The Maine Children’s Alliance has submitted comments to the federal government in opposition to the proposed Public Charge rule. This rule would threaten to undermine the benefit of public services to immigrant families and their children, which are critical to their health and well-being. These families are increasingly part of the fabric of our communities; by risking their access to basic, vital services, we threaten the vitality of our communities, and of our nation as a whole.
Today is the last day to submit comments on this rule in the Federal Register. Go here to submit your own comments. Not sure where to start in crafting your comments? Feel free to use information from our comments, or go here for more information on the proposed rule and its potential negative effects. Read below for excerpts from our submitted comments:
The Maine Children’s Alliance is strongly opposed to the Department of Homeland Security’s Notice of Proposed Rulemaking (NPRM) on inadmissibility on public charge grounds. This proposed rule would cause major harm to the health and well-being of young children in immigrant families—a significant share of the entire young child population—without cause. When we threaten to take away the systems in place to ensure the health and well-being of our youngest and most vulnerable, we rob the country – and our state – of a healthy future. We strongly urge that the rule be withdrawn in its entirety.
For nearly 25 years, the Maine Children’s Alliance has promoted sound policies and best practices to make sure all Maine children have the resources and opportunity to reach their full potential from birth to adulthood. This starts with collecting and analyzing data, partnering with organizations and coalitions, and promoting data-driven policy decisions. Our core initiative areas include: Early Care and Education, Child Health and Hunger, and Family Economic Security. As a data- and research-informed organization, we know how critical it is to the overall health of children and their families to have access to affordable healthcare, safe and stable housing, adequate food, and financial security. In short, we know that it is vital for families and children to have the resources to meet their basic needs, in order to thrive and contribute to our communities and economy.
The proposed rule would dramatically alter the “public charge” test with harmful consequences for young children and their parents. Under the proposal, the Department of Homeland Security would consider an applicant’s use of benefits beyond the existing standards of cash assistance and long-term institutional care to include Medicaid, the Supplemental Nutrition Assistance Program (SNAP), housing assistance, and Medicare Part D subsidies. This would likely lead individuals—including parents of US citizen children—to withdraw or unenroll from benefit programs that support their health, well-being, and financial security. While only the use of benefits by an individual would be considered under the proposed rule—and not their dependents—there is simply no way to implement this rule without direct harm to children. Parents’ own well-being is an important determinant of children’s health and development. Children do better when their parents are healthy and economically stable. The destabilizing effect of this rule would harm parents who lose access to benefits and their children who will be directly impacted.
Children of immigrants represent a large and growing share of young children in the United States. Roughly 9 million young children under age 8—approximately 26% of all young children—in the US live with one or more immigrant parent. The vast majority of these children—94 percent—are U.S. citizens. As such a large segment of our young child population, the experiences, development, and education of children of immigrants are consequential for our entire country. Our future is tied to their health and well-being, as well as their success in school and later careers. As of 2016, there were an estimated 19,900 children in Maine who were living in families where one or more parents were immigrants not born in this country. The poverty rate of these immigrant children is 27%. [i] This underscores that these families and children are already not getting adequate resources, so it is even more important that we do not risk access to these programs and services meant to support them.
The proposed rule would exacerbate widespread fear of accessing public programs and services to millions of children and adults, beyond those subject to the “public charge” test. The proposed regulation would make immigrant families more afraid to seek programs that support their basic needs, including for their US citizen children. An estimated 26 million people may unenroll or refuse public benefits because of this proposed rule, including approximately 9.2 million children in immigrant households, representing approximately 13% of our nation’s child population.
Critical public benefit programs—Medicaid, SNAP and housing assistance—contribute to the healthy development of young children. Early childhood is a critical period of development, and children need access to healthy foods, safe and stable housing, and healthcare to grow up healthy and strong. Decades of research show the positive impact of public benefits on children’s long-term health and economic security. When children get access to these programs, they are both healthier and their families have more money in their budgets to spend on other basic needs. In Maine, for fiscal year 2018, there were 121,350 children enrolled in Mainecare – or 45% of the population of children in Maine. For a snapshot in time enrollment number, in December 2017 there were 63,927 children receiving SNAP benefits, accounting for around 1 in 4 children in Maine.
