Submit Your Comments to the USCIS

Monday, May 17, 2010

Submit Your Comments to the USCIS

 
In response to concerns expressed by Dance/USA and the broader national performing arts community, U.S. Citizenship and Immigration Services (USCIS) has opened a public comment period, inviting feedback regarding a specific area of artist visa processing - the amount of time allowable between multiple engagements in a single visa approval period. Click here to read the draft memo open for public comment.

Dance/USA, in partnership with the national Performing Arts Visa Working Group, will submit detailed comments to USCIS.

To give greater voice to the concerns that dance organizations have about the visa process, we encourage you to consider submitting comments on behalf of your organization. We've drafted sample talking points (see below) that may be modified to include details about your dance company’s experience with the visa process.

Comments must be received by USCIS by May 24, 2010.

Email all comments to opefeedback@uscis.dhs.gov. For more information on the USCIS Comment Process, click here.

Support Reasonable Artist Visa Validity Periods:

U.S. Citizenship & Immigration Services (USCIS) is seeking comments on guidance it plans to offer to its staff when processing visa petitions in which there are gaps of time between performances. While the memo is generally supportive of the process we would like USCIS to use, arts organizations are encouraged to weigh in with statements explaining why efficient and reliable visa processing is essential to supporting international cultural exchange.

Sample Talking Points:

• BE SURE TO PERSONALIZE YOUR MESSAGE. Explain how and why your organization uses the artist visa process. Because USCIS really reads these comments, do not simply cut and paste these talking points, but make the message your own.

• Dance organizations from all regions of the country and of all budget sizes present international artists to U.S. audiences. By inviting foreign artists to perform under O and P visas, dance companies provide American audiences the opportunity to experience a diversity of talent and encourage a supportive climate for U.S. arts organizations to perform abroad.

• The allowable gap between performances should not be limited to a specific number of days. We are pleased to see that USCIS is not proposing such a limit.

• We support the memo's direction to "approve a petition for the length of the validity period requested." If arts organizations were required to file multiple petitions for each engagement by the same artist, the result would impose severe administrative burdens and financial costs.

• In addition to addressing the subject of the draft policy memo, we request immediate action by USCIS to improve the artist visa process by shortening processing times and improving the accuracy and reliability of the petition process. These changes can make an instant, measurable impact on improving the climate for international cultural activity.

Unified Advocacy Continues:

Dance/USA’s efforts to improve the visa process for guest artists are conducted in close collaboration with our advocacy partners in the Performing Arts Visa Working Group: American Federation of Musicians, Association of Performing Arts Presenters, League of American Orchestras, North American Performing Arts Managers and Agents, OPERA America, Performing Arts Alliance, and Theatre Communications Group, and under the guidance of immigration attorney and www.artistsfromabroad.org author Jonathan Ginsburg.

In addition to representing dance companies before USCIS and the White House, we continue to work with Congress to seek a legislative remedy to improve the reliability and efficiency of visa processing. This issue was also included as an advocacy priority during national Arts Advocacy Day, endorsed by dozens of national arts organizations.




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