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Today the National Coalition for Literacy celebrates the inauguration of President Joseph Robinette Biden, Jr. and Vice President Kamala Devi Harris! 

Throughout his career, President Biden has been a consistent advocate for adult education, most notably in his promotion of adult career pathways innovation in the White House report Ready to Work: Job-Driven Training and American Opportunity that accompanied the Workforce Innovation and Opportunity Act authorization in 2014. In that report he spoke of adult education programs as “particularly important to those hardest hit by the twists and turns of global competition, technological changes, economic isolation, or inadequate education opportunities.”

As the Biden Administration begins to address the economic fallout of the global pandemic and the systemic inequities that it has both revealed and exacerbated, adult education will continue to play a pivotal role. Adult education programs seek to counteract systemic inequities in education that disproportionately affect Black, Brown, Indigenous, and immigrant/refugee community members by providing instruction in foundational literacy and numeracy skills, high school equivalency, and workforce/college readiness. As recent Survey of Adult Skills data shows, in the United States, 19 percent of adults are profoundly in need of literacy skills development and 29 percent lack critical numeracy skills. These adults are overrepresented in communities of color—the same communities that have been most adversely affected by the COVID-induced health and economic challenges that are rooted in systemic inequity.

Adult education in the United States has deep roots in social justice efforts that recognize and promote literacy and learning as central to access, voice, and action for all. The very first adult schools – Massachusetts in 1842; California in 1856 – were community-level efforts focused on immigrant integration through English language and civics instruction, and basic literacy for adults with limited formal education. During the civil rights protests of the 1960s, a federal investment in adult education was recommended as one strategy for mitigating the effects of structural and systemic racism. Over the decades since then, adult education has continued its mission of opening the doors to economic opportunity and full participation in society through education. While the recent Survey of Adult Skills data demonstrates the persistence of inequities, the power of adult education to address them and promote social justice is documented in studies such as The Case for Investment in Adult Education. As the Education Strategy Group has noted, “education holds the key to economic revitalization and must play a central role in addressing systemic inequities.”

During the months of the pandemic, adult education programs have turned to remote teaching to continue providing services. Yet this instruction has been inaccessible to many in adult education’s learner population due to limitations on digital access in rural and low-income areas of the country. Educational inclusion and digital inclusion now go hand in hand, and adult education’s ability to counter the effects of educational inequity and systemic racism increasingly depend on complementary investments in digital infrastructure and access to internet-enabled devices and digital skills instruction.

In states and communities across the country, adult education’s power lies in its ability to meet the moment and rise to the challenge. The National Coalition for Literacy welcomes President Biden and Vice President Harris and encourages them to build on the nation’s commitment to educational equity by recognizing adult education’s critical work, investing in it, and rewarding it.

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

NCL Comment on Proposed Changes to Public Charge Rule

NCL Comment on Proposed Changes to Public Charge Rule

The U.S. Department of Homeland Security has proposed a new rule for determining adult immigrants’ eligibility for green cards and changes in visa status. The proposed rule hinges on whether the immigrant is or may become dependent on public support:

Aliens who seek adjustment of status or a visa, or who are applicants for admission, must establish that they are not likely at any time to become a public charge, unless Congress has expressly exempted them from this ground of inadmissibility or has otherwise permitted them to seek a waiver of inadmissibility. Moreover, DHS proposes to require all aliens seeking an extension of stay or change of status to demonstrate that they have not received, are not currently receiving, nor are likely to receive, public benefits as defined in the proposed rule. (

The National Skills Coalition explains public charge succinctly:

Public charge is the standard by which individuals can be denied permanent resident (green card) status or otherwise forbidden from extending or changing their visas if they are determined to be dependent on the government for support, or likely to be dependent in the future. The public charge is a totality of circumstances test, in which federal officials weigh the positive and negative factors in an individual immigrant’s application and determine whether they are at risk of becoming a public charge. The current public charge policy has been in place for decades, and was most recently affirmed in 1999 policy guidance from the federal government.

