Georgetown CCF just submitted our comments on the Trump Administration’s proposed rule to lift current rules used to determine whether an immigrant is likely to become a “public charge”. The proposed rule would replace carefully crafted existing regulations with almost unlimited discretion for Department of Homeland Security (DHS) officers to “use their judgment” to determine if someone is allowed into the U.S. or allowed to adjust their status lawful permanent resident (LPR).
Officially, the proposed rule is DHS Docket No. USCIS-2025-0304, “Public Charge Ground of Inadmissibility.”
In sum, this is a terribly crafted policy which will cause uncertainty and fear which will in turn cause significant harm to children and families, including citizen children. This will lead to a range of social and economic harms that are completely overlooked in the proposed rule.
In fact, one in four children in the U.S. lives in a “mixed-status” household – the vast majority of these children are citizens. If put into effect, we estimate that the number of uninsured children in the U.S. could grow by more than 25% — and this would be primarily citizen children losing their coverage. This is because of a well-known impact of such anti-immigrant policies – the “chilling effect” whereby parents avoid enrolling their children in Medicaid or CHIP due to fear of interacting with government. Given the unprecedented actions taken by the Trump Administration – like allowing CMS to share the personal data collected through the Medicaid program with U.S. Immigration and Customs Enforcement (ICE) – this chilling effect is undoubtedly stronger than ever.
The proposed rule relies on an incredibly shoddy methodology to conduct a cost-benefit analysis. As our comments detail, it is actually impossible to quantify tangible benefits stemming from this ill-advised policy.
As our comments summarize:
“The NPRM would eliminate a century of established policy, carefully calibrated to address policy issues and undefined terms in the law, without offering a reasoned policy alternative. In so doing, the NPRM would cause considerable harm to children and families, especially the one-in-four U.S. children who live in mixed status households (a household with at least one noncitizen), the vast majority of whom are U.S. citizens. The predictable harm that would stem from the NPRM includes considerable health insurance coverage losses, jeopardizing the well-being of millions of children, primarily citizen children. The cost-benefit analysis (CBA) in the NPRM contains several methodological and conceptual flaws that undermine the validity of its conclusions. Research suggests that there will be much greater harm if the NPRM is finalized than the CBA lays out, primarily impacting U.S. citizen children. By rescinding the 2022 final rule Public Charge Ground of Inadmissibility” the NPRM would undo longstanding public charge policy and undermine the reliance interests of immigrant families and their communities. Families would be forced to make painful decisions as they try to predict how the rules may change in the future, including forgoing needed health coverage and other benefits for their U.S. citizen children out of confusion, fear, and an abundance of caution. There is no justification to put the health and well-being of so many children and families at risk, including U.S. citizen children.”