Recently, an internal CIS memorandum surfaced on an anti-immigration web site. From the context of the memo, it is clear that this was intended for consideration of various administrative options. This was likely the source of the recent allegation made by several Republican senators that the administration was considering an "administrative amnesty."

Some of the proposals are clearly on the extreme edge of what is possible, others are very simple, common sense steps that can be taken to ameliorate existing problems. It is highly likely some, if not many of these proposals will be adopted either in the form initially proposed or after being modified.

When asked about the memo by the American Immigration Lawyers Association, the CIS offered the following statement:

“Internal draft memos do not and should not be equated with official action or policy of the Department. We will not comment on notional, pre-decisional memos. As a matter of good government, U.S. Citizenship and Immigration Services (USCIS) will discuss just about every issue that comes within the purview of the immigration system. We continue to maintain that comprehensive bipartisan legislation, coupled with smart, effective enforcement, is the only solution to our nation's immigration challenges.

Internal memoranda help us do the thinking that leads to important changes; some of them are adopted and others are rejected. Our goal is to implement policies wisely and well to strengthen all aspects of our mission. The choices we have made so far have strengthened both the enforcement and services sides of USCIS – nobody should mistake deliberation and exchange of ideas for final decisions. To be clear, DHS will not grant deferred action or humanitarian parole to the nation’s entire illegal immigrant population.”