On September 22, 2018 the Trump Administration proposed changes in the “public charge” rules that would expand the discretion of the Office of Homeland Security to deny applications for green cards or certain types of visas. This decision would be based on an immigrant’s age, family size, income, and assets, as well as based on whether they have utilized certain cash or non-cash public benefits or programs they are legally entitled to use, including use of the Supplemental Nutrition Assistance Program (SNAP). Such a change could make life more difficult for New Yorkers who depend on and are eligible for many of our nation’s public benefit programs. As Food Policy Monitor reported in its previous issue and discussed at the October Food Policy Forum, the proposed rule change could reverse recent progress in reducing food insecurity in New York City.

Before Trump’s “public charge” rule can be finalized, however, the administration is required by law to review and respond to every unique public comment they receive about the proposed regulation. Several elected officials and advocacy organizations, led nationally by a coalition called Protecting Immigrant Families, have called on people to submit 100,000 comments to the Federal Register on the proposed rule change by the deadline, December 10, 2018.

The CUNY Urban Food Policy Institute calls on Food Policy Monitor readers and faculty, staff and students at CUNY to voice their opinions on the public charge rule. Two websites are available for simple online posting of comments directly to the Federal Register. One created by the New York City Mayor’s Office of Immigrant Affairs is available here. The other, created by Protecting Immigrant Families, is available here.

In a related development, on November 15, CUNY Urban Food Policy Institute’s Director Nicholas Freudenberg testified at a City Council hearing of the Committees on Immigration, General Welfare and Health on The Impact of the Proposed “Public Charge” Rule on NYC. He observed that the proposed change in the public charge rule was only one of a cascade of enacted and proposed policy changes that would make it more difficult for immigrants and other vulnerable populations in New York City to find the assistance they needed to avoid hunger and food insecurity. Such an increase, he said:

“could precipitate a surge of health and social problems. To reduce this risk, New York City and State legislators can embrace what we in public health call the “precautionary principle”, the belief that it is better to act with compelling albeit uncertain evidence than to wait for the bodies to pile up. City and state legislators can develop local and state responses to reduce food insecurity and its federal policy-induced rise now—or they can wait until we see the health, educational and social consequences of rising food insecurity and leave it to our children and grandchildren to pay the costs.”

The full testimony is here.