As one of the largest and historically important nonprofit children and family service providers in the country, Children’s Home Society of Washington (CHSW) is writing to express our strong opposition to the Department of Homeland Security’s Notice of Proposed Rulemaking (NPRM) on inadmissibility on public charge grounds. The proposed rule would cause major harm to the health and wellbeing of young children in immigrant families—a significant share of the young child population—without justification.

CHSW has been supporting families since 1896 and currently provides comprehensive services to 30,000 children and families annually in Washington state. With a mission to develop healthy children and create strong families, CHSW programs foster effective parenting skills, improve school readiness, develop emotional competence, provide nutritional and education services, and work to keep children safe and secure. CHSW has provided early learning services to children under the age of 5 for more 25 years. In addition, the organization supports families through parent education and support groups, basic needs, child and family counseling, and foster care and adoption services.

We believe strongly that this proposal will jeopardize children living in immigrant families and/or extended families. 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, including United States citizen 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 percent of all young children—in the United States live with one or more immigrant parent. The vast majority of these children—94 percent—are U.S. citizens.  As 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 wellbeing, as well as their success in school and later careers.

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 U.S. citizen children. An estimated 26 million people may potentially disenroll or refuse public benefits because of this proposed rule, including approximately 9.2 million children in immigrant households, representing approximately 13 percent of our nation’s child population.

Critical public benefit programs—such as Medicaid, SNAP and housing assistance—contribute to the healthy development of young children. Early childhood is a formative period of development, and children need access to enough healthy foods, safe and stable housing, and adequate health care to grow up healthy and strong.  Decades of research show the positive impact of public benefits—such as Medicaid, and SNAP—on children’s long-term health and their 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.

This proposal could create devastating consequences to children that will last the remainder of their lives. As children’s practitioners and advocates we agree with research that clearly demonstrates that trauma in the first few years of a child’s life can derail healthy development for years.  This could lead to lifelong problems in learning, behavior, and physical and mental health. CHSW urges that the rule be withdrawn in its entirety.

Sharon Osborne is the president/CEO of Children's Home Society of Washington and Children's Home Society & Trust Foundation.