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USCISRulemakingUSCIS-2010-0012

Inadmissibility on Public Charge Grounds

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American Academy of Pediatrics (AAP) filings
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American Academy of Pediatrics (AAP) filed 7 comments on this docket between Nov 15, 2018 and Feb 13, 2019. 733 other organizations filed here. The comment window closed 2787d ago.

What American Academy of Pediatrics (AAP) filed (7)

Feb 13, 2019· Comment Submitted by Megan Schwartz, American Academy of Pediatrics· USCIS-2010-0012-59452

Dear Secretary Nielsen: As a pediatrician in Woodburn, Oregon, I write to offer comments on the Department of Homeland Securitys Notice of Proposed Rulemaking: Inadmissibility on Public Charge Grounds (DHS Docket No. USCIS-2010-0012). Pediatricians are dedicated to the health, safety, and well-being of all infants, children, adolescents, and young adultsno matter where they or their parents were born. If finalized, the proposed rule on public charge would put the health of millions of children and families at risk. I urge you to rescind this rule and instead craft policies that allow immigrant children and families to be healthy and safe. The policies proposed in this rule would deter immigrant families from accessing health and human service programs that keep them healthy and productive like Medicaid and the Supplemental Nutrition Assistance Program (SNAP). For many months, pediatricians have seen parents forgoing vital services to keep themselves and their children healthy out of fear that using such programs jeopardizes their chances of getting a visa or green card. I see many patients every day who rely on WIC services to supplement their nutrition. WIC provides a vital piece of education for patients and families. We also see patients who let Medicaid lapse and area afraid to come in to clinic to receive childhood vaccinations due to fear of being billed. If this proposed rule were to be finalized, families will continue to avoid seeking services for which they are eligible, like health insurance and food assistance. Widespread confusion about which benefits are and are not included in a public charge determination would also lead to families avoiding programs that are not part of this proposed rule. This chilling effect would jeopardize the health of millions of families. In my state of Oregon, there are 440,847 children enrolled in Medicaid in FY17. Medicaid helps children stay healthy and reach their full potential. For example, children with Medicaid are twice as likely to have routine check-ups and vaccinations than uninsured children. They are also more likely to receive proper treatment for chronic conditions and less likely to have avoidable hospitalizations. Patients on Medicaid get their lead and iron levels checked as toddlers to make sure their levels are appropriate. Medicaid allows for sports physicals that are necessary for school sports in addition to the regular check-ups to monitor growth and development. Further, the health of children is inextricably linked to the health of their parentschildren do better when their parents are mentally and physically healthy. Parents who are enrolled in health insurance are more likely to have children who are insured too. Disenrollment from health insurance by parents will result in a loss of coverage and access to preventive health care for their children. Nutrition assistance programs also help children grow up strong. Children who are hungry and live in households where food is scarce have difficulty learning, and are more likely to experience educational, health, and behavioral problems as a result. Children of immigrants who participate in SNAP are more likely to be in good or excellent health, be food secure, and reside in stable housing. We have multiple patients come to clinic complain of abdominal pain secondary to hunger. SNAP services are an excellent resource so that my patients can avoid hunger. The impact of this rule is enormous and presents immigrant families with an impossible choice: keep yourself or your children healthy but risk being separated, or forgo vital services like preventive care and food assistance so your family can remain together. One in every four children in the United States lives in an immigrant family, meaning that the child or at least one parent is foreign-born. I work at Federally Qualified Health Clinic that is primarily focused on immigrants and migrant workers. Nearly 60-70% of our population are migrant farm workers a…

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Feb 5, 2019· Comment Submitted by Marguerite Oetting, Iowa Chapter of American Academy of Pediatrics· USCIS-2010-0012-42787

Filed on regulations.gov — full text not in the inline record.

