December 19, 2025
The Honorable Kristi Noem Secretary of Homeland Security Washington, D.C. 20528
RE: DHS Docket No. USCIS-2025-0304, U.S. Citizenship and Immigration Services
Thank you for the opportunity to submit comments on the Department of Homeland Security (DHS) notice of proposed rulemaking (NPRM), “Public Charge Ground of Inadmissibility”, published in the Federal Register on November 19, 2025. On behalf of Children’s HealthWatch, we write in strong opposition to the NPRM and urge DHS to immediately withdraw its proposal and leave the current regulations, as codified in the 2022 rule, in effect.
Children’s HealthWatch is a nonpartisan network of pediatricians, child health researchers, and policy experts who examine how policy decisions affect the health and well-being of young children and their families. We accomplish this by interviewing caregivers of young children in emergency departments and primary care clinics in four U.S. cities: Boston, MA; Minneapolis, MN; Little Rock, AR; and Philadelphia, PA. Since 1998, we have interviewed more than 80,000 caregivers and analyzed those data to determine the impact of policy decisions on the health and development of young children.
Children’s HealthWatch is deeply alarmed by DHS’ proposal to rescind the 2022 public charge rule and grant the agency broad authority to deny permanent residency based on any past or future use of safety net programs, as well as an applicant’s health characteristics. In the absence of clear, consistent guidelines, this proposal would create significant gaps and inconsistencies in how public charge determinations are made – including for family members who are not seeking adjustment of status. Such uncertainty, coupled with broader attacks on immigrant families, will foster fear and confusion, encourage arbitrary decision-making, and threaten the health and economic stability of millions of families who live, work, and raise children in the U.S.