December 8, 2018
Submitted via www.regulations.gov
Samantha Deshommes, Chief
Regulatory Coordination Division, Office of Policy and Strategy
U.S. Citizenship and Immigration Services
Department of Homeland Security
20 Massachusetts Avenue NW
Washington, DC 20529-2140
Re: DHS Docket No. USCIS-2010-0012, RIN 1615-AA22, Comments in Response to Proposed Rulemaking: Inadmissibility on Public Charge Grounds
Dear Ms. Deshommes:
I am writing on behalf of The Parent-Child Home Program National Center to express our strong opposition to the Department of Homeland Security’s Notice of Proposed Rulemaking (NPRM) on inadmissibility on public charge grounds. The proposed rule would cause major harm to the health and well-being of young children in immigrant families – a significant share of the national population of young children – without justification. We oppose these changes because we believe that they will have a devastating effect on millions of parents and their children, limiting their ability to access stable housing, food, physical and mental health services, and educational attainment. By denying parents access to the critical health, food, and housing supports, the government risks doing irreparable damage to an entire generation of the children these parents care for, the workforce of our future. We urge that the rule be withdrawn in its entirety.
The Parent-Child Home Program (PCHP) is an evidence-based school readiness program that utilizes education to break the cycle of poverty for families. It levels the playing field, supporting a diverse population of low-income families in building school readiness and school success for their children and for others in their communities. Extensive research and evaluation demonstrates that PCHP increases parent-child interaction, and builds the critical language, literacy, and social-emotional skills needed for school readiness and school success, significantly reducing the need for special education and remedial programs when children enter school. PCHP supports access to equal opportunities and quality education right from the start, so that the all children in this country are able to succeed in school and become engaged and productive citizens.
Facts About the Families with whom Parent-Child Home Program Works:
- 60% pf PCHP families have a home language other than English, and
- 84% of PCHP families have not previously had any access to quality early childhood services; however, despite these obstacles,
- PCHP children enter school performing 10 months above their chronological age,
- PCHP graduates are 50% more likely to be ready for kindergarten than their peers, and
- PCHP children are at least 50% less likely to need special education services than their peers.
Applying the Public Charge test to an array of critical benefits that families need to survive will have very harmful consequences for young children across the country, significantly reducing access to food, proper health care, and stable housing. Because children live with their parents, restrictions on access to benefits for parents puts all children in those families at risk. Under the proposal, the Department of Homeland Security would consider an applicant’s use of benefits beyond the existing standards of cash assistance and long-term institutional care to include Medicaid, the Supplemental Nutrition Assistance Program (SNAP), housing assistance and, Medicare Part D subsidies. Just the existence of the proposal is already having a chilling effect, leading parents, many of whom are parents of US citizens, to withdraw from benefit programs that support their health, well-being, and financial security. The added standards for income, health, English language proficiency, and other factors in the proposal will make it even harder for low-income immigrant parents to provide for the well-being and stability of their children.
While only the use of benefits by an individual would be considered under the proposed rule, and not their dependents, it is very important to acknowledge that this rule cannot be implemented without direct harm to children, most of whom are US citizens. The direct harm is caused not only because the well-being of parents’ is a critical determinant of children’s health and development, but also because children could directly lose access to adequate food and a roof over their head both of which are key to children’s ability to thrive.
Already states and communities across the country are experiencing the disenrollment of parents from SNAP, Medicaid, and housing assistance benefits, and the chilling effect of this proposal is also keeping parents from accessing programming for which their children are eligible, including early education services. We are seeing Parent-Child Home Program families ceasing to access SNAP benefits, leaving them with insufficient food to nourish themselves and their children, and due to the powerful chilling effect of this proposal rule also hesitating to enroll their children in pre-kindergarten and other early childhood programs. Not accessing needed food and nutrition resources poses severe health risks to young children, it interferes with their normal development and their ability to grow and learn, increasing the need that they will need additional developmental and educational supports when they enter school. As PCHP knows from five decades of experience, instability in the home environment – homelessness, hunger, stress – can interfere significantly with early childhood development and can have a lifelong impact on the children involved. In addition, not accessing early childhood education programming reduces the chances that children will enter elementary school ready to be successful, and substantially increases the burden on remedial services once those children begin school. Our country, communities, and children and their parents of all backgrounds deserve better.
In New York, where PCHP is headquartered, the proposed changes to the Public Charge would impact 645,000 children, and nationally they would impact over 9.2 million children (source: Fiscal Policy Institute 2018). This is an extraordinary and untenable number of lives to put at risk, and could have severe national consequences as we all experience the impact of families not accessing out of fear or not being able to access needed health care, food, and shelter.
The proposal to expand the public programs to be considered in a public charge test would cause unprecedented damage to the health and well-being of millions of young children. In response to the questions posed to the public, no additional programs should be considered in the public charge determination because of the harm that would be inflicted on children, families, communities, and our nation’s future. For many of these same reasons, PCHP also adamantly opposes the inclusion of CHIP in a public charge determination. CHIP ensures that children have access to the health care they need to grow into healthy, productive adults. It ensures use of critical preventive services that are much more cost effective than paying for both emergency health care and the adult ramifications of neglecting the health of young children. This action would further exacerbate the harmful impacts of this rule by extending its reach further, leading to many eligible children foregoing health care benefits, both because of a direct inclusion in the public charge determination and because of the chilling effect discussed above.
For all the above reasons, the Parent-Child Home Program strongly opposes the public charge proposed rule and urges the Department of Homeland Security to immediately withdraw the proposed rule in its entirety. The policy will harm millions of families by undermining access to essential health, nutrition and shelter, severely damaging the lives of too many children and the future of the entire nation. Thank you for your consideration of these comments.
Very truly yours,
Sarah E. Walzer