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JNCL-NCLIS submitted the following letter. Feel free to use as a resource.
The Joint National Committee for Languages (JNCL) represents a diverse network of over 130 organizations, companies and research institutes encompassing all areas of the Language Enterprise. On behalf of our members, we are writing today to express our strong opposition to the Department of Homeland Security’s proposed public charge rule as runs counter to federal laws ensuring meaningful access to government services and prohibiting discrimination on the basis of national origin.
For over a hundred years, the US public has agreed that offering health care, nutrition services and housing assistance to help all families living within the US is the best way for individuals to be productive, contributing members to society. Decades of federal nondiscrimination law, including Title VI of the Civil Rights Act of 1964 and Executive Order 13166, have solidified this principle. However, this proposed policy would discriminate against those residing in this country legally, including those who may have limited English proficiency.
The “Public Charge” rule will bring unintended consequences for thousands of state and local government agencies around the country charged with public safety, health, education, justice and other vital services. The ability to effectively execute their mission will be compromised when immigrant communities, fearing repercussions, will further isolate themselves from programs and officials that rely on community participation for success. For local agencies fighting crime, combatting public health threats, or fostering education, this policy would serve to complicate their mission. At the same time, the general population also suffers the consequences. Every day vis-à-vis language access services, these organizations help to integrate immigrants into the American mainstream. Isolating immigrant communities and Limited English Proficient populations in particular is not in the best interest of local agencies or our country’s future success.
Not only government agencies and the general public will be affected by this rule. Small and medium size businesses that provide language access services will also be in the crosshairs. There are an estimated 8,000 language service companies operating in the United States who provide interpretation and translation services to virtually every industry in operation. With at least 350 languages spoken in the US according to the most recent Census data, the impact of discriminating against LEPs would be felt in every corner of the nation. Industries including health care, law enforcement, educational institutions and finance, rely on language companies to comply with language access laws and facilitate best practices in order for the country to move forward. For example, hospitals are expected to lose billions of dollars under the proposed rule as legal immigrants will forgo needed benefits and delay access to care, resulting in sicker patients with higher medical costs. To remove this basic and fundamental consumer protection would significantly reduce the demand for language services, striking a critical bow to a large portion of the American economy.
We recommend that the Trump Administration, in order to avoid violating civil rights law, should immediately withdraw this proposal and instead advance policies that strengthen and expand access to programs for which individuals are eligible and bilingual education for all ages.
In October, the Trump Administration directed the Department of Homeland Security (DHS) to publish a proposed rule expanding the definition of who is to be considered a “public charge” to include immigrants and non-immigrants alike who are authorized to be in the United States. The rule is accepting comments and recommendations from the general public until December 10, 2018.
In immigration law, someone who is deemed a “public charge” is primarily dependent on government support to fulfill their basic needs (i.e. food, shelter, etc.).
Indeed, for over a hundred years, the US public has concurred that offering health care, nutrition and housing assistance to help all families living within the US is the best way for individuals to be productive, contributing members to society. Decades of federal law has reinforced and enshrined this as a national value, especially with regard to those with limited English proficiency (LEPs).
In consultation with its membership, JNCL-NCLIS believes that the proposed rule would be extremely harmful to individuals and families legally allowed to reside in the United States, especially those with limited English proficiency, which the proposal explicitly singles out. LEPs depend on language services to solicit everything from legal aid to healthcare services, and this rule directly contradicts a number of federal nondiscrimination and inclusion laws, namely Title VI of the Civil Rights Act of 1964 and Executive Order 13166.
Using the resources above, please join JNCL-NCLIS and our members in submitting a comment on the “Inadmissibility on Public Charge Grounds” rule. Comments will be accepted until December 10th.