On behalf of the Charles B. Wang Community Health Center (CBWCHC), we are offering comments to the DHS Proposed Rule on Inadmissibility on Public Charge Grounds. CBWCHC is a federally qualified health center which provides primary care and support services to the medically underserved in NewYork City, with a focus on Asian Americans. For 47 years, we have provided high quality and accessible health care to all patients regardless of their ability to pay, the language they speak, or their immigration history. In 2017, we served more than 58,000 patients with 300,000 service visits.

We know from experience that changes to immigration and public benefits rules often affect a broader group of individuals than those directly impacted by the policy change. Green card holders and/or immigrants exempted from the rule (such as refugees or asylees) could be frightened and confused about the potential consequences of applying for food, health, and housing support that they are eligible to receive. Since undocumented immigrants are ineligible for nearly all of these forms of assistance — and because cash assistance is already considered in public charge determinations — the rule will affect immigrants who are lawfully in the United States and often working along with spouses and children who are likely U.S. citizens.  

CBWCHC operates a health insurance enrollment program to help eligible patients and community members sign up for Medicaid, CHIP, Medicare, and ACA marketplace health plans. We are aware that despite efforts to assure families that Medicaid and CHIP could not be used in public charge determinations under existing policy, some eligible immigrants did not enroll because they feared that it could negatively affect their status. The proposed rule would amplify these fears, which would likely lead to broad falloffs in participation in Medicaid and other programs among immigrant families which include both citizen and non-citizen members.

We are already experiencing drop-offs in Medicaid participation among our patients, most notably pregnant women in our Ob/Gyn practice. Ensuring that women have access to health coverage during their entire pregnancy is essential to the health of mothers and babies. Prenatal services, which are a significant part of pregnancy services, improve health outcomes for mothers and children. Mothers who do not receive prenatal care are three times more likely to have a low birth weight baby and five times more likely to die than mothers who receive prenatal care. There is also a risk that pregnant women who forgo Medicaid and thus lose access to pregnancy-related services may decide not to enroll babies or young children in Medicaid, CHIP, WIC, SNAP or other nutrition assistance programs.

In New York State, about 3.8 million children ages 0 to 17 are in families participating in one of the four major benefits programs -Medicaid/CHIP, SNAP, TANF, and SSI. Kaiser Family Foundation estimates that 15%to 35% of U.S. citizen and non-citizen children in mixed-status households will disenroll from CHIP/Medicaid if the proposed rule is approved. The evidence is overwhelming that Medicaid/CHIP produce near and long-term benefits for children. Children with health insurance do better in school, on average, and miss fewer school days due to illness or injury. They are also more likely to finish high school, attend college, and graduate from college. Research shows that they earn more as adults and experience fewer emergency room visits and hospitalizations.

SNAP also has a strong, positive impact on children’s near-and longer-term well-being. Extensive research finds that adults given access to food stamps as young children had lower rates of certain health problems such as heart disease and obesity, and women who had access to food stamps as young children showed improved economic self-sufficiency. High school completion, in particular, rose dramatically. The positive impact on children is the reason that SNAP is available to legal immigrant children during their first five years in the United States, even though adults are barred from participation during their first five years.

The proposed rule is likely to have adverse effects on the health and wellbeing of the entire community, not just immigrants and their family members. Delayed treatment for communicable diseases, lowered vaccination rates, and higher rates of unwanted pregnancy and sexually transmitted infections pose population health risks that affect the entire community. Likewise, reduced care for serious psychiatric illnesses could result in higher rates of suicide and substance use with consequences for both those suffering from mental health conditions as well for the population broadly. 

Written by Jane T. Eng, Esq.
Jane T. Eng, Esq. is the President and Chief Executive Officer of the Charles B. Wang Community Health Center. She oversees the operations of a federally qualified community health center which provides affordable and culturally competent primary health care to underserved Asian Americans. A graduate of Harvard Law School, Ms. Eng is vice president of the Association of Asian Pacific Community Health Organizations and a board member of the Community Health Care Association of New York State.


Posted by Charles B. Wang Community Health Center

The Charles B. Wang Community Health Center is a nonprofit and federally qualified health center, established in 1971. Our mission is to provide high quality and affordable health care to the undeserved, with a focus on Asian Americans. Our vision is to ensure that everyone has full and equal access to the highest level of health care. Learn more at www.cbwchc.org.

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