Children’s HealthWatch Comments on the Department of State’s interim final rule, “Visas: Ineligibility Based on Public Charge Grounds”

On January 14, 2022, Children’s HealthWatch submitted comments on the Department’s of State’s interim final rule, “Visas: Ineligibility Based on Public Charge Grounds,” published in the Federal Register on November 17, 2021.

As pediatricians and public health researchers, we are acutely aware of the harmful health and economic consequences resulting from long-standing exclusions of immigrant families from public programs as well as increased immigration and enforcement actions – including the 2019 public charge rule. These policies threaten the health and well-being of immigrant families, specifically children. As such, we are gravely concerned about the culture of fear that has been perpetuated by policies that target immigrants across the United States, including families with young children. Research has demonstrated the damaging effects of both the culture of fear and discriminatory policies on increasing family economic hardship and harming health.

Access to financial support necessary to meet basic needs is essential for the health and development of children and the well-being of their families. For these reasons, it is critical that DOS move forward quickly to remove the text of its October 2019 rule from the Code of Federal Regulations and restore the longstanding regulatory text that appeared prior to DOS’ October 2019 rule. This approach clarifies a currently confusing DOS policy landscape and minimizes harm to children in immigrant families who are currently often deterred from seeking critical government services. Furthermore, this recommendation is aligned with that of the Protecting Immigrant Families campaign, whose sign-on comment we have endorsed along with hundreds of national, state, and local groups.