Submit Your "Public Charge" Comments By Dec. 10, 2018


Since the beginning of this year, we have seen our communities negatively affected by misinformation surrounding the Trump administration’s proposed public charge rule. On October 10, 2018,  the Trump administration published its long-feared proposal in the federal register. As rumors of changes to the rule spread, we saw families begin to voluntarily pull back from programs that provide assistance in accessing health care, food, and housing. U.S. immigration policy has long allowed government officials to deny visas or permanent residency to  immigrants who they project will become dependent on the state - or a "public charge.” Under the proposed changes to this rule, immigrants who legally access a number of social services that support hard-working, low-income immigrant families, could now also be denied a green card or refused admission to the United States. These changes are directly aimed at low-income, non-English speaking immigrants and are intended to make it harder for low income immigrants to be reunited with their family members and block their path to residency. 


The impact of this rule change if it were adopted would be devastating to many low income immigrants and their families. However, because of misinformation, just the possibility of this change is already having a “chilling effect” on vast number of immigrants who would not be affected by the rule change. In other words, low-income immigrants are already avoiding services needed for the health and well-being of their families out of fear. Experts project a substantial chilling effect – those that may drop or not apply for benefits because they believe they will be affected by the new rule -- of 25 million people currently living in the US. The majority of those to be impacted would be US citizen children, who account for a quarter of all U.S. children.

The impact of the proposed change goes beyond social and moral ramifications. It also has the potential for a tremendous economic impact. According to the Fiscal Policy Institute, a 25% disenrollment from programs immigrants are otherwise qualified to receive would result in:

  • $12 billion loss of federal funds in supports to families across the country
  • A negative ripple effect through the economy of about $24 billion
  • Approximate loss of 164,000 jobs

While Latino and other immigrants make significant contributions to the economy, many continue to struggle to get their basic needs met. Many of the programs targeted by this rule have helped millions of Latinos lift themselves out of poverty:

  • 21% of Latino households received SNAP in the last year
  • Approximately 32% of Latinos are covered by Medicaid
  • About 740,000 Latino households received federal rental assistance in 2015


One major thing we must remember is that the rule has not gone into effect! The existing public charge guidance is still in place until a new rule is finalized. We must do everything in our power to fight this rule change and protect our community. We can still fight this! The federal government is accepting comments to this proposed rule until December 10, 2018. Under the rulemaking process, the government must respond to all comments received. Our members, clients, and students are counting on us to submit organizational comments to stop this rule from becoming final. Your comment has the power to slow down the rulemaking process and help shape any rule change that may occur to protect immigrant families.


For individuals:

  • Make the comments your own
  • If you are an expert, highlight your qualifications
  • If you are a concerned individual, highlight why you care
  • Include a relevant personal story — your own or someone else’s (if you use their name, get permission) about how the rule will affect your ability to work and provide for yourself or your family
  • Highlight relevant data and research
  • Provide a translation of non-English comments
DO NOT sign on to comments from someone else (A sign-on letter with 10 signatures would only be counted by the agency as one comment. If those 10 people were to each send in their own comment that would count as 10 comments); DO NOT copy someone else’s comments verbatim.

For organizations:
  • Please note that identical comments are counted as one comment. For example, if 10 organizations sign onto a comment, that is counted as one comment. If agency A and agency B submit identical comments separately, those are counted as one comment. It is recommended that at least 30% of the comment is unique material.  
  • Comment templates are meant to provide information, but you have a powerful story to tell. Modify the comments to include information about your organization, clients, and share your organization’s perspective on how the proposed rule would impact your community.  
  • Comments must be relevant to be considered. Your comments should explain how taking away the ability to use these public services would harm your organizational members and community


Click on any of these links to submit your comments:

How to submit organizational comment (deadline: December 10, 2018):

Visit the federal public charge comment portal at Click on “comment now” and either enter your comment in the text box (must be fewer than 5000 characters) or upload your comments as a PDF.

Samantha Deshommes, Office of Policy and Strategy
U.S. Citizenship and Immigration Services, Department of Homeland Security
20 Massachusetts Avenue, NW
Washington, DC 20529-2140


Shareables for your networks to help increase the number of comments submitted to fight this rule: