Publish Date:
Letter, Testimony and Comments

The proposed rule would lead to enormous upheaval and harm in the lives of the communities APIAHF advocates on behalf of. Despite this significant change, DHS has provided wholly insufficient evidence for why it is needed, both in terms of alleged policy problems and any circumstances that have changed since the guidance it seeks to overturn was promulgated. In addition, DHS acknowledges but fails to provide a remedy for the significant economic impact the regulation would have on communities, populations, states and industry, including manufacturers, health care providers and other stakeholders whose work or business is intertwined with the lives and health of immigrants. In fact, DHS entirely fails to consider whether this proposed policy is needed at all and whether it is the right approach to promoting the integration and success of immigrants. It appears that the rule stems, not from any sound policy analysis or process, but a pre-conceived decision born out of animosity for immigrant populations. This assertion is backed up by press reports stemming the start of this administration, when public charge was proposed alongside other methods of singling out immigrants.