SAVE THE DATE
41st ANNUAL WIC CONFERENCE
SEE OUR EVENTS PAGE FOR MORE DETAILS!
December 5, 2018
Ms. Samantha Deshommes, Chief
Regulatory Coordination Division, Office of Policy and Strategy
U.S. Citizenship and Immigration Services
U.S. Department of Homeland Security
20 Massachusetts Avenue NW
Washington, DC 20529-2140
RE: DHS Docket No. USCIS-2010-0012;
Proposed Rule on Inadmissibility on Public Charge Grounds
Dear Ms. Deshommes:
The WIC Association of New York State, Inc. represents 91 local agencies that administer the Special Supplemental Nutrition Program for Women, Infants and Children (WIC) in New York State. Our agencies currently serve close to 500,000 low-income women, infants and children throughout the state who are at nutritional risk.
Our mission, as a leading statewide organization, is to support and enhance the delivery of health and nutrition services to all WIC participants.
The WIC Association board includes Providers and Consumers of WIC programs, and Advocates who have worked in WIC programs as qualified Nutritionists, Nurses, and Administrators or worked in other related health care programs. Our combined professional experiences and knowledge has enabled us to envision a strong WIC community throughout New York State with healthy Women, Infants, Children and their families. For over 40 years, the Association has been advocating for WIC participants and local agency staff, as well as providing valuable input into WIC Program development and policy through collaboration with the NYSDOH. Our advocacy and outreach efforts have resulted in achieving adequate funding for staff, streamlining WIC services, eliminating barriers and enabling WIC participants to access other health care needs.
Until this year, the federal government had excluded programs such as the Supplemental Nutrition Assistance Program (SNAP), CHIP and Medicaid from becoming public charge determinations. We strongly believe that the proposed rule by the current administration to broaden the definition of who might be a “Public Charge” will force many needy immigrant families to opt out of the programs that enable them to obtain healthcare, nutrition, housing and other benefits. Even though WIC is not mentioned in the current public charge proposal and the rule is several months away from becoming a reality, it has already had a disastrous effect on WIC participation. Since January 2017, WIC agencies across the country have been reporting a decline in their caseloads. This is because WIC participants fearing the worst outcomes have chosen to forgo the much-needed WIC benefits and services. Additionally, it must be noted that while the proposed rule is intended to target non-citizens, approximately 90 percent of children under age six born to immigrant parents are U.S. citizens.
In New York State, during FFY 2018, the WIC Program’s caseload decreased by 6%. In addition to caseload dropping, the no-show rate increased by another 3%. WIC Program staff have communicated that an increased number of WIC participants have reported that they are scared and nervous to utilize WIC Program benefits. Some have asked for their entire WIC record to be deleted.
This is very disturbing because low-income pregnant women and newborn infants depend on WIC to supplement their nutrition needs and for breastfeeding support. A continued increase in the number of immigrant families who drop out of WIC or fail to participate, despite being eligible, will result in more morbidity and financial costs, especially as it relates to low-birth weight infants, failure to thrive, complications during pregnancy and delivery, increased illnesses among children, and more emergency room visits.
In the 44 years since WIC has been serving the needy, it is often cited as the most successful nutrition program as it has continued to improve birth outcomes, increase breastfeeding rates, improve children’s physical and cognitive health and improve the lifestyle of families in countless ways.
We, as members of the WIC communities in New York state, serving as providers and advocates strongly oppose including SNAP, CHIP, Medicaid, and Public Housing Assistance as programs considered public charge, and we further strongly oppose including any additional programs within public charge determinations.
On behalf of the WIC Association of NYS, Inc., I would like to thank you for taking the time to review this submission.
Lauren Brand, Chair