Relatively few immigrants are currently eligible for cash assistance or related public benefits, in part due to the 1996 welfare-reform law. But the new proposal would also require federal officials to predict whether the immigrant might receive benefits in the future. Given that immigrants who are granted green cards are then eligible to apply for US citizenship, and that US citizens are eligible for a wide range of public benefits, the rule would have sweeping implications. Ultimately, the proposed changes would affect millions of legally authorized immigrants and prospective immigrants. (

The NCL opposes the proposed rule in its entirety and has submitted a comment outlining its reasoning to DHS (see below). The comment period is open through December 10. We encourage all who work with adult immigrants to review the analysis provided by the National Skills Coalition and to submit comments from their own knowledge and experience. Feel free to use the text of the NCL’s comment as needed and appropriate.


Text of the NCL comment:

Samantha Deshommes, Chief, Regulatory Coordination Division

Office of Policy and Strategy, U.S. Citizenship and Immigration Services

Department of Homeland Security

20 Massachusetts Avenue NW

Washington, DC 20529-2140

Re: DHS Docket No. USCIS-2010-0012

Dear Ms. Deshommes

I write on behalf of the National Coalition for Literacy regarding the proposed changes to federal policy on the public charge as outlined in the Notice of Proposed Rulemaking referenced above. The Coalition opposes the proposed changes because they will have an adverse effect on adult immigrants’ ability to become and remain valuable contributors to U.S. economic and societal strength.

The NCL is a coalition of leading national, regional, and local organizations dedicated to advancing adult education, family literacy, and English language acquisition in the United States. A number of our member organizations and affiliates are submitting comments related to their specific constituencies; the comments provided here address the overall potential effects of the proposed changes. Our concerns fall into three categories: potential obstacles to adult immigrants’ participation in education and training; potential challenges for adult education and workforce training providers; and potential issues for state and local adult education systems.

Potential Obstacles to Adult Immigrants’ Participation in Education and Training

  • The new rule could force immigrants who are adult learners and jobseekers to choose between their health and their education. While education and training programs themselves are not included in the list of public benefits that would count against immigrant applicants seeking green cards or changes in visa status, many participants in training programs depend on other benefits that would be counted against them—such as the Supplemental Nutrition Access Program (SNAP) or Medicaid—to be able to persist and complete their education. As a result, immigrants who are adult learners and jobseekers could be faced with the difficult decision of whether to dis-enroll from health and nutrition programs and jeopardize their ability to complete their training, or to stay enrolled in the programs and potentially jeopardize their immigration status.
  • The new rule would undermine immigrant workers’ ability to upskill for in-demand occupations. The overwhelming majority of jobs in the U.S. economy today require some postsecondary education; an analysis of Bureau of Labor Statistics data shows that 84 percent of jobs today require education and skills beyond the high school level.[1] The U.S. labor market has especially strong demand for workers at the middle-skill level: jobs that require more than a high school diploma, but not a four-year degree.[2]

Immigrants represent one in six American workers,[3] and are crucial to meeting the demand for middle-skill occupations such as machine operator, welder, certified nurse aide, and computer user support specialist. Training for middle-skill occupations is often provided by community colleges, where some immigrants draw on public benefits such as SNAP to enable them to complete their studies. Counting these students’ use of public benefits as a negative factor in the public charge test will undermine their ability to upskill and prepare for the open positions that American employers need to fill.

