Catholic Charities NY’s Immigrant and Refugee Services most recent advocacy efforts related Public Charge: Comments in Response to Proposed Rulemaking: Public Charge Grounds of Inadmissibility
On April 14, 2022, Immigrant and Refugee Services for Catholic Charities Community Services, Archdiocese of New York submitted a comment to the Department of Homeland Security’s proposed public charge rule. Catholic Charities support a clear administrable public charge rule that “welcomes the stranger.” The prior administration’s public charge rulemaking – despite not being in effect – continues to cause chilling effects on immigrants seeking residence, particularly to the most vulnerable noncitizens: the poor, the elderly, and the disabled. For this reason, CCCS supports a rule that establishes clarity rather than continued confusion and uncertainty. CCCS believes that the rule of law and the consequent respect for human dignity must be the guiding core principles that are properly balanced when policies are designed to advance both national and individual interests. This proposed rule, if implemented with our recommendations as well as those by similar organizations, will provide the needed clarity and stability for noncitizens and their families. In our comment CCCS focused on the following recommendations:
Removal of the word “Alien” from the preamble and regulatory text and replacing it with “noncitizens”
Removal of State, Tribal, territorial or local benefits for consideration in a public charge determination from the regulatory text
Retention of the proposed language regarding the term “totality of the circumstances,” where no one factor other than an insufficient affidavit of support, if required, should be the sole criterion for determining whether the applicant is likely to become a public charge.
Do not require additional evidence or additional questions on the I-485 regarding the five factors for consideration of the totality of the circumstances
Provide funding to trusted community organizations that can provide outreach and education to immigrants and their families.
Due to the continuing damage done by the previous attempts at rulemaking, we urged DHS to finalize a rule that included the above recommendations as soon as possible.
