UPDATE, December 10, 2018: The comment period for the Trump administration’s anti-immigrant “public charge” rule closes today. More than 10,000 UCS supporters submitted a petition opposing this mean-spirited policy that would punish hard-working immigrant families and undermine public health. Members of the Good Food For All collaborative also weighed in with a statement on the rule and the administration’s broader immigration policy. We will be watching for further action on this proposal in 2019.
From an ill-conceived campaign promise to build a border wall to the recent deployment of thousands of US troops to confront a non-existent “invasion,” radical immigration policy has been a hallmark of the Trump presidency. The administration has introduced a baseless Muslim travel ban; ordered a separation of families at the southern border that landed more than 2,600 children in government shelters; and suggested that children born in the US to noncitizen parents should not be granted citizenship.
Now, the administration is working to target immigrant families closer to home—at the dinner table.
The Department of Homeland Security recently requested public comments on a proposal to change longstanding immigration policy by dramatically expanding the types of public benefits that—if immigrants use them, or even if they’re deemed likely to use them in the future—would weight against their visa or green card applications. Among them are benefits from the Supplemental Nutrition Assistance Program (SNAP, formerly food stamps), which acts as the first line of defense against hunger and financial instability for millions of families in the United States. The end result? Many immigrant families—including those who work and pay taxes (which is most) and those with children born in the US—will be forced to choose between maintaining a path to citizenship and putting food on the table during hard times.
Like many of the attacks that preceded it, the proposed policy is fundamentally at odds with the values we stand for as a nation: we do not discriminate based on religion or national origin, nor do we turn our backs on those in need. Furthermore, it threatens to dramatically worsen hunger and health disparities among some of our most vulnerable populations—including children who are themselves citizens.
UCS joins thousands of organizations in strongly opposing the Trump administration’s so-called “public charge” rule. Below is the letter we submitted to the Department of Homeland Security, outlining the potential damage that could be wrought by the policy.
UCS Submits Public Comment to DHS on Proposed Public Charge Rule, “Inadmissibility on Public Charge Grounds; Notice of Proposed Rulemaking”
November 9, 2018
The Union of Concerned Scientists (UCS) is a science-based nonprofit seeking solutions to our planet’s most pressing problems—from combating global warming and developing sustainable ways to feed, power, and transport ourselves, to fighting misinformation, advancing racial equity, and reducing the threat of nuclear war. Immigration has always been and remains a critical source of America’s unparalleled scientific leadership; the diversity it brings is central to creating effective and meaningful solutions to our nation’s problems. It also enriches our lives in innumerable ways. We therefore submit this comment to express strong opposition to proposed sweeping changes by the Department of Homeland Security (DHS) to US immigration law and the definition of a “public charge.” This proposed rule defies evidence and would prove devastating to many immigrant families—including those whose children are citizens of the United States—who could be forced in hard times to choose between meeting their daily needs and maintaining a path to citizenship.
Our opposition to the aforementioned policy and programmatic changes is grounded in the following:
- Data refute the notion that immigrant families rely disproportionately on all forms of public assistance. In 2017, the National Academies of Sciences, Engineering, and Medicine examined the economic implications of immigration. Among other findings, the resulting report revealed that just 4.2 percent of immigrant households with children utilize housing assistance—which would be newly considered in determining public charge under the proposed rule—compared with 5.3 percent of US-born households., Data based on individual, rather than household participation shows that US-born populations use programs like SNAP and Medicare at higher rates than either naturalized citizens or noncitizen immigrants after adjusting for poverty and age., The proposed rule would unjustifiably bring harm to working families who are eligible for these programs—with potential lasting consequences for the long-term health and economic vitality of their communities.
- The proposed rule would deter participation in programs such as Medicaid, which returns proven benefits for the long-term health, achievement, and economic success of children. The future of our country depends in part on the wellbeing and economic success of its children—about one in four of whom lives with at least one immigrant parent. Research shows that participation in Medicaid not only helps children become healthy adults, but also leads to greater academic achievement and later economic success. Children with access to Medicaid have lower rates of high blood pressure, hospitalizations and emergency room visits as adults; are less likely to drop out of high school; and have higher incomes later in life—contributing a strong return on investment in the Medicaid program. One study reviewing Medicaid expansion during the 1980s and 1990s estimated that, based on children’s future earnings and tax contributions alone, the government would recoup 56 cents of each dollar spent on childhood Medicaid by the time the children turned 60.
- The proposed rule penalizes working families whose most accessible employment opportunities are often low-wage and lack benefits, such as health insurance. Research shows that the majority of children of immigrants live in households in which both parents are working yet are employed in lower-paying jobs without employer-sponsored health insurance., The food industry is among those that relies heavily on immigrant labor to fill low-wage jobs, from agricultural production to food distribution and service. Food workers make up about 14 percent of the nation’s workforce, and approximately one-fifth are foreign born. The proposed rule would compromise workers’ abilities to feed and care for their own families—even while many work in roles that uphold our food system as we know it.