  • The new rule would reduce enrollment, retention, and completion rates in adult education and workforce programs. Evidence from prior changes in immigration policy strongly suggests that many immigrants who are not subject to the public charge test will nevertheless withdraw from a broad array of public programs and services out of confusion, fear, or an abundance of caution. For example, following passage of the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) in 1996, thousands of immigrant families withdrew from public benefits programs for which they were eligible.[4] The proposed new rule has been widely publicized, and human services agencies are already reporting an increase in immigrants disenrolling from public benefits programs.[5] If this regulation is enacted, it is reasonable to expect that this type of disenrollment will continue, and will include two types of needless disenrollment: 1) immigrants who are not subject to the public charge test, and 2) immigrants who disenroll even from services that are not included in the public charge determination. Such needless disenrollment would lower overall participation rates for adult education and workforce programs, as well as reducing the likelihood of success for participants who withdraw from services midway through a program.
  • The new rule would increase financial instability for immigrants who are college students and heighten their risk of dropping out. Many college students are part of larger households, either as adult children or as spouses and parents themselves. This is especially true for community college students, whose average age is 26 years old. According to the National Center for Education Statistics, one-third of community college students have family income of less than $20,000 per year.[6] Penalizing immigrant students for drawing on public benefits would have a tremendous negative impact on these financially fragile households, making it more likely that students would need to cut back on their course load or withdraw from education altogether. The long-term effect would be to reduce higher education attainment among some of the very students who most need to build a strong economic footing for themselves, their families, and their American communities.
  • The new rule could punish immigrants for attempting to improve their English skills. Research from the Organization for Economic Cooperation and Development (OECD) shows that better basic skills and higher earnings are tightly connected in the United States – more so than in other industrialized countries.[7] This means that as immigrants improve their reading, math, and spoken English skills, they are better able to contribute economically to American society. The proposed regulation acknowledges the centrality of English language skills to economic self-sufficiency by characterizing them as a positive factor in the totality of circumstances test. However, individuals commonly improve their English skills through participation in education programs such as those offered at community colleges. Individuals who rely on Medicaid or other public benefits to enable them to succeed in their English language classes could be discouraged from continuing their education and improving their employability by fear of being found a public charge.

Potential Challenges for Adult Education and Workforce Training Providers

  • The new rule would create confusion and add expensive, time-consuming responsibilities for financial aid advisors, guidance counselors, and educators. Adult learners and workers rely on professionals to give them accurate guidance as they make important life decisions about which higher education or workforce program to enroll in, how to pay for tuition, how much debt they can safely take on, and the financial consequences of their decisions. The proposed rule would increase the preparation required for high school guidance counselors, college financial aid advisers, career navigators, and other education professionals, as they would need substantial training in order to provide accurate guidance to immigrant applicants and their families about the repercussions of accessing public benefits as they pursue their educational goals. School districts, higher education institutions, and nonprofit organizations would thus be subject to an unfunded mandate. Higher education institutions, nonprofit organizations, and state and local agencies would also face the challenge of updating enrollment forms, software programs, and other documentation that currently reassures participants that enrolling in publicly funded programs will not jeopardize their immigration status, and substituting a much more nuanced and complicated disclaimer.
  • The new rule would place workforce professionals at risk of providing advice far beyond their areas of expertise. There are more than 550 workforce boards in the United States, thousands of American Job Centers, and tens of thousands of workforce training providers. Staff at these agencies and programs are expected to be knowledgeable about workforce development, not to be immigration legal experts. The new rule would remove a clear, bright-line standard for when an immigrant may be considered a public charge, and replace it with a highly complex, multi-faceted test. This increased complexity would make it difficult for education and workforce provider staff to advise participants in a straightforward way on whether using a public benefit might jeopardize their immigration status. As a result, workforce systems could be forced to use scarce public resources to train staff on an exceptionally complicated new set of federal restrictions. In addition, confusion or excessive caution could lead individuals to be turned away from services for which they are actually eligible.

