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Author: Deborah Kennedy

Comments on the Revised Naturalization Civics Test

Comments on the Revised Naturalization Civics Test

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.


Deborah Kennedy
Executive Director

November Observations

November Observations

November is the month for two observations that are integrally related to adult literacy and adult education.

National Family Literacy Month

Founded in 1994 by the National Center for Families Learning, this observation “offers an opportunity for practitioners to emphasize the important role that families play in the education of their children,” according to the NCFL.

Over the past several decades, researchers across the country have recognized the strong correlation between parents’ and caregivers’ educational attainment and children’s educational outcomes. We know that families thrive when they learn together.

Source: National Center for Families Learning blog post

Visit the NCFL blog for 30 Days of Families Learning Together and other suggested activities for teachers, parents, and community members.

National Native American Heritage Month

Since 1990, November has been designated as the month to celebrate and raise awareness of the heritage of the first Americans and the powerful contributions they have made to the country’s formation and growth. This month-long observation also provides an opportunity to advocate for policy changes that will address the educational and other inequities that Native American and Alaska Native communities face. As the National Congress of American Indians notes,

Nationwide, Native youth face some of the lowest high school graduation rates, and even fewer enroll in and graduate from college. On average, less than 50 percent of Native students graduate from high school each year in the seven states with the highest percentage of American Indian and Alaska Native students.

Observation of Native American Heritage Month is sponsored by the Library of Congress in collaboration with multiple other federal agencies. Visit these sites for information and resources:

Celebrate AEFL Week at the National Book Festival

Celebrate AEFL Week at the National Book Festival

The Library of Congress National Book Festival is taking place this weekend, and participating is a great way to observe Adult Education and Family Literacy Week.

According to the Festival information page, more than 120 authors, poets, and illustrators will be participating on nine virtual stages:

  • Children
  • Teens
  • Family, Food & Field
  • Fiction
  • Genre Fiction
  • History & Biography sponsored by Wells Fargo
  • Poetry & Prose sponsored by National Endowment for the Arts
  • Science
  • Understanding Our World

Author presentation videos for children and teens will be released at 9 AM ET on Friday, September 25, and will be available on demand via the Festival platform, Library website and YouTube. All author presentation videos on other stages will launch at 9 AM ET on the next day, Saturday, September 26. For a complete line-up of authors and their video presentations, please see the complete video on demand list.

From Friday through Sunday, September 25-27, we will feature interactive live Q&A sessions with select authors to complement their presentation videos. We list them in the schedule under “Live Events by Stage” and “Live Events by Day.”

Attendees may also explore the author presentation videos by following three Timely Topic Threads that weave through the festival and offer a more profound appreciation for the subjects – “Democracy in the 21st Century,” “Fearless Women” and “Hearing Black Voices.”

Register to participate, and enjoy!

An AEFL Week Opportunity

An AEFL Week Opportunity

National Adult Education and Family Literacy Week has begun!

How will you take advantage of this opportunity?

AEFL Week raises public awareness about the need for and value of adult education and family literacy. Its goal is to increase financial and societal support for access to basic education programs for U.S. adults with low literacy, numeracy, and digital skills. Advocates across the country use this opportunity to elevate adult education and family literacy nationwide with policymakers, the media, and the community.

What are some ways to participate this week?

  • Start with toolkits and other resources for planning advocacy around AEFL week
  • Customize and share NCL’s AEFL Week social media messaging for direct service providers, policy makers, and donors
  • Host an online event to raise awareness of adult education and family literacy

What about next week, next month, next spring?

AEFL Week is also a great opportunity to plan out your advocacy strategy for the next 6 months or more.

  • Who are your federal and state legislators? What are their positions on adult education, family literacy, digital equity? Plan out a schedule for when you will contact them over the next few months and what you will say.
  • What information about literacy and numeracy levels in your specific community or locale can you obtain from the PIAAC Skills Map? How can you use that information to explain the importance of adult education?
  • What information about digital access in your community can you obtain from the National Broadband Map? How can you use that information to support your points about digital literacy and digital inclusion?
  • What are some of the strengths and successes of your program and your adult learners? How can you use those to illustrate the value (and return on investment) of adult education?

This AEFL Week, take the opportunity to become a more informed, more creative, and more persistent advocate. And let us know how we can help!

National Adult Education and Family Literacy Week was established when the National Coalition for Literacy worked with Senators Patty Murray (D-WA) and Lamar Alexander (R-PA) and then-Representative Jared Polis (D-CO) to create a Congressionally-recognized designation that would draw attention to the importance of adult education and family literacy. Since then, NCL has sponsored AEFL Week in September each year on behalf of its members and the field as a whole, and has worked with Members of Congress to have the week recognized through resolutions in the Senate and the House of Representatives.

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