,
> officer, and supervisory time with benefits). In addition, this figure
> includes the estimated overhead cost for printing, stocking, and
> distributing the form which is \$45,000.

## Public Cost

> **The estimated annual public cost is** **\$415,000**. This is based n
> the number of respondents 500,000 x 5 Minutes (.083) per response x
> \$10 (Average hourly rate).

15. There has been no increase or decrease in the burden hours or costs
    associated with this information collection.

16. USCIS does not intend to employ the use of statistics or the
    publication thereof for this information collection.

17. USCIS will display the expiration date for this information
    collection.

18. The USCIS does not request an exception to the certification of this
    information collection.

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B.  **Collection of Information Employing Statistical Methods.**

> Not Applicable.

#### C. Certification and Signature.

#### 

#### PAPERWORK CERTIFICATION

> In submitting this request for OMB approval, I certify that the
> requirements of the Privacy Act and OMB directives have been complied
> with including paperwork regulations, statistical standards or
> directives, and any other information policy directives promulgated
> under 5 CFR 1320.

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

**Stephen Tarragon Date**

[Deputy Chief]{.underline},

[Regulatory Management Division]{.underline},

[U.S. Citizenship and Immigration Services]{.underline},

[Department of Homeland Security]{.underline}.