Forgoing critical health and nutrition programs would harm children’s development. The consequences of parents forgoing basic needs programs for themselves would be deeply damaging for children. Parents’ stress and health challenges impede protective caregiving and can undermine children’s development. The proposed rule would increase poverty, hunger, and illness with profound negative outcomes for children during childhood and into adulthood. Poorer children and teens are at greater risk for several negative outcomes such as poor academic achievement, school dropout, abuse and neglect, behavioral and socio-emotional problems, physical health problems, and developmental delays.[ii]
The proposed rule would have adverse impacts on pregnant women, infants, and toddlers. The proposed rule would create barriers to accessing health care and nutrition assistance for pregnant women. Medicaid covers almost half of all births in the United States. This coverage improves access to care and overall health and reduces mortality rates. If pregnant women decline to enroll in Medicaid and lose access to pregnancy-related health services, there would likely be serious health implications for mothers and their children. Similarly, fear of enrolling children in Medicaid or CHIP would result in fewer regular doctor visits. The first months and years of a child’s life are marked by rapid growth and brain development and are an especially important time for consistent health care.  Similarly, nutrition assistance is vital prenatally and in early childhood. Data about births is not available by immigrant status of parents in Maine. But we do know that poverty increases the risk for low birthweight and pre-term babies, and families who are poor tend to have less access to prenatal care. In 2017 in Maine, 1,388 babies were born without prenatal care in the first semester; 1,066 babies were born premature; and 878 babies were low birthweight.
There is a wide body of recent research that reflects a positive return on investment in programs that support young children and their families. Through these programs, we invest in children’s health, well-being, and healthy development. Significant gains for children, families and our communities are realized through better outcomes in education, health, social behaviors, and employment
For all the above reasons, we urge you to withdraw this harmful rule in its entirety. Thank you for your consideration.
 National Scientific Council on the Developing Child, Young Children Develop in an Environment of Relationships: Working Paper No. 1, 2009, http://developingchild.harvard.edu/wp-content/uploads/2004/04/Young-Children-Develop-in-an-Environment-of-Relationships.pdf.
 Migration Policy Institute tabulation of 2014 American Community Survey (ACS) and 2008 Survey of Income and Program Participation (SIPP) by Bachmeier and Van Hook.
 2012-2016 5-Year American Community Survey Public Use Microdata Sample (ACS/PUMS); 20122016 5-Year American Community Survey (ACS) estimates accessed via American FactFinder; Missouri Census Data Center (MCDC) MABLE PUMA-County Crosswalk. Custom Tabulation by Manatt health, 9/30/2018. Found online at: https://www.manatt.com/Insights/Articles/2018/Public-Charge-Rule-Potentially-Chilled-Population.
 Maya Rossin-Slater, “Promoting Health in Early Childhood” Future of Children 25 (2015); Hilary Hoynes, Diane Whitemore Schazenbach, Douglas Almond, “Long-Run Impacts of Childhood Access to the Safety Net,” American Economic Review 106 (2016); David Murphey, Health Insurance Coverage Improves Child Well-Being, Urban Institute, 2017, https://www.childtrends.org/publications/health-insurance-coverage-improves-child-well.
 Megan Sandel, Richard Sheward, Stephanie Ettinger de Cuba, et al.,“Unstable Housing and Caregiver and Child Health in Renter Families,”Pediatrics 141 (2018); Katie K. Tseng, Su Hyun Park, Jenni A. Shearston, et al.,“Parental Psychological Distress and Family Food Insecurity: Sad Dads in Hungry Homes,” Journal of Developmental and Behavior; Caroline Ratcliffe, Signe-Mary McKernan, Child Poverty and Its Lasting Consequence, Urban Institute, 2012, http://www.urban.org/UploadedPDF/412659-Child-Poverty-sand-ItsLasting-Consequence-Paper.pdf .
 American Psychological Association, Effects of Poverty, Hunger and Homelessness on Children and Youth, 2018, https://www.apa.org/pi/families/poverty.aspx; Caroline Ratcliffe, Signe-Mary McKernan, Child Poverty and Its Lasting Consequence, Urban Institute, 2012, http://www.urban.org/UploadedPDF/412659-Child-Poverty-sand-ItsLasting-Consequence-Paper.pdf ; Greg J. Duncan, Katherine Magnuson, The Long Reach of Early Childhood Poverty ; Robert D. Putnam, Our Kids: The American Dream in Crisis, New York, New York, 2015.
 Anne Rossier Markus, Elie Andres, Kristina West, et. al, “Medicaid Covered Births, 2008 Through 2010, in the Context of the Implementation of Health Reform,” Women’s Health Issues 23 (2013).
 Stan Dorn, John Holahan, “The Benefits of Medicaid Expansion: A Reply To Heritage’s Misleading Use Of Our Work” Health Affairs Blog, 2013, http://healthaffairs.org/blog/2013/05/03/the-benefits-of-medicaid-expansion-a-reply-to-heritages-misleading-use-of-our-work/ .
 Elisabeth Wright Burak, Promoting Young Children’s Healthy Development in Medicaid and the Children’s Health Insurance Program (CHIP), Georgetown Center for Children and Families, 2018, https://ccf.georgetown.edu/wp-content/uploads/2018/10/Promoting-Healthy-Development-v5-1.pdf.
[i] PRB analysis of 2012-2016 5-year ACS PUMS, US Census Bureau
[ii] American Psychological Association, Effects of Poverty, Hunger and Homelessness on Children and Youth