Children’s HealthWatch’s Public Comment on Public Charge

Dear Director Cissna:

Thank you for the opportunity to comment on the Department of Homeland Security (DHS)’s Notice of Public Rule Making (NPRM) for “Inadmissibility on Public Charge Grounds” published on October 10, 2018. On behalf of Children’s HealthWatch, a network of pediatricians, public health researchers, and policy and child health experts, please accept these comments and our opposition in the strongest possible terms to this rule change that will threaten the health and well-being of families of immigrants, including children.1

Children’s HealthWatch is committed to improving children’s health in America. Every day, in urban hospitals across the country, we collect data on children ages zero to four, many of whom are from families experiencing economic hardship. Over the past 20 years, we have surveyed more than 65,000 caregivers. We analyze our data and release our findings to researchers, legislators, and the public to inform public policies and practices that can give all children and their families equal opportunities for healthy, successful lives.

Lifelong health and well-being have their roots in early childhood, thus to ensure strong communities, all young children and their families need to meet their basic needs, such as adequate healthy food, a decent, affordable and stable home, utilities to keep them safe and healthy, and affordable high-quality health care.

Immigrant families are an integral part of our communities — they are our neighbors, coworkers, friends, and fellow parents. The changes detailed in this rule threaten our country’s health as it forces immigrant families to choose between providing basic necessities that keep children healthy, like food, shelter, and medical care, and having their family remain together in
the United States. The proposed rule marks a significant and harmful departure from current rules by expanding the list of programs that may be considered when determining public charge and requiring immigrants, not just their sponsors, to earn at least 125 percent of the federal poverty line.