Submit comments opposing the ‘public charge’ proposal!

Note: The first phase of this campaign is now over. We are now awaiting the results of the public comment review and the publication of the final public charge rule. When that happens, we will launch a second phase focused on educating the public and service providers about the specifics of the new rule, while simultaneously pursuing legal action as appropriate.

Emma Lazarus’ poem at the foot of the Statue of Liberty invites the world to “give me your tired, your poor, your huddled masses yearning to breathe free.” For centuries, people have come with little or nothing, and built new lives and new fortunes here. It’s the American Dream.

But now the Trump administration wants to slam the door on working-class immigrants by subjecting anyone who earns less than 250% of the federal poverty line ($62,750 for a family of 4) to intense scrutiny, and effectively excluding anyone below 125% of FPL ($31,375 for a family of 4).

Immigrants applying for a green card or visa could be deemed to be a “public charge” – someone who depends on the government – and turned away if they earn below 250% of FPL and use any of a wide range of public programs for working families, or are deemed to be likely to use them in the future.   [ LEA EN ESPAÑOL

This is an assault on America’s fundamental values, and we must fight back. Whether you’re an immigrant yourself, a community advocate, a service provider, a business owner, an elected official or just a concerned citizen, you can help us ensure that the government receives an overwhelming number of unique comments on this issue.

Key resources

MIRA materials:
Sample arguments
• What is ‘public charge’ and why is this proposal so dangerous? (with table of who/what is covered)

Highly recommended: Six scenarios for how ‘public charge’ could be applied

Migration Policy Institute data on Mass. children with immigrant parents:
Children in U.S. immigrant families (pick Mass. in menu)
English learners in Massachusetts (incl. data on families and poverty)

Manatt: Data tables on Mass. residents by income & status

Mass. school district data profiles (see selected populations tab)

U.S. Census data for Mass. (or select city/town)

Blue Cross Blue Shield study on Mass. impact

Boston impact analysis

National Protecting Immigrant Families campaign resources

How crucial are safety net programs for U.S. families? Urban Institute: Material hardship among nonelderly adults and their families in 2017

In partnership with Health Care for All, Health Law Associates and the Massachusetts Law Reform Institute, we’ve put together this guidance and a collection of resources to help you. Your comments can be as short as 250 words, or as long as you need them to be. 

You can submit your comments on our portal, or if you’d like feedback and advice, you can email your draft to us first (see contacts below). You will be asked for your name, address and email when you submit your comment; if you need to remain anonymous, please email us and we’ll submit for you.

Note that there’s a 5,000-character limit for submissions on the portal; if you have a longer comment, you can email it to us to submit as a PDF. If you have a comment in a language other than English, please email it to us. And please don’t sign on to someone else’s comments; submit your own!

Here’s some guidance (download as a handout):

If you’re commenting in your personal capacity:

Focus on aspects of your personal/family context that inform your opinion. These may include your own immigration story, your immigrant parents or grandparents, and personal experience being working-class and/or using public programs. For example: “I am an immigrant from El Salvador who worked as a janitor for 10 years before starting my own business.” Or: “I wouldn’t be here if these standards had been in place decades ago. My father came to America from Hungary in 1942 with nothing but a suitcase, and he worked two jobs to put my sisters and me through college. We’re now a doctor, a college professor and an engineer.” Or: “I got pregnant when I was 21, and I relied on Medicaid to keep myself and my daughter healthy, even as I worked two jobs.” Flesh out your story and explain why the “public charge” proposal goes against your values – and against fundamental American values.

If you’re commenting in your professional capacity:

Describe your organization and your position there.
It’s important to say what your organization does, the kinds of people it serves, and your role. Highlight relevant data about your connections to immigrants and/or to working-class families. For example: “I am a pediatrician at Downtown Community Health Center in City, Mass., which provides primary care for 5,000 working-class families, about 50% of whom are immigrants and their children.” Or: “I am a member of the TownX School Committee. Our district has 10,000 students, more than half of whom qualify for free or reduced-priced lunch. About 20% are immigrants, and 40% more are children of immigrants.” Or: “I am executive director of the Cape Verdean Women’s Collaborative, an immigrant-led nonprofit that helps women learn English, gain job skills and advance socio-economically.”

If you have special expertise or credentials, describe them.
For example: “I have a Ph.D. in public health and have published extensively on links between SNAP and school success.” Or: “I have 20 years’ experience teaching in urban high schools.”

If you work directly with immigrants, describe their context.
What countries do they come from? What kinds of jobs do they have? What do you know about how hard they work, why they came to the U.S., their economic situation, and the role, if any, that public benefits play in their families’ lives?

Why, specifically, are you concerned about public charge?
This is a two-part question. There are the implications of the proposal itself – e.g. that a mother seeking a green card could be denied because she was on Medicaid while pregnant – and the widespread fear that the proposal has caused. Dig into each as relevant, providing concrete examples (“20 of my patients have disenrolled from Medicaid out of fear, leaving themselves without access to much-needed treatment for chronic diseases such as diabetes and high blood pressure”). Make sure to distinguish between facts and misinformation. For example, the rule would not penalize parents for benefits received by their U.S. citizen children, or for participating in certain programs (e.g. WIC).

Do you have personal reasons to oppose this proposal?
Even if you’re submitting comments in your professional capacity, feel free to include your personal perspective as well. Many doctors who treat immigrant patients, e.g., are immigrants or children of immigrants themselves. That’s relevant, too. See guidance for personal comments above.


Questions? Email Sarang Sekhavat from MIRA at This email address is being protected from spambots. You need JavaScript enabled to view it. (legal expert) or Marion Davis at This email address is being protected from spambots. You need JavaScript enabled to view it. (writing advice, translation, help finding data). To submit a finished comment as a PDF, email Kailey Cano at This email address is being protected from spambots. You need JavaScript enabled to view it.

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