On August 18, 2011, NAFSA submitted comments to U.S. Citizenship and Immigration Services (USCIS) on how it might improve Form I-765 “Application for Employment Authorization” and its instructions. USCIS had published a notice in the July 20, 2011, Federal Register asking for such comments so that it might, among other things, “enhance the quality utility, and clarity” of the form and “minimize the burden” on those who use it. NAFSA recommended that USCIS:

  • Amend the instructions regarding full-time off-campus employment authorization pursuant to a “special student relief” Federal Register notice
  • Amend the instructions to clarify procedures for M-1 students seeking practical training after completing studies
  • Amend the instructions to clarify eligibility codes at item 16 on Form I-765
  • Include “in care of” or “c/o” line in I-765 address fields