The Center for Immigration Studies (CIS) respectfully submits the following public comment to U.S. Citizenship and Immigration Services (USCIS) in response to the Department of Homeland Security’s (DHS) notice of proposed rulemaking (NPRM), “Employment Authorization Reform for Asylum Applicants”, DHS Docket No. USICS-2025-0370, as published in the Federal Register on February 23, 2026.