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Feb 5, 2019· Comment Submitted by Mary Rimsza, Arizona Chapter of the American Academy of Pediatrics· USCIS-2010-0012-45826

Dear Secretary Nielsen, The Arizona Chapter of the American Academy of Pediatrics, which represents over 900 pediatricians in the state of Arizona, offers the following comments on the Department of Homeland Securitys Notice of Proposed Rulemaking: Inadmissibility on Public Charge Grounds (DHS Docket No. USCIS-2010-0012). In Arizona, there are 902,742 children enrolled in Medicaid in FY17. Medicaid helps children stay healthy and reach their full potential. If finalized, the proposed rule on public charge would put the health of millions of children and families at risk because the policies proposed in this rule would deter immigrant families from accessing health and human service programs that keep them healthy and productive like Medicaid and the Supplemental Nutrition Assistance Program (SNAP). We I urge you to rescind this rule and instead create policies that allow immigrant children and families to be healthy and safe. Pediatricians in Arizona have seen parents forgoing vital services to keep themselves and their children healthy out of fear that using such programs jeopardizes their chances of getting a visa or green card. If this proposed rule were to be finalized, families will continue to avoid seeking services for which they are eligible, like health insurance and food assistance. Widespread confusion about which benefits are and are not included in a public charge determination would also lead to families avoiding programs that are not part of this proposed rule. This chilling effect would jeopardize the health of millions of families nationwide. We know that children with Medicaid are twice as likely to have routine check-ups and vaccinations as uninsured children. They are also more likely to receive proper treatment for chronic conditions and less likely to have avoidable hospitalizations. One in four Arizona children lives with an immigrant parent. The health of children is linked to the health of their parents and children do better when their parents are mentally and physically healthy. Parents who are enrolled in health insurance are more likely to have children who are insured too. Disenrollment from health insurance by parents will result in a loss of coverage and access to preventive health care for their children. Nutrition assistance programs also help children grow up strong. Children who are hungry and live in households where food is scarce have difficulty learning, and are more likely to experience educational, health, and behavioral problems as a result. Children of immigrants who participate in SNAP are more likely to be in good or excellent health, be food secure, and reside in stable housing. As pediatricians, we are dedicated to the health, safety, and well-being of all infants, children, adolescents, and young adultsno matter where they or their parents were born. The impact of this rule is enormous and presents immigrant families with an impossible choice: keep yourself or your children healthy but risk being separated, or forgo vital services like preventive care and food assistance so your family can remain together. We strongly urge you to rescind this rule and to not consider use of public benefits programs like SNAP and Medicaid in public charge determinations. Sincerely, Mary Ellen Rimsza, MD, FAAP AzAAP Advocacy Committee Chair

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Feb 5, 2019· Comment Submitted by Richard Ward, Georgia Chapter--American Academy of Pediatrics· USCIS-2010-0012-47835

See attached document from the Georgia Chapter--American Academy of Pediatrics; Terri McFadden, MD, FAAP, President

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Nov 29, 2018· Comment Submitted by Sharon Swindell, President, Michigan Chapter, American Academy of Pediatrics· USCIS-2010-0012-13189

