FF-Comments-PublicCharge-12.7.18-Final

Sep 19, 2026

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Comments submitted to U.S. Citizenship and Immigration Services oppose a proposed DHS rule that would broaden the definition of “public charge” in determinations for lawful permanent resident status and/or lawful admission. The submission argues the change would harm immigrant families with children by discouraging use of health care, nutrition assistance, and housing supports, increasing risk of reduced income, and potentially raising homelessness and food insecurity. It also criticizes new negative factors tied to household size, child age, and income thresholds while ignoring immigrants’ economic mobility over time.

LanguageEnglish

CategoryLetters

FormatPDF

Pages17

Reading Time6 min

AccessFree to download

Introduction

Proposed Changes to “Public Charge” Determinations

Impact on Children and Families

Housing and Nutrition Assistance Effects

Disadvantaging Standards for Families with Children

December 7, 2018 Submitted [via www. regulations.gov](via www. regulations.gov) [U.S. Citizenship and Immigration Services](U.S. Citizenship and Immigration Services)[ ](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 Sir/Madam: First Focus is a bipartisan advocacy organization dedicated to making children and families a priority in federal policy and budget decisions. As an organization dedicated to promoting the safety and well-being of all children in the United States, we are writing in strong opposition to the proposed rule regarding public charge determinations as published in the Federal Register. Introduction The future of our nation depends on the well-being and success of our children. They are one-quarter of our population, but all of our future. Yet child poverty remains high in the United States and costs the U.S. over $1 trillion a year, representing 5.4 percent of our GDP.1 Therefore everyone– regardless of socioeconomic status– benefits from strategies that improve child well-being. The proposed rule’s sweeping changes to long-standing, bipartisan immigration policy determining eligibility for green cards and admission to the United States would jeopardize our country’s economic future through targeting access to health care, nutrition assistance and housing support for tax-paying, legal immigrant households with children. The rule proposes to expand who may be deemed a public charge (i.e. , burden on the public coffers) in the consideration of an application for lawful permanent resident (LPR) status and/or lawful admission. The proposed rule would expand current considerations to allow government officials to consider an applicant’s use of benefits beyond the existing standards of cash assistance and long-term medical care. This represents a drastic change from the current definition to include someone who utilizes benefits for support. As a result, the determination would now include a broader range of services including Medicaid, nutrition assistance through the Supplemental Nutrition Assistance Program (SNAP) and housing assistance such as Section 8 Housing Choice Vouchers, Section 8 Project Based Rental Assistance and Public Housing. This rule will directly impact children whom themselves apply for green cards later in life unless they are asylees, refugees, or otherwise exempt. The U.S. Department of Homeland Security (DHS) acknowledges that thanks to a chilling effect--whereby fear and misinformation prompt families to avoid accessing important programs, regardless of whether participation will actually count within the public charge determination--the proposed rule will also likely impact U.S. citizen children with immigrant parents. Furthermore, there is no way to hurt immigrant parents without also harming their children. Children in households where parents are limited from accessing critical benefits will suffer from a loss of income and resources to the household that support their healthy development. FIRST FOCUS | 1400 EYE ST. NW SUITE 650 WASHINGTON, DC 20005 | INFO@FIRSTFOCUS.ORG 1 When it comes to housing assistance, there is no way to separate benefits to parents and their children who live in the same home. You cannot divide up a home or an apartment based on who is eligible for assistance, so when parents lose assistance and housing becomes unaffordable, the entire family, including children, is put at risk of homelessness. Similarly, individuals who rely on SNAP use that assistance to put food on the table for the entire family, including their children. This means that children with immigrant parents--including many U.S. citizen children--will also be harmed when their parents lose access to assistance programs and there is a loss of share

FAQs

What is the document’s main position on the proposed public charge rule?

The document strongly opposes the proposed rule, arguing that it would jeopardize immigrant families with children and undermine their access to critical supports.

Which types of benefits does the submission say could be included under the expanded public charge consideration?

It states the determination would broaden to include Medicaid, nutrition assistance through SNAP, and housing assistance such as Section 8 programs and public housing.

How does the submission argue the rule would affect children?

It argues that children would be harmed directly and indirectly because benefits tied to households cannot be separated between parents and children, and loss of assistance can lead to reduced resources, homelessness risk, and food insecurity.

Sep 19, 2026

Upload by Aran