Immigrants and U.S. sponsors are waiting longer than ever to receive responses to their applications to U.S. Citizenship and Immigration Services (USCIS), and the agency has released a new proposed rule today that would dramatically increase fees for most applications to help process them quicker. But data in that rule reveal one important reason why processing times are increasing, and it has nothing to do with money: for 82 percent of form types, USCIS adjudicators are simply spending more time reviewing the form than in the past, leading to a backup of applications sitting at the agency without anyone to look at them. As a result of the longer review times, it will take USCIS more than 3.3 million additional man-hours to process its backlog.

The processing time that applicants feel is how long it takes to find out the outcome of their request. As I have previously documented, the average of the median processing times across all forms for which DHS-USCIS reports data increased threefold—from less than 4 months in 2012 to over a year in 2022. However, the 80th percentile at the most‐​delayed locations was more than double the average at 27 months, and 20 percent of applicants at those locations waited even longer.

But another type of processing time is even more important: the time it takes for an adjudicator to review the application after they pick it up. This “review time” is how long it takes an adjudicator to issue a decision on an application from the time they start looking at it, not the total time that the application is with the agency (including all the time it takes for someone to finally look at it). These review times are measured in hours or minutes, not months and years, but any time that is added to the review time can balloon when multiplied across millions of applications.

Table 1 shows the time per completion for 2023, 2019, 2016, and 2010 for the forms that USCIS reported. USCIS is spending more money to take longer to adjudicate forms. 2023 was the best year for adjudication time for just nine forms, which are mostly less common forms (with the notable exception of the I‑90 form). Adjudicators were taking longer than one of the prior years for the other 42 forms (82 percent of the forms), and for 34 forms, adjudicators were taking longer than they were as recently as 2019. The 42 forms that are taking longer account for 86 percent of USCIS’s backlog (for which review times are reported).

Take one example. The largest proposed fee in 2023 will be for the I‑956 Application For Regional Center Designation under the EB‑5 investor visa program: $47,695, up from $17,795. USCIS says that it takes 108.5 hours to review, but in 2019, USCIS said that it took only 34.95 hours to process an Application For Regional Center Designation. USCIS is saying that its adjudicators are now taking nearly three times as long, and it wants nearly three times the money.

But it’s not just investor-related applications. The I‑129 for L‑1 temporary workers, for instance, is taking adjudicators over 1 hour and 20 minutes longer to process in 2023 than in 2019. In an agency where every additional minute can be multiplied by tens of thousands of applications, the fact that the agency keeps moving backwards on so many forms results in a massive decline in efficiency

USCIS spends over 5 hours on each asylum application, which is longer than any other non-investor-related application. This is an hour more than they spent per-application in 2019, but even four hours would be far longer than they should be spending. It spends just 2 hours per green card application. The problem is that adjudicators are looking for reasons to deny asylum applications rather than looking for whether applicants meet the criteria.

The consequence of the longer reviews is that it will take nearly 10 million man-hours to process the existing USCIS backlog—over 3.3 million more man-hours than if USCIS was processing every application as fast as it has in the past. This is the equivalent of USCIS needing to hire 1,605 more employees just to keep the backlog from growing.

This level of inefficiency is unacceptable. The agency needs to change from a “get-to-no” culture to one where customer service and processing efficiency is paramount. The agency must impose metrics that encourage efficiency and hold adjudicators accountable. It should start with disclosing statistics on the performance of each adjudicator.

One major reason for the slower processing times is that the agency has greatly increased the lengths of its forms from fewer than 200 pages total to more than 700 pages total from 2003 to 2023. Every additional page means more time for the adjudicators to review the application. USCIS needs to cut back on the red tape and focus on streamlining applications. USCIS has made improvements under this administration, but not enough to justify a significant fee increase.