Potential Issues for State and Local Adult Education Systems

  • The new rule would undercut state and local education and workforce policy goals. State and local governments regularly advance policies to improve the education and employability of their residents. For example, more than 40 states have established goals for postsecondary credential attainment, such as having 60 percent of state residents earn a college degree or other postsecondary credential by 2025.[8] Many states will not be able to reach their goals without including their immigrant residents.[9]

To accomplish their goals, states have established programs and services to equip returning adult students to persist and succeed in their education, including through assistance in accessing key public benefits. For example, in 2018 Illinois passed Senate Bill 351, known as the College Hunger Bill, to facilitate access to SNAP benefits for certain low-income college students.[10] Research has shown that supportive services that help individuals access public benefits programs are often vital to ensuring that working adults succeed in postsecondary education.[11] However, the proposed public charge rule would penalize immigrants for using such benefits, thus creating a disincentive for them to participate in the very programs that are intended to help them succeed in their education and contribute economically. As a result, this federal regulation would undercut state and local efforts to invest in the human capital of their residents, by discouraging qualified immigrants from even applying for public benefits programs.

Our central concern is thus the negative effect that the proposed rule would likely have on immigrant participation in publicly funded adult education and workforce programs, extending far beyond the scope of the proposed rule itself. Even though the public charge proposal does not apply to some categories of immigrants (such as refugees), and even though it does not include education and workforce programs, the mere proposal of these regulatory changes has already had a notable negative effect.[12] Given the complexity of the new rule, education and workforce professionals may find it difficult to give a blanket reassurance to worried adult learners and jobseekers, and may see dips in enrollment, participation, and completion.

In light of these concerns, the NCL urges DHS to withdraw the proposed rule in its entirety, and instead to allow the principles that were affirmed in the 1999 field guidance on public charge to remain in effect. This field guidance, issued by the legacy Immigration and Naturalization Service (INS), is consistent with Congressional intent and case law. It represents a clear, straightforward standard that is administratively simple and relatively non-burdensome for workforce and education service providers to communicate to their immigrant constituents, and has been in use for decades.

Thank you in advance for your thoughtful consideration of these comments and for your action in response to the concerns we raise.


Deborah Kennedy



[1] Source: The United States’ Forgotten Middle (National Skills Coalition, 2017.) Available at

[2] Ibid.

[3]Source: Frequently Requested Statistics on Immigrants and Immigration (Migration Policy Institute, February 8, 2018.)

[4] Michael Fix & Jeffery Passel, Trends in Noncitizens’ and Citizens’ Use of Public Benefits Following Welfare Reform, March 1999, (noting fear and confusion around public charge as a factor in noncitizen benefit enrollment decreases), available at Also see Leighton Ku & Alyse Freilich, Caring for Immigrants: Health Care Safety Nets in Los Angeles, New York, Miami, and Houston, Feb. 2001 (detailing several conversations with immigrants who decided that the risk of public charge was too great to receive Medicaid, even though policy had been issued that Medicaid posed no public charge risk), available at

[5] Source: ”Spooked by Trump Proposals, Immigrants Abandon Public Nutrition Services,” (New York Times, March 6, 2018.) Available at:

[6] Source: Community College FAQs (Community College Research Center, Columbia University, n.d.) Available at :

[7] Time for the US to Reskill? (OECD, 2013.)

[8] See overview of all states here: and details on 29 of the state goals here:

[9] See, for example: Middle Skill Credentials and Immigrant Workers : Texas’ Untapped Assets (National Skills Coalition, 2017.)

[10] Source : “Governor signs College Hunger Bill, assuring low-income community college students can access food security via SNAP, “ (Chicago Coalition for the Homeless, n.d.) Available at :

[11] Source: Connecting College Students to Alternative Sources of Support The Single Stop Community College Initiative and Postsecondary Outcomes (Rand Corp., 2016.) Available at:

Click to access RAND-Report_Executive-Summary-1.pdf

[12] For evidence of this effect, see “A proposed federal policy won’t target immigrants for using welfare. In Texas, they might drop out anyway” (Texas Tribune, Sept 28, 2018). Available at: See also “Immigrants drop subsidized food, health programs – fearing aid will be used against them” (NBC News, Sept 8, 2018). Available at

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