The Honorable Robert F. Kennedy Jr.
Secretary
U.S. Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201
RE: (Docket ID Docket: AHRQ-2025-0002) Opposition to Personal Responsibility and Work Opportunity Reconciliation Act; Interpretation of ”Federal Public Benefit”
Dear Secretary Kennedy,
New Jersey Policy Perspective (NJPP) is a nonpartisan think tank that drives policy change to advance economic, social, and racial justice through evidence-based, independent research, analysis, and strategic communications. For decades, NJPP has provided timely and insightful research to policymakers in New Jersey to improve outcomes and opportunities for families and individuals across the state.
NJPP strongly opposes any attempt to restrict access to Health and Human Services programs that help build healthy communities. All the programs now being considered “federal public benefits” under this rule proposal would harm the health of those individuals excluded and all residents of the state.
Federally Qualified Health Centers (FQHCs)
Federally qualified health centers provide critical health care to communities often underserved by the health care system as a whole. More than 1 in 4 FQHC patients are uninsured, substantially higher than the state average.[i] In 2023, the state’s 138 FQHCs served more than 570,000 patients, including 145,700 uninsured patients.
People get sick and require care regardless of immigration status. Pushing those people out of the health care system by treating them as a “public charge” does not make them healthier or reduce usage of public benefits. Instead, these punitive policies hurt overall health and well-being by pushing families with mixed immigration status away from care.[ii]
These restrictions ignore an important fact: the FQHCs provide a service for the general welfare. This policy ignores the role that better health, nutrition and education have on society as a whole. If one group of people is excluded from or avoided basic medical care, healthy pregnancy and infancy, or early childhood experiences, those costs multiply on everyone.
Also, immigrants have higher employment rates than native-born adults, contributing greatly to the state and local economy. In New Jersey, immigrants are a major driver of business growth. The roughly 2.2 million immigrants living in the state generate billions in economic activity and local and state tax revenue.[iii] Excluding large parts of this population from basic care will hurt their ability to remain economically independent. This aligns with research showing that the cost of insuring immigrant residents is generally lower than the cost of insuring native-born residents.[iv]
Other programs
Similar logic applies to the vast array of programs now being considered “federal public benefits” under this proposal. Almost all of these programs provide benefits to the community when they reach a broad population:
- Head Start programs and high-quality early childhood education reduce lifetime costs for child participants and improve a wide range of health and academic outcomes.
- Substance Use Prevention, Treatment, and Recovery Services help reduce the risks of overdose and substance use disorder on families and communities.
- Title X Family Planning helps families plan how many children to have and keep a family size they can support economically.
- Community Services Block Grants provide funding to Community Action Agencies to deliver services that reduce poverty and promote independence.
- Education and Training Voucher programs support youth aging out of foster care in pursuing higher education and developing independent living skills.
- Kinship Guardianship Assistance Program ensures relatives who take guardianship of youth receive the guidance and resources needed to strengthen families, increase kinship placements, and promote long-term cost savings.
Simply put, these programs do not act as “benefits” to the recipients. Instead, these programs seek to reduce the overall cost to society and government by providing preventative measures that encourage economic independence and security.
NJPP urges HHS to withdraw this proposed rule that misclassifies these prevention measures that benefit all residents as “federal public benefits” that go to a select few.
Sincerely,
Brittany Holom-Trundy
Research Director
New Jersey Policy Perspective
End Notes
[i] New Jersey Primary Care Association, Federally Qualified Health Centers in New Jersey, March 2024. https://www.njpca.org/wp-content/uploads/2024/04/March-2024_NJPCA-Bifold-FQHC-Snapshot.pdf
[ii] Dulce Gonzalez et al. Mixed-Status Families and Immigrant Families with Children Continued Avoiding Safety Net Programs in 2023. Urban Institute, Aug. 7, 2024. https://www.urban.org/research/publication/mixed-status-families-and-immigrant-families-children-continued-avoiding
[iii] Marleina Ubel, New Immigrants Drive Economic Growth in New Jersey, New Jersey Policy Perspective, Apr. 15, 2024. https://www.njpp.org/publications/report/new-immigrants-drive-economic-growth-in-new-jersey/
[iv] Neeraj Kaushal and Felix Muchomba. Cost of Public Health Insurance for US-Born and Immigrant Adults. JAMA Network Open. 2023;6(9):e2334008. doi:10.1001/jamanetworkopen.2023.34008
