Children’s HealthWatch strongly opposes the U.S. Department of Housing and Urban Development (HUD) repeated attempt to deny housing assistance to families with mixed immigration status. This revived 2019 proposal continues the ongoing attacks on immigrant families and would harm the health and development of young children, increase family instability, and generate substantial and avoidable public costs. 

The proposed rule would force thousands of mixed-status families—including U.S. citizen children—to choose between family unity and housing stability. This is an untenable and harmful choice. HUD’s similar 2019 proposal, which was never finalized, estimated that 25,000 families, including 55,000 children, would have been denied housing as a result. 

More than one in four children under age five in the U.S. has at least one immigrant parent, and most of these children are U.S. citizens. A mixed status household is one which there are varying citizenship or immigration statuses, sometimes including a family member without a Social Security number. Under current law, housing subsidies for mixed-status families are prorated so that ineligible members do not receive benefits. The draft proposal would go further, denying assistance to entire households or preventing ineligible caregivers from serving as leaseholders on behalf of eligible children. As HUD’s own prior estimates indicated, the majority of those affected would be eligible children. 

Over the last 27 years, we have surveyed more than 80,000 caregivers of children ages 0–4 in urban hospitals across the country. Our research consistently shows that stable, affordable housing is foundational to child health. When families cannot meet basic needs such as housing, the consequences are immediate and long-lasting. Eviction, housing instability, and homelessness are associated with profound harms to children’s health and development. Compared to stably housed families, children in families with a history of eviction are more likely to be in fair or poor health and at risk of developmental delays. Their caregivers are more likely to report depressive symptoms and be in poor health, and their families are more likely to experience multiple economic hardships. Families with an eviction history are also far more likely to experience homelessness or repeated moves—a severe form of housing instability with devastating impacts on children’s health and development. 

HUD’s proposal would also increase the risk of family separation. Some families may attempt to preserve assistance for eligible members by splitting households. Decades of research demonstrate that family separation is a severe stressor that can disrupt brain development and have lifelong consequences for emotional and behavioral health. Public policies should reduce toxic stress in early childhood—not intensify it. 

HUD’s mission is to create strong, sustainable, inclusive communities and quality affordable homes for all. For the health and future of our nation’s children, we urge HUD to live up to its mission and immediately withdraw this proposal.

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