Naturalization Test Redesign

In December 2022 USCIS announced that it was starting a pilot project to redesign the English/civics test for naturalization. If the pilot test is adopted, applicants will face a more difficult English/civics exam. This community explainer breaks down some of those challenges, and how advocates can push for a more inclusive process of naturalization.

In December 2022 USCIS announced that it was starting a pilot project to redesign the English/civics test for naturalization. The redesign came about after an Executive Order by President Biden ordering government to restore faith in our legal immigration system and to increase access to naturalization. Unfortunately, the pilot test put forward in the redesign has the opposite effect because it will be more difficult for applicants to pass.

The naturalization law and regulations require an understanding of English in ordinary usage, using simple words and phrases, where no extraordinary conditions may be imposed. The regulations also require that the civics test be given orally, but the test being introduced by USCIS is a written multiple choice exam.

The current evaluation of English/civics for naturalization was introduced in 2008 after a multi-year collaboration with stakeholders and education experts. The evaluation of English/civics involves answering basic questions during the course of the naturalization interview such as biographic information and pleasantries, followed by an oral test of civics where an applicant must answer 6 out of 10 questions correctly (from a possible pool of 100 questions). The material used is basic civics knowledge that the applicant can study in advance. The applicant must also write and read one of three dictated sentences.

The redesigned test represents new challenges for adult learners because it requires a higher level of reading ability than can be met by low-literacy adults who learn orally. The civics portion of the pilot requires test-taking skills in multiple choice format that is not currently required of naturalization applicants and poses a barrier to those without formal education. In addition, instead of evaluating English ability during the naturalization interview by asking basic questions on the applicant’s information on the form, USCIS proposes a new English exam where applicants would have to describe a scene in a picture presented to them on a screen. This leaves the questions and answers open to varied interpretations subject to the adjudicator’s discretion, which could result in a denial or unnecessary re-test. USCIS is also proposing that the test would be separate from the naturalization interview, creating an additional step and added processing time to qualify for naturalization.

ILRC and the Naturalization Working Group are opposed to the redesign and have expressed grave concerns to USCIS about the proposed changes. Coordinated by the NALEO Educational Fund, the NWG is the policy complement to the New Americans Campaign (NAC), which is the largest collaborative dedicated to increasing the number of people who become US citizens.

USCIS has forged ahead regardless of criticism and has plans to begin testing this new format with volunteer organizations who are preparing students for the new test design, administering the test, and providing feedback to USCIS. The pilot is being administered by a group that received a government contract to assess the results, Teaching English as a Second Language (TESOL). TESOL has created a Technical Advisory Group (TAG), made up of unnamed testing professionals, which will review the result of the pilot and make a recommendation to USCIS sometime in late 2023 or early 2024. USCIS promised that after the report is completed, a decision will be made as to whether the pilot will be implemented at USCIS field offices. USCIS has stated that they hope to implement this new testing structure in 2024.

If you wish to express opposition to a new multiple-choice reading-based civics test and a separate English test using picture prompts, send your comments to:

• uscisfeedback@uscis.dhs.gov;
• public.engagement@uscis.dhs.gov;
• Cisombudsman.publicaffairs@uscis.dhs.gov;
• policyfeedback@uscis.dhs.gov;
• Natzredesign22@uscis.dhs.gov;
• Send a copy to citizentest@ilrc.org