In mid-November 2020, U.S. Citizenship and Immigration Services (USCIS) released a revised version of the civics test that is required for people who were not born in the United States and wish to become citizens. NCL has significant concerns about the revised test, and has submitted a letter expressing those concerns through the response channel provided by USCIS. The text below is excerpted from that letter.

---

Mr. Kenneth Cuccinelli  
Senior Official Performing the Duties of Director 
United States Department of Homeland Security 
U.S. Citizenship and Immigration Services 

Dear Mr. Cuccinelli,

I am writing on behalf of the National Coalition for Literacy to convey NCL’s significant concerns about the development process, administration procedures, and preparation requirements for the revised naturalization civics test that was released by USCIS in November 2020. NCL is an alliance of the leading national and regional organizations dedicated to advancing adult education, family literacy, and English language acquisition in the United States. Our comments on the revised civics test are based on insights provided by our member organizations, who have deep expertise in working with refugees, immigrants, and U.S.-born adults in need of educational opportunity. Based on this input, NCL opposes the implementation of the revised test and respectfully asks that USCIS continue using the 2008 version until a full review of the new one has demonstrated that it adheres to USCIS’ stated goal of producing a standardized, fair, and appropriate test that is not more difficult and does not decrease the pass rate. NCL further requests that USCIS plan for revision or elimination of the new test if the results of the review show that it is not equivalent to the 2008 one on these measures.

Preparation Requirements

The 2008 version of the civics test requires applicants to answer up to 10 questions from a list of 100; they must answer six correctly. In the 2020 version, 20 questions are asked from a list of 128 possible questions and answers, and applicants must correctly answer 12. To pass the 2020 version, then, applicants will have more content to learn (128 questions instead of 100), so more preparation time will be required. The increased content burden will also reduce the number of applicants who are able to prepare on their own; applicants will need to take a citizenship class, if they can find one that is available in their community. More applicants will fail the test at the first interview and will need to return for a second try, requiring more time off work and increased effort on their part. In light of these considerations, it seems likely that the 2020 test will impose a greater burden on test takers than the 2008 test.

Administration Procedures

The administration procedures for the 2020 test place a substantial additional burden on USCIS test administrators as well. In the 2008 version, as soon as the applicant answers six of the possible ten questions correctly, the test is ended. In the 2020 version, by contrast, the test must continue until the administrator has asked all 20 questions, regardless of when an applicant has answered 12 correctly. This will double the amount of time required for administering the civics test, and could potentially triple it in some cases—resulting in fewer interviews per day for each USCIS officer and thus increasing the length of time required for each applicant to obtain an appointment and complete the test. The resultant slowing of the testing process will have the overall effect of decreasing the pass rate.

Development Process

USCISS developed the 2008 civics test through an extended process of pilot testing, stakeholder input, item revision, and field testing, all of which took place in a fairly transparent way. The 2020 development process has involved considerably less communication outside of USCIS. As a result, the degree to which stakeholder input, including that of the Technical Advisory Group, was taken into account is not known, and the process and outcomes for field testing and item revision is unclear. Undoubtedly the test development process, particularly piloting and field testing, was impeded by the effects of the pandemic during the spring and summer of 2020; all the more reason to delay implementation of the revised test until a review of the development process assures that it is valid for all test takers, reliable across test administrations, and fair to both applicants and administrators.

Thank you for the opportunity to offer our comments and feedback regarding the revised civics test. Please feel free to contact us if we can provide further information on any of these points or on the overall process of making U.S. citizenship available to those who have so much to contribute to our nation’s strength and success. We look forward to the department’s thoughtful consideration of our recommendations and concerns.

Cordially,

Deborah Kennedy
Executive Director