Dear Secretary Noem,
We appreciate the opportunity to respond to the Interim Final Rule (IFR) on “Alien Registration Form and Evidence of Registration” published on March 12, 2025, which completely fails to acknowledge the sweeping administrative, fiscal, and health costs posed by its implementation. As pediatricians and child health experts, we urge the Department of Homeland Security (DHS) to immediately rescind the IFR and eliminate in its entirety this unnecessary, highly costly and irreparably harmful new registration requirement.
Children’s HealthWatch is a network of pediatricians, public health researchers, and policy and child health experts who examine how public policies affect the health and well-being of young children. The mission of Children’s HealthWatch is to achieve health equity for young children and their families by advancing research to transform policy. We accomplish this mission by interviewing caregivers of young children in emergency departments and primary care clinics in five cities: Boston, Minneapolis, Little Rock, Baltimore, and Philadelphia. Since 1998, we have interviewed more than 75,000 caregivers and analyzed those data to determine the impact of public policies on the health and development of young children. More than 25 percent of the young children in this dataset have immigrant mothers, mirroring national statistics that nearly one in four children age 0-5 in the US has at least one immigrant parent.1
Forcing immigrant children to register with the government will undoubtedly harm, and even criminalize, undocumented children, including unaccompanied children in government custody. It will be especially harmful for children with disabilities, Black and Brown children, children with limited English proficiency, and children who are victims of trafficking or other crimes. All children, regardless of citizenship status, deserve to live with their families in stable homes free of fear.
Comprehensive evidence demonstrates that forced family separations, economic instability, and the constant fear of deportation harm children’s mental and physical health impede their educational progress and undermine the nation’s long-term prosperity. The formation and requirements of the registration system are not only unprecedented but also counterproductive to the nation’s goals of promoting family stability and economic growth.
For hundreds of years, the United States has welcomed immigrants and their dream for a better, more prosperous life. However, policies of fear and punishment do not build a brighter future for American communities with healthy people and strong workers; to the contrary, such policies will compromise the health of current and future generations, diminish their ability to excel in school, work and life, and diminish the potential of communities across the nation.
Based on our expertise in child health and development, we know that immigration enforcement measures like those established in the IFR will have long term negative impacts on the health of all children, including young children and those who are US citizens. In addition, these rules affect the well-being of entire communities. With this knowledge, we write in strong opposition to the IFR’s creation of a new process for the registration of immigrant children and their families.
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