NAFSA provided comments to U.S. Citizenship and Immigration Services (USCIS) on USCIS's plan to make Form I-539 an entirely online application as part of USCIS's Transformation initiative (now known as ELIS). NAFSA recommended that USCIS:
- Ensure Integration of USCIS and Partner Agency Information Systems
- Limit the Initial Implementation of I-539 E-Filing to B-1/B-2 Extension Applications
- Allow DSOs, ROs, and Employers’ Representatives “Read Access”