- The proposed rule risks worsening hunger and health disparities among vulnerable populations—including children—by deterring participation in effective nutrition programs. Already, social service providers have noted decreases in immigrant participation in major safety net programs stemming from fears of risking green cards or eventual citizenship. Representatives from WIC (Special Supplemental Nutrition Program for Women, Infants, and Children) agencies in states across the country reported reduced program participation following the first release of the draft rule. Though WIC has since been removed from the proposed rule, SNAP remains. Lingering fears are likely to deter immigrant families’ participation in both of these critical programs that prevent hunger and maintain health while families work toward regaining financial stability. Children of immigrant parents, already more likely to experience food insecurity than children of US-born parents, would face greater risk of hunger and poor health without assistance from these programs. Young children’s participation in SNAP is linked to lower rates of obesity and metabolic syndrome in adulthood, as well as higher rates of high school completion.
- The proposed rule would undermine the core function of the social support programs that comprise the federal safety net, which protects us all from the unexpected. The safety net is designed to protect children and adults from the devastating consequences of food insecurity, lack of healthcare, and financial instability in the face of unpredictable events such as job loss, family illness, or other crisis. These are circumstances that can befall any family unexpectedly. The proposed consequential changes to long-standing immigration policy based on a subjective evaluation of factors such as age, health, financial status, and education would have the negative side effect of preventing immigrants’ use of major safety net programs altogether. Such changes run counter to the purpose of the safety net and would undermine its effectiveness at safeguarding individual families, entire communities and the nation as a whole. When people in our country are poorer and sicker, we all lose.
- The apparent rationale of the proposed rule flies in the face of core American values. Effectively requiring immigrants to demonstrate they have the resources to meet any current or even future need for assistance as a precondition to legal immigration and citizenship is contrary to America’s founding core as a refuge, as well to our nation’s ideals of equality, justice, and self-determination. Furthermore, in institutionalizing policies with consequences that will be overwhelmingly borne by people of color, the proposed rule threatens to reinforce racist and anti-immigrant sentiments that degrade our country and cause immeasurable harm to citizens and non-citizens alike.
UCS appreciates the opportunity to comment on this proposed rule. In expressing our strong opposition to the proposal, we join the thousands of organizations across the country who have voiced similar objections. The sweeping changes to immigration policy proposed in this rule would exacerbate hunger and health disparities, particularly among children of immigrants; cause harm to all our communities; deny our country the benefits that immigrants bring; and signal to the rest of the world that our society has abandoned our core American values of decency, hard work, and opportunity for all.
Thank you for your consideration.
 National Academies of Sciences, Engineering, and Medicine. 2017. The Economic and Fiscal Consequences of Immigration. Washington, DC: The National Academies Press.
 Immigrant households are based on the head of household’s immigrant status (where the head of household is considered immigrant if they are not a citizen or are a naturalized citizen).
 Nowrasteh, A. and R. Orr. 2018. Immigration and the welfare state: Immigrant and native use rates and benefit levels for means-tested welfare and entitlement programs. Washington, DC: Cato Institute.
 Supplemental Nutrition Assistance Program
 The Annie E. Casey Foundation. 2018. Children in immigrant families. Baltimore, MD. Online at https://datacenter.kidscount.org/data/tables/115-children-in-immigrant-families?loc=1&loct=1#detailed/1/any/fal, accessed October 19, 2018.
 Chester, A. and J. Alker. 2015. Medicaid at 50: A look at the long-term benefits of childhood Medicaid. Washington, DC: Center for Children and Families. Online at https://ccf.georgetown.edu/2015/07/27/medicaid-50-look-long-term-benefits-childhood-medicaid/, accessed October 19, 2018.
 Brown, D.W., A.E. Kowalski, I.Z. Lurie. 2015. Medicaid as an investment in children: What is the long-term impact on tax receipts? NBER Working Paper Series. Cambridge, MA: National Bureau of Economic Research.
 The Annie E. Casey Foundation. 2018. Children with all available parents in the labor force by family nativity. Baltimore, MD. Online at https://datacenter.kidscount.org/data/tables/5060-children-with-all-available-parents-in-the-la-bor-force-by-family-nativity?loc=1&loct=1#detailed/1/any/false/870,573,869,36,868,867,133,38,35/78,79/11478,11479, accessed October 19, 2018.
 Earle, A., P. Joshi, K. Geronimo, et al. 2014. Job Characteristics Among Working Parents: Differences by Race, Ethnicity, and Nativity. Monthly Labor Review. Washington, DC: Bureau of Labor Statistics.
 Food Chain Workers Alliance and Solidarity Research Cooperative (FCWA/SRC). 2016. No piece of the pie: US food workers in 2016. Los Angeles, CA: Food Chain Workers Alliance.
 Baumgaertner, E. 2018. Spooked by Trump Proposals, Immigrants Abandon Public Nutrition Services. The New York Times, March 6.
 Chilton, M. et al. 2009. Food insecurity and risk of poor health among US-born children of immigrants. American Journal of Public Health 99(3): 556-562.
 Council of Economic Advisers (CEA). 2015. Long-term benefits of the Supplemental Nutrition Assistance Program. Washington, DC: Executive Office of the President of the United States.
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