The Online Resource for Massachusetts Poverty Law Advocates

How to Submit Comments to Oppose Proposed "Public Charge" Rule Changes that harm low-income immigrants in Massachusetts and US

Thanks to all those who joined in the MIRA-MLRI-Health Law Advocates webinar yesterday. We know these rules are really CONFUSING !  Here's the core take-aways.  
  • These are PROPOSED rules. NOTHING has changed today. However, if the rules are finalized, the regulation would dramatically rewrite immigration policy and make green cards only available to the highest bidder. You and the people you serve had a right to submit public comments on these proposed rules, and we urge you to do so. 
  • Immigrants who are currently receiving SNAP, MassHealth or any other benefits should NOT close their cases or stop applying for benefits to which they are legally eligible. There are important resources for immigrants who may want specific legal advice, see link to resources on EOHHS website. 
  • Many immigrants are simply NOT subject to "public charge" - including immigrant who already have their green cards and are not planning to travel outside the US for lengthy periods; victims of violence, refugees, asylees and other groups of immigrants. And there is NO "public charge" disqualification for immigrants applying to naturalize (become U.S. citizens). Here's a link to an FAQ that answers a lot of basic questions about this proposed rule: https://protectingimmigrantfamilies.org/faqs/  
If you missed the webinar or just need to tune in for more information - we strongly recommend registering for the excellent presentations done by our colleagues at the Center for Law and Social Policy and the National Immigration Law Center. There is a Public Charge 101 webinar on Wednesday, 10/17 at 1 PM (EST) from our national PIF colleagues, Click HERE to Register. 
 
If you are able to submit comments to these rules - FRAC has created a micro site here to collect and directly submit comments from the anti-hunger community. But you can also submit comments through the Mass Immigrant and Refugee Advocacy Coalition (MIRA), link here.  And here is a wealth of excellent resources from our national partners that you can review - here. The DEADLINE is December 10th - so you have time.  As of 1 PM today, there are over 7,000 comments already filed - some good and some quite bad.  
  • We strongly recommend that these be unique comments  from individuals or groups- comments that give data or personalized stories of what this rule could mean for the communities you work with. The comments can be shore (one para) or many paragraphs - but need not be detailed analyses of the proposed rules. MLRI, MIRA, HCFA, HLA and other sister orgs and national groups are all working on detailed comments - but hearing from you and your clients about what this may mean is also really important.    
  • If you are working with individuals who want to hand write comments, or write them in their own language, you can make a PDF or JPEG of these comments and submit them directly to the following weblink. https://www.regulations.gov/comment?D=USCIS-2010-0012-0001  We strongly recommend that organizations that are collecting handwritten or non-English language comments include a typed/translated version of the same. Individuals can submit these comments without including their name or identity, or your organization can submit them without identifying the person. 
  • If you know local elected officials - your Mayor or City Council or State Rep or Senator - please urge them to submit comments on how this will harm municipalities that may lose valuable workers and do not have the resources to help individuals and families who may fall on hard times.  

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