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Federal Register / Vol. 86, No. 159 / Friday, August 20, 2021 / Proposed Rules Costs to Information Technology Typology to USCIS
DHS is planning upgrades to internal management systems and databases as a requirement to implement this proposed rule. The estimated cost of these upgrades in FY 2022 is a one-time cost of $12.5 million that will impact virtually all processing and recordkeeping systems at USCIS. The cost embodies funds for enhancements and refurbishment to the USCIS Global case management system that would support features such as: Ensuring transition of positive credible fear screening cases to the hearing process currently provided for affirmative asylum cases, support for withholding of removal and CAT
adjudication features, non-detained scheduling enhancements, and capabilities to accept and provide review for electronic documents. The one-time cost also includes funds earmarked for teams that support integrations with other internal and external-facing systems, such as recordkeeping, identity management and matching, reporting and analytics, applicant-facing interfaces, and other key USCIS systems, as well as external systems at Immigration and Customs Enforcement ICE, CBP, or DOJ.98
Included in these $12.5 million costs are the costs to pay staff to make these upgrades. DHS estimates between 30
and 40 individuals, with a little over half contract personnel and the rest being Federal employees, would be involved either partor full-time in the implementation of these enhancements through FY 2022. The Federal personnel would mainly comprise GS14 and GS
15 level personnel and supervisory and management staff.

IT costs are expected to decline in FY
2023 and remain flat into the future at $4.375 million, which accounts for ongoing operations and maintenance costs. New features or upgrades are not expected at this time, but if they were to be needed in the future, those enhancements would result in additional costs not included here.
At present, DHS does not envision new facilities or additional structures being required from an IT perspective to implement this rule.
Importantly, this effort is expected to coincide with the first electronic processing of the Form I589. Since this will be a significant change for processing asylum applications, unexpected errors or system changes could have impacts on this project as well. Additional dependencies rely on the availability of ICE, CBP, and DOJ
systems to integrate with USCIS systems to provide for streamlined implementation. However, since this trajectory was enabled outside the scope of this rule, we do not attribute costs to it.
As described earlier in this analysis, we expect no net change regarding biometrics collection germane to asylum applications for individuals with a positive credible fear determination. We also detailed how factors concomitant to more expeditious EAD approvals make it impossible to estimate the magnitude or even direction in the net change in Form I765 filing volumes related to asylum or withholding of removal, and hence, commensurate biometrics collections and fee payments.
However, given the parameters of this proposed rule, any net change in biometrics would not impose new costs to the Federal Government. The
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maximum monthly volume of biometrics submissions allowed by the current ASC contract is 1,633,968 and the maximum annual volume is 19,607,616.99 The average number of individuals that submitted biometrics annually across all USCIS forms for the period FY 2016 through FY 2020 was 3,911,857.100 Given that the average positive-screened credible fear population is 59,280 Table 3, which is 1.52 percent of the biometrics volume, a volume change would not encroach on these bounds.
One scenario that we do account for relates to costs for a particular USCIS
ASC district. The DHSASC contract was designed to be flexible to reflect variations in benefit request volumes.
The pricing mechanism within this contract embodies such flexibility.
Specifically, the ASC contract is aggregated by USCIS district, and each district has five volume bands with its pricing mechanism. The incumbent pricing strategy takes advantage of economies of scale because larger biometrics processing volumes have smaller corresponding biometrics processing prices.101 For example, Table 9 provides an example of the pricing mechanism for a particular USCIS
district. This district incurs a monthly fixed cost of $25,477.79, which will cover all biometrics submissions under a volume of 8,564. However, the price per biometrics submission decreases from an average cost of $6.66 for volumes between a range of 8,565 and 20,524 to an average of $5.19 once the total monthly volume exceeds 63,503. In other words, the average cost decreases when the biometrics submissions volume increases jumps to a higher volume band.

TABLE 9EXAMPLE OF PRICING MECHANISM FOR A USCIS DISTRICT PROCESSING BIOMETRICS APPOINTMENTS, FY 2021
District X

Volume band
Baseline: Fixed price per month
Fixed price per person processed
Fixed price per person processed
Fixed price per person processed
Fixed price per person processed

AA
AB
AC
AD
AE

Minimum volume 0
8,565
20,525
31,753
63,505

Maximum volume 8,564
20,524
31,752
63,504
95,256

Costs $25,477.79
6.66
5.94
5.53
5.19

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Source: USCIS, IRIS Directorate, received May 10, 2021.

At the district level, since there are small marginal changes to costs in terms
of volumes, it would take a substantial change in volumes for a particular
district to mount a significant change in costs for that district. If biometrics
98 While this plan tracks the FY 2022 time frame, variations in the pace of Federal and contractor hiring and retention during the performance period, unforeseen legal or other policy challenges to any electronic process, and the ability of relevant offices to truly operationalize minimal functionality give their own staffing constraints to handle manually
any additional process automations, could delay some implementation into FY 2023.
99 Data and information provided by the USCIS
IRIS Directorate. The average annual biometrics volumes were obtained through the CPMS database.
The cost contract reflects the most recent contract update, dated June 18, 2020.

100 Data and information provided by USCIS IRIS
Directorate, utilizing the CPMS database.
101 Economies of scale is a technical term that is used to describe the process whereby the greater the quantity of output produced in this case more biometric service appointments, the lower the perunit fixed cost or per-unit variable costs to produce that output.

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