Dear Secretary Nielsen: As a pediatrician practicing in Ypsilanti, Michigan and I also serve as the P{resident of the Michigan Chapter of the American Academy of Pediatrics. I write to offer comments on the Department of Homeland Securitys Notice of Proposed Rulemaking: Inadmissibility on Public Charge Grounds (DHS Docket No. USCIS-2010-0012). Pediatricians are dedicated to the health, safety, and well-being of all infants, children, adolescents, and young adultsno matter where they or their parents were born. If finalized, the proposed rule on public charge would put the health of millions of children and families at risk. I urge you to rescind this rule and instead craft policies that allow immigrant children and families to be healthy and safe. The policies proposed in this rule would deter immigrant families from accessing health and human service programs that keep them healthy and productive like Medicaid and the Supplemental Nutrition Assistance Program (SNAP). For many months, pediatricians have seen parents forgoing vital services to keep themselves and their children healthy out of fear that using such programs jeopardizes their chances of getting a visa or green card. I care for a number of families in which parents are immigrants but their children are U.S. citizens. Their children greatly benefit from access to care due to Medicaid but parents have become reticent to maintain these services on behalf of their children. This is of great concern to me, as I anticipate poorly controlled conditions such as asthma, creating individual costs to the child but also greater costs to society. If this proposed rule were to be finalized, families will continue to avoid seeking services for which they are eligible, like health insurance and food assistance. Widespread confusion about which benefits are and are not included in a public charge determination would also lead to families avoiding programs that are not part of this proposed rule. This chilling effect would jeopardize the health of millions of families. In my state of Michigan, there are 1,285,914 children who participate in Medicaid and CHIP. Medicaid helps children stay healthy and reach their full potential. For example, children with Medicaid are twice as likely to have routine check-ups and vaccinations than uninsured children. They are also more likely to receive proper treatment for chronic conditions and less likely to have avoidable hospitalizations. My primary care practice is in a low-income region and the majority of my patients depend on Medicaid for access to needed health care. I have many patients with asthma, complications from premature birth, heart conditions, developmental delays, and mental health challenges. The care they receive is critical in preventing costly hospitalization, missed school, and mitigation of delays that would lead to special education needs. Parents who are enrolled in health insurance are more likely to have children who are insured too. Disenrollment from health insurance by parents will result in a loss of coverage and access to preventive health care for their children. Nutrition assistance programs also help children grow up strong. Children who are hungry and live in households where food is scarce have difficulty learning, and are more likely to experience educational, health, and behavioral problems as a result. Children of immigrants who participate in SNAP are more likely to be in good or excellent health, be food secure, and reside in stable housing. The improved access to optimal nutrition affects my patients ability to fight infections and promotes healthy weight. Many of the children I care for have childhood obesity linked to access to less healthy foods. The impact of this rule is enormous and presents immigrant families with an impossible choice: keep yourself or your children healthy but risk being separated, or forgo vital services like preventive care and food assistance so your family can remain…

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Nov 27, 2018· Comment Submitted by Jean Davis, American Academy of Pediatrics· USCIS-2010-0012-12006

Dear Secretary Nielsen: I am writing to offer comments on the Department of Homeland Securitys Notice of Proposed Rulemaking: Inadmissibility on Public Charge Grounds (DHS Docket No. USCIS-2010-0012). I live in Chicago, where my children attend Chicago public schools. I work for the American Academy of Pediatrics, supporting pediatricians work in communities to promote the health, safety, and well-being of all infants, children, adolescents, and young adultsno matter where they or their parents were born. I strongly urge you to rescind this proposed rule and instead craft policies that allow immigrant children and families to be healthy and safe and contribute to their communities. The policies proposed in this rule would deter immigrant families from accessing important health and human service programs that keep them healthy and productive. Programs like Medicaid, CHIP, and the Supplemental Nutrition Assistance Program. The pediatricians I work with have been describing for many months, that they have seen parents choosing not to access important services that would keep themselves and their children healthy because they are afraid it would hurt their chances of getting a visa or green card. If this proposed rule were to be finalized, families will continue to avoid seeking services for which they are eligible, like health insurance and food assistance. Widespread confusion about which benefits are and are not included in a public charge determination would also lead to families avoiding programs that are not part of this proposed rule. This chilling effect would jeopardize the health of millions of families. In Illinois, there are over 1.7 million children enrolled in Medicaid and CHIP. These programs help children stay healthy and reach their full potential. For example, children with Medicaid are twice as likely to have routine check-ups and vaccinations than uninsured children. They are also more likely to receive proper treatment for chronic conditions and less likely to have avoidable hospitalizations. I cant imagine not having health insurance for my family. Nutrition assistance programs also help children grow up strong. Children who are hungry and live in households where food is scarce have difficulty learning, and are more likely to experience educational, health, and behavioral problems as a result. Children of immigrants who participate in SNAP are more likely to be in good or excellent health, be food secure, and reside in stable housing. Include information about how SNAP benefits your patients. In Chicago, the vast majority of children are eligible for nutrition services. I worry about the impact this would have on my kids fellow students and their ability to learn and succeed. This proposed rule would force families to make an impossible choice: help your children to grow and develop into productive citizens and risk being separated, or forgo important preventive health care and food. One in every four children in the United States lives in an immigrant family, meaning that the child or at least one parent is foreign-born. In Illinois, there are over 2 million people who are immigrants or have an immigrant parent. Two of my grandparents were immigrants, and I am very proud of their legacies. Investing in nutrition, health care, and other essential needs keeps children learning, parents working, families strong, and allows all of us to contribute fully to our communities. I strongly urge you to rescind this rule and to not consider use of public benefits programs like SNAP and Medicaid in public charge determinations. Jean Davis Chicago, IL 60631

