The Trump Administration has proposed changes to the “public charge” test. The “public charge” test is used to determine if a person requesting entry into the US would mainly rely on government benefits for financial support. The proposed changes would have harmful effects to health care, housing, and food access to low-income immigrant families including US citizen children.
The deadline to submit comments against the proposed public charge rule is Monday, December 10. Many of you are hard at work on your organizational comments. If anyone needs support or more information, the Alliance for Health Equity would be happy to connect you to PIF-IL or other hospital colleagues with expertise. The healthcare/public health comment guidance we put together as PIF-IL includes information on both healthcare/Medicaid and food/SNAP. Our staff will submit a comment on behalf of the Alliance for Health Equity.
Comments from individuals – please share widely with colleagues!
Comments on the public charge proposal must be submitted by Monday, December 10. All comments must be unique. While organizational comments are important, individual comments are just as important and help to multiply the overall number of comments. Also, comments from providers who can speak to the personal impact and broader public health impact are very important in this process.
More information: The Department of Homeland Security has published a proposed rule that would redefine what being a “public charge” means and would expand what programs are considered in “public charge” determination. The proposed changes would have harmful effects on health care, housing, and food access for immigrant families. Comments on the public charge proposal must be received by December 10, 2018. All comments must be unique. https://protectingimmigrantfamilies.org/
Guidance from PIF-IL and ICIRR:
General best practices for everyone:
- Don’t discuss the programs that are not specifically included in the rule
- Do oppose the expansion of the rule to include any additional programs, not just the program that matters most to you.
- Do express your views and concerns clearly
If you’re commenting in your personal capacity:
Write comments in your own words. Talk about your own experience and viewpoint.
Focus on aspects of your personal/family context that inform your opinion. These may include your own immigration story, your immigrant parents or grandparents, and personal experience being working-class and/or using public programs. For example:
“I am an immigrant from El Salvador who worked as a janitor for 10 years before starting my own business.”
“I wouldn’t be here if these standards had been in place decades ago. My father came to America from Hungary in 1942 with nothing but a suitcase, and he worked two jobs to put my sisters and me through college. We’re now a doctor, a college professor and an engineer.”
“I got pregnant when I was 21, and I relied on Medicaid to keep myself and my daughter healthy, even as I worked two jobs.” Flesh out your story and explain why the public charge proposal goes against your values – and against fundamental American values. If you are concerned that this rule change may affect you personally, say so!
If you are commenting in your professional capacity:
Describe your organization and your position there. It is important to say what your organization does, the kinds of people it serves, and your role. Highlight relevant data about your connections to immigrants and/or to working-class families. For example:
“I am a pediatrician at Downtown Community Health Center in [City], Illinois, which provides primary care for 5,000 working-class families, about 50% of whom are immigrants and their children.”
“I am a member of the Town X School Committee. Our district has 10,000 students, more than half of whom qualify for free or reduced-priced lunch. About 20% are immigrants, and 40% more are children of immigrants.”
“I am executive director of the Pilsen Women’s Collaborative, an immigrant-led nonprofit that helps women learn English, gain job skills and advance socio-economically.” If you have special expertise or credentials, describe them. For example: “I have a Ph.D. in public health and have published extensively on links between SNAP and school success.” “I have 20 years’ experience teaching in urban high schools.” If you work directly with immigrants, describe their context: What countries do they come from? What kinds of jobs do they have? What do you know about how hard they work, why they came to the U.S., their economic situation, and the role, if any, that public benefits play in their families’ lives? Why, specifically, are you concerned about public charge? This is a two-part question: the implications of the proposal itself – e.g. that a mother seeking a green card could be denied because she was on Medicaid while pregnant – and the widespread fear that the proposal has caused. Dig into each as relevant to your work, providing concrete examples (“20 of my patients have disenrolled from Medicaid out of fear, leaving themselves without access to much-needed treatment for chronic diseases such as diabetes and high blood pressure”). Make sure to distinguish between facts and misinformation. For example, the rule would not penalize parents for benefits received by their U.S. citizen children, or for participating in certain programs (e.g. WIC).
Do you have personal reasons to oppose this proposal? Even if you’re submitting comments in your professional capacity, feel free to include your personal perspective as well. Many doctors who treat immigrant patients, e.g., are immigrants or children of immigrants themselves. That’s relevant, too. See guidance for personal comments above.
If you have any additional questions about public charge, please email Andi Goodall at Andi.Goodall@iphionline.org