The Trump administration published on October 10 a proposed rule change (PDF) that would increase the chance of an immigrant being determined to be a public charge and therefore being denied legal permanent residency or entry to the US. The proposed rule instructs immigration officials to take a broadened array of public benefits--including health and nutrition programs such as Medicaid and the Supplemental Nutrition Assistance Program (SNAP)--into consideration, along with other factors, when making public charge determinations. The proposed changes are expected to cause large numbers of immigrant parents to disenroll themselves and their children from safety-net programs, in large part due to fear and confusion over the rule even among immigrant families to whom the rule does not apply. There have been reports that this is already occurring. This issue brief discusses how this rule change could impact Medicaid and Children's Health Insurance Program (CHIP) enrollment among a particularly vulnerable group: low- and moderate-income children "in need of medical attention," defined as children with a current or recent medical diagnosis, disability, and/or need for specific therapy. This includes children with potentially life-threatening conditions such as asthma and cancer, and newborns who require immunizations, among others. The analysis found that 4.8 million children in need of medical attention lived in households with at least one noncitizen adult and were insured by Medicaid or CHIP. The authors estimate that 700,000 to 1.7 million children in need of medical attention are likely to be disenrolled from Medicaid/CHIP if the rule is changed. Once disenrolled, these children are likely to become uninsured, and are thus at higher risk of going without care or experiencing delays in care. Although not the primary focus of this analysis, there will likely be other negative health impacts from the proposed rule change for children in immigrant households, where a parent or adult caretaker disenrolls from any of the wide range of safety-net programs included in the proposed rule change, regardless of whether the children themselves are disenrolled from Medicaid/CHIP. A 60-day public comment period is underway, after which the Department of Homeland Security is required to review and respond to comments prior to finalizing the rule.
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