NSCC has joined with other Massachusetts community colleges in writing to the Department of Homeland Security in opposition to the changes regarding “public charge,” published in the Federal register on October 10, 2018. The definition of a “public charge” is someone who is dependent on government benefits and as a result, may be denied access to these critical resources. An expanded “public charge” definition would include those who participate in additional safety net programs, including Medicaid and SNAP.
If you have questions, or would like more information, please feel free to contact the Dean of Students’ Office: 978-762-4000, x6614.
Comments on Public Charge MA CC Presidents 11/15/18
November 15, 2018
U.S. Citizenship and Immigration Services
Department of Homeland Security
20 Massachusetts Avenue NW
Washington, DC 20529‐2140
Re: DHS Docket No. USCIS‐2010‐0012, RIN 1615‐AA22, Comments in Response to Proposed Rulemaking:
Inadmissibility on Public Charge Grounds
We are writing on behalf of ten (10) Community Colleges in the Massachusetts Community College System in
response to the Department of Homeland Security’s (DHS or the Department) Notice of Proposed Rulemaking
(NPRM or proposed rule) to express our opposition to the changes regarding “public charge,” published in the
Federal register on October 10, 2018. The proposed rule would create significant harm to the health and wellbeing of immigrant students, children, parents, and families, as legally present immigrants decide to forego enrollment for themselves and/or their families in the programs specified under the rule out of fear of harming their future eligibility to stay in U.S. Further, the proposed rule could create additional barriers and represent a deterrent to international students and visitors seeking to study and work in the United States. We urge that the proposed rule be withdrawn in its entirety, and that the 1999 guidance remain in effect.
Three quarters of our students are adults, and fall into the two lowest quintiles of income; almost all work and
many full‐time, and two out of five are parents. Located in proximity to our Commonwealth’s Gateway Cities,
our Colleges serve generations of immigrants, second‐language speakers, and those seeking socio‐economic
mobility. Our Colleges’ programs and pathways in Adult Basic Education, ESOL, and Certificates and Associate
Degrees in STEM, Health Care, Manufacturing, and other key industries are critical to the future prosperity of
these students, their family, and ultimately, our Commonwealth and the nation.
As higher education leaders, we are committed to ensuring that all students are given the opportunity to
succeed in school and contribute their talents to our nation’s workforce and economy. As such, we are
especially dismayed about the counterproductive consequences of this proposed “public charge” rule on
immigrant students—students who contribute greatly to the rich cultural diversity of the nation’s college
campuses, serve as leaders on our campuses, and work in our communities. Like their peers, immigrant
students‐‐including those who have obtained legal permanent residency and U.S citizenship‐‐ work hard to
earn their postsecondary degrees and credentials. Other immigrant students aspire to one day become legal
permanent residents and U.S. citizens, apply their education and training to their field of study, and contribute
to our country.
In particular, we present the following concerns:
- The proposed rule would substantially expand the definition of “public charge,” and lawfully present
immigrants would face increased barriers to maintaining or adjusting their immigration status.
Students who depend on SNAP to fulfill a basic need to complete college will be placed into greater
risk when trying to improve their immigration status.
- The rule would discourage immigrant youth and U.S.‐born youth with non‐citizen parents from
pursuing a college education and would increase families’ financial instability.
- Research shows that postsecondary education boosts economic mobility, improves lives, and helps
the economy, yet the proposed rule would deter immigrant youth from enrolling in higher education.
- The rule would penalize low‐income immigrants who receive or who are likely to receive public
benefits that enable them to enroll and succeed in college, and it would create significant and lasting
harm to the health and well‐being of immigrant youth and their families.
- The proposed rule would have profound consequences on entire communities in Gateway Cities.
- The proposed rule would discourage adult immigrant learners from participating in workforce training,
certification programs, and adult education programs that help to improve their English language skills.
- Concerns Related to International Students
- International Students: The proposed rule would apply to international students, visitors, and workers
seeking to extend or adjust their status.
- Workforce Development: The proposed rule could affect changes in the U.S. talent pipeline that
would ultimately undermine our nation’s global competitiveness.
- The complex regulations under the proposed rule would create significant administrative burdens on
institutions and college advisors, as well as increased uncertainty about use of braided funding for
education and career pathway programs.
For these reasons, the Department should immediately withdraw its current proposal, rely instead on the
1999 policy guidance regarding public charge, and dedicate its efforts to advancing policies that strengthen—
rather than undermine—the ability of immigrants to access postsecondary pathways and support themselves
and their families in the future.
Thank you for the opportunity to submit comments on the NPRM. Please do not hesitate to contact any of us
to provide further information.
John B. Cook, PhD
Springfield Technical Community College
Laura Douglas, PhD
Bristol Community College
Fall River, MA
Pam Y. Eddinger, PhD
Bunker Hill Community College
Patricia A. Gentile, EdD
North Shore Community College
Lane A. Glenn, PhD
Northern Essex Community College
Ellen Kennedy, EdD
Berkshire Community College
David Podell, PhD
President, MassBay Community College
Valerie Roberson, PhD
Roxbury Community College
Christina Royal, Ph.D.
Holyoke Community College
Yves Salomon‐Fernandez, PhD
Greenfield Community College