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Dec 10, 2018

YMCA Comments on Proposed Changes to the Public Charge Rule

We respectfully ask the U.S. Department of Homeland Security to withdraw the proposed regulation changes to the “public charge” criteria because of the far-reaching, negative impact they would have on the immigrant families we serve.

As the largest Y in the Midwest, the YMCA of Metro Chicago provides thousands of immigrant families each year with resources that help them thrive and become contributing members of our society. As a mission-driven organization, we take pride in offering Early Education and Care, School Age, Community Schools Initiative (CSI), and Youth Safety and Violence Prevention (YSVP) programs to families living in some of the most economically-challenged areas in our region.

The Y is concerned that these immigrant families will not be able to distinguish which programs will impact their ability to obtain legal residency in the U.S. and, as a result, will stay away from all Y programs that are partially subsidized by the federal government, such as Early Head Start, Head Start, Child Care Assistance, and 21st Century Community Learning Centers.

Many of these parents work two to three jobs to make ends meet, and the help they receive from the Y with assistance from our government and partner organizations is critical to keeping their families afloat and overcoming barriers such as poverty.

Families enrolled in our early learning, day camp, and out-of-school time programs rely on our assistance so they can work and go to school with the security of knowing that their child is being cared for in a safe, nurturing environment. In programs such as Early Head Start/Head Start and CSI, we serve the entire family by providing parents with access to:

  • Referrals to dental care and other wrap-around services
  • ESL and GED programs
  • Essentials such as hygiene kits, winter coats, clothing, and diapers
  • Job training
  • Financial literacy classes
  • Parent cafes where they can share concerns, learn communication strategies with their child, and meet other parents

When parents are forced to give up benefits that help feed, house, and educate their children in order to obtain a green card, these factors can perpetuate the cycle of trauma that leads to violence. In fact, the Heartland Alliance’s Illinois Poverty Report 2017 uncovered various findings that demonstrate that both poverty and violence often come from the same causes. They also show that the unaddressed trauma that exists in impacted communities directly feeds into further poverty and violence.

The Y’s robust YSVP initiative offers trauma-informed programs designed to reduce or prevent the cycle of harm. We believe that “Healing is Prevention,” and we work to address and treat “adverse childhood experiences” or ACEs, which can be anything from experiencing homelessness, witnessing or being a victim of a violent crime, or food insecurity during childhood. Through our signature programs, we work with youth with the highest risk of committing violence to process these traumatic events and alleviate the anxiety and depression that often result from experiencing many ACEs.

According to the proposed regulation change, the federal government can still decline lawful permanent residence to individuals not currently receiving benefits if they conclude that they are “likely to become a public charge” in the future. This opens the door to discrimination based on age, income, family size, medical conditions, and education level. Immigrant parents may feel they need to decline critical resources from organizations such as the Y to avoid jeopardizing their chances at becoming legal residents. This situation could lead to food insecurity and homelessness, thus creating more ACEs and the cycle of violence will continue.

The Y is committed to diversity and inclusion. We work together to ensure that everyone, regardless of ability, age, cultural background, ethnicity, faith, gender, gender identity, ideology, income, national origin, race, or sexual orientation has the opportunity to reach their full potential with dignity.

Our nation’s rich history is made up of immigrants that journeyed here with hopes of creating a better future for their families. The sweeping changes resulting from this proposed rule would severely limit legal immigration to the U.S. and undermine our ability to receive hard-working individuals and families that strengthen our communities and bolster our economy. Denying legal residence based on presumptions of what services may be required in the future locks many of the families we serve out of opportunities based upon the conscious or unconscious biases of the Department of Homeland Security staff.

Again, we ask the Department of Homeland Security to reconsider these proposed rule changes and instead work with Congress to create meaningful immigration reform that will truly make America’s communities safer and enable families to thrive.

Richard H. Malone
President and CEO, YMCA of Metro Chicago