By: Sarah Grusin, Eskedar Girmash, and Daniel Young
Executive Summary
These comments offer suggestions for how the Department of Homeland Security should define “public charge” in response to an Advance Notice of Proposed Rulemaking. We urge DHS to adopt a narrow definition of public charge, and to ensure the regulations include clear guardrails to prevent a public charge determination from being used as a tool to discriminate against people of color, women, people with disabilities, older adults, or anyone else.