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Nov 15, 2018· Comment Submitted by Anna Shvygin, American Academy of Pediatrics· USCIS-2010-0012-8463

I write to you as a second-year medical student who will become a pediatrician in just a few more years. I also write to you as an immigrant who came to this country ten years ago. I came here with my parents, with little more than $10,000 to our name, and had to rely on the many federal aid programs just to be able to afford food and health care. My family and I were "public charges", as you would call us, and I will be forever grateful to have been labeled as such. If I had not been a so-called public charge, I would not have gone on to study medicine, and I would not have felt the need to give back to the very people who supported my family's dream. So I urge you today to not entertain this wedge issue any longer, for it is nothing more than that. I urge you to listen to your constituents, the people of this nation, for we are the ones you represent. And I urge you to remain humane and beneficent as you remain in power, for you will be remembered by my generation for how you treat those who need your help. I will now speak to you as a future medical professional. The Universal Declaration of Human Rights states that "(1) Everyone has the right to a standard of living adequate for the health and well-being of himself and of his family, including food, clothing, housing and medical care and necessary social services, and the right to security in the event of unemployment, sickness, disability, widowhood, old age or other lack of livelihood in circumstances beyond his control." I know that the U.S. does not officially recognize the right to FOOD, CLOTHING, HOUSING, AND MEDICAL CARE as a fundamental human right; I'm sure that there is a great reason for that. But I must appeal to your humanity. Children who come to the U.S. seeking refuge from troubles they cannot control have the same, if not greater, need for medical care and proper nutrition as American children. It is not the fault of these immigrant children, nor is it the fault of the families that bring them here, that they are immigrants. Therefore, they shall not be penalized for seeking safety and prosperity by these predatory policies. If you enact this policy, you will deter immigrant families from seeking necessary medical and nutritional assistance. If you prevent these families from having these fundamental needs met, their children will grow up sicker, poorer, and less educated than their healthy peers. And children who grow up into sick adults are an even greater burden on the American economy, with easily-preventable health conditions such as heart disease, diabetes, and obesity driving healthcare spending through the roof. If you are having trouble with compassion and morality, at least consider embracing your fiscal conservatism. Best of luck.

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Abstract

The U.S. Department of Homeland Security (DHS) proposes to prescribe how it determines whether an alien is inadmissible to the United States under section 212(a)(4) of the Immigration and Nationality Act (INA) because he or she is likely at any time to become a public charge. Aliens who seek adjustment of status or a visa, or who are applicants for admission, must establish that they are not likely at any time to become a public charge, unless Congress has expressly exempted them from this ground of inadmissibility or has otherwise permitted them to seek a waiver of inadmissibility. Moreover, DHS proposes to require all aliens seeking an extension of stay or change of status to demonstrate that they have not received, are not currently receiving, nor are likely to receive, public benefits as defined in the proposed rule.

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