KVH Comments on Proposed Public Charge Rule

December 10, 2018
U.S. Citizenship and Immigration Services
20 Massachusetts Ave. NW
Washington, D.C. 20529

Kentucky Voices for Health works with consumers, health advocates, service providers, and decision-makers across the Commonwealth to advocate for policies that promote health equity through access to affordable, accessible, and quality health care for all Kentucky residents. For Kentucky’s low-income population, this includes promoting access to a Medicaid program that meets the health needs of 1.4 million children and adults as well as SNAP benefits to reduce food insecurity. We write today to oppose the proposed rule redefining “public charge” for immigration purposes by including benefits received through Medicaid, federal nutrition programs such as the Supplemental Nutrition Assistance Program (SNAP) or programs offered through Housing and Urban Development (HUD). While this policy negatively impacts immigrant families in many other ways, our opposition is specifically focused on the negative impacts on immigrant families’ health by including these vital programs.

Both SNAP and Medicaid are important work supports that allow low-income residents the ability to work in low-wage jobs or search for work while meeting basic nutritional and health care needs. This new rule creates a chilling effect that will drive both adults and children away from these programs and cause serious consequences as a result. In Kentucky, application assisters are already hearing from many of the immigrant households they serve that they no longer feel safe applying for benefits which members of their family are legally entitled to receive.

Without Medicaid coverage, individuals cannot access preventive and basic health care, leading to increases in utilization of charity care and costly emergency room services when health issues become urgent or emergent. The loss of Medicaid coverage would be especially harmful to pregnant women and individuals with special health care needs.

A loss of SNAP benefits would increase food insecurity and further exacerbate these health impacts. Food insecurity is associated with some of the most common and costly health problems in the U.S., including diabetes, heart disease, obesity, hypertension, chronic kidney disease, and depression. Restricting access to SNAP would eliminate the health benefits participants get from the program.[1] Additionally, food insecurity and related health problems are immensely costly; the U.S. had $178 billion in avoidable healthcare, educational, and lost work productivity costs attributable to hunger and food insecurity in 2014. Restricting access to SNAP would simply increase avoidable costs attributable to hunger and food insecurity.[2]

The inclusion of HUD programs, including the Section 8 Housing Choice Voucher Program, Project-Based Section 8 Rental Assistance, and Public Housing will also create negative impacts in the lives of immigrant families. Like SNAP and Medicaid, KVH fears that families who would not be impacted will be frightened away from them due to confusion and panic caused by the proposed rule changes. Studies show stable housing is a strong determinant of physical health, mental health, and ability to keep a job.[3] For children, negative impacts include increased poverty, increased homelessness, and decreased long-term educational success.[4]

This rule is not about keeping out bad actors or undocumented immigrants. This is about families who have come to the United States legally, work, pay taxes, and contribute to our communities. The Department should not cause harm to these families and their communities simply because they need some additional—often temporary—help. We implore the Department for Homeland Security to reexamine its own data into the multiple negative consequences this new policy would inflict upon immigrants and their children and take the more compassionate step of leaving this policy as it currently exists. Thank you for your time and attention in this matter.


Emily Beauregard
Executive Director

Sheila Schuster, PhD
Board Chair

[1] Food Research & Action Center. (2017). The Impact of Poverty, Food Insecurity, and Poor Nutrition on Health and Well-Being. Available at: https://www.frac.org/wp-content/uploads/hunger-health-impact-poverty-food-insecurity-health-well-being.pdf. Accessed on October 5, 2018.
[2] Ibid
[3] E.g., Meredith Horowki, Housing Instability and Health: Findings from the Michigan Recession and Recovery Study, National Poverty Center Policy Brief #29 (March 2012), https://www.npc.umich.edu/publications/policy_briefs/brief29/NPC%20Policy%20Brief%20-%2029.pdf; Matthew Desmond and Carl Gersheson, Housing and Employment Insecurity Among the Working Poor, Soc. Problems 1 (2016), available at https://scholar.harvard.edu/files/mdesmond/files/desmondgershenson.sp2016.pdf?m=1452638824https://pediat rics.aappublications.org/content/early/2018/01/18/peds.2017-2199 (finding that housing instability can lead to employment insecurity).
[4] See Will Fischer, Research Shows Housing Vouchers Reduce Hardship and Provide Platform for Long-Term Gains Among Children, Center on Budget and Policy Priorities (October 7, 2015), ; see also Linda Giannarelli et al., Reducing Child Poverty in the US: Costs and Impacts of Policies Proposed by the Children’s Defense Fund (Jan. 2015), available at https://www.childrensdefense.org/library/PovertyReport/assets/ReducingChildPovertyintheUSCostsandImpactsofPol iciesProposedbytheChildrensDefenseFund.pdf.