Advocacy alert: Citizenship test changes

Dec 8, 2020Articles
U.S. Citizenship Advocacy alert

Last week, USCIS released a new citizenship civics test. Those who apply for naturalization after December 1, 2020 will be required to take the new test. The following changes have been instituted:

  • The total number of study questions has increased from 100 to 128.
  • The number of questions asked on the test has increased from 10 to 20 (with 60% still required to be answered correctly).
  • 40 of the current test questions are the same while the remaining 88 are new or re-phrased.

These changes will create a significant barrier for many immigrants. The new test questions require a higher level of English, putting citizenship out of reach for those with less proficiency. The increased number of questions will lengthen the amount of study time required, creating a burden for students. We are also concerned because the test was piloted with a relatively small number of applicants. In the past, new tests were developed over a six-year period with input from experts and piloted with a much larger pool of individuals. These changes could increase an already significant backlog at USCIS for citizenship applicants.

You can read more about the changes at the USCIS website. We also created a YouTube video for our students about the new test.

USCIS is providing an opportunity for the public to submit comments about the test changes through December 14, 2020. Literacy Pittsburgh has submitted a comment and we encourage you to do the same. Please email your feedback to using the template below as a guide. Please be sure to include information about why this issue is important to you.


Email to:

Subject: Volume 12: Citizenship and Naturalization, Part E, English and Civics Testing and Exceptions, Chapter 2, English and Civics Testing

Dear Director,

My name is __________________. I am a volunteer tutor with Literacy Pittsburgh. As a volunteer tutor, I help prepare students to succeed in their dream of becoming an American citizen.  [Please adapt according to your relationship with Literacy Pittsburgh]

Literacy Pittsburgh offers literacy programs for adults and families in Allegheny County and Beaver County, including immigrants from more than 100 different countries.  Last year, more than 5,000 people in the Greater Pittsburgh area improved their reading, writing, math, English language, citizenship, computer, and workplace skills. Free classes and tutoring move students from learning to earning and help them succeed as workers, parents and neighbors. Approximately half of our students are immigrants who rely on us for English language learning, human services coordination, and preparation for citizenship.

I would like to share comments about the Policy Manual Update for Civics Educational Requirement for Purposes of Naturalization – Volume 12: Citizenship and Naturalization, Part E, English and Civics Testing and Exceptions, Chapter 2, English and Civics Testing.  I am concerned about the changes that have been made to the Civics portion of the citizenship test. I agree with the observations made by ProLiteracy, a national adult education organization with a network of 5,000 adult education service providers and customers, of which Literacy Pittsburgh is a member. 

  1. Some of the new test questions or re-phrasing of existing questions require a higher level of English comprehension, making it harder for low-level English language learners to respond correctly. A quarter of the new questions introduce new topics not currently covered in most citizenship instruction and the answer choices include abstract concepts that do not add value. Further, most of the new questions address old content with new, more demanding language. These changes unnecessarily increase the difficulty of the test and create a significant barrier for individuals with more limited English proficiency or less education. It also forces citizenship preparation educators to revise their instructional plans and increase expenses to purchase new textbooks that reflect the new content.
  2. The increase in the number of study questions and the number of test questions puts greater demands on students, teachers, and volunteer tutor preparation time, at best lengthening the time for naturalization preparation and at worst discouraging immigrants from pursuing citizenship at all. The additional questions will also increase the interview time for each applicant, which will in turn draw on already overtaxed resources at USCIS with a current backlog of 300,000 naturalization applications.
  3. The process for development of the new test represents a considerable departure from processes for previous test updates in terms of expertise, stakeholder feedback, and pilot testing. This departure sets a dangerous precedent and further undermines confidence in the immigration system.

I am concerned that the changes will discourage otherwise eligible applicants, increase the burden and time for those who still choose to apply, and create an unfounded barrier to naturalization for many immigrants with low literacy skills due to interrupted educational backgrounds.  

Literacy Pittsburgh has prepared nearly 250 immigrants to become citizens over the past ten years. In our experience, this is an arduous process for all immigrants at all English language proficiency levels. The changes to the test unnecessarily increase the difficulty of an already difficult process. When coupled with the increased application fees, these changes will serve to slow the naturalization process for many immigrants and potentially disincentivize others from embarking on the process, robbing our country of the valuable contributions of too many newcomers.

Thank you for the opportunity to submit comments on the proposed changes.


Literacy Pittsburgh (formerly Greater Pittsburgh Literacy Council) helps create better lives through learning. Recognized as a national leader in adult and family literacy, Literacy Pittsburgh is the largest provider of adult basic education in Allegheny and Beaver Counties. Last year, Literacy Pittsburgh helped more than 4,000 individuals acquire the skills needed to reach their fullest potential in life and participate productively in their communities. Literacy Pittsburgh provides free, personalized instruction in workforce readiness, high school diploma test preparation, digital literacy, English language learning, math, reading, and family literacy through one-to-one and small class instruction. Founded in 1982, it serves local adults through numerous neighborhood locations and its Downtown Pittsburgh Learning Center.       

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