WAWH Submits Comments to DHS on Public Charge Rule

12/10/2018

December 10, 2018

The Wisconsin Alliance for Women’s Health (WAWH) appreciates the opportunity to comment on the Department of Homeland Security’s (DHS’) Inadmissibility on Public Charge Grounds proposed rule. WAWH is a state-based organization that advocates for public policies to promote the health, economic security, and safety of Wisconsin women and girls.

We strongly oppose the proposed rule because it would erect insurmountable barriers to the ability of immigrants and citizens to access and use Medicaid and other public benefit programs for which they are lawfully eligible. The proposed rule would drastically change the definition of what it means to be a “public charge” by considering immigrants’ use of public benefits beyond those used for subsistence. It would improperly penalize immigrants who use public benefits to augment their standard of living and ultimately achieve self-sufficiency. The proposed rule would also create a widespread chilling effect whereby both immigrants and citizens, especially women and citizen children, disenroll from or forego enrollment in public benefits. The resulting effects would needlessly harm individuals’ and families’ health and well-being, the greater public health, the U.S.
economy, and the public budget.

Further, the proposed rule would undo decades of policy work that improved benefits administration and eligibility processes for such programs. Streamlined enrollment and access to public benefits such as Medicaid have had a positive impact on public health. In particular, Medicaid and health related public benefits programs improve both individual quality of life and population health of the U.S. No person should have to question whether accessing the health care they need will adversely impact their immigration status or ability to remain in the U.S.

Given the proposed rule’s significant detrimental effects, its contravention of established law and practice, and its lack of supporting evidence, DHS should immediately withdraw its proposed rule.

View our full comments here: