Pushing back in the fight against federal sabotage with public comment

By Rosana G. Ferraro |

In the past months, the White House administration has proposed major changes to the rules that implement government policy, proposing and making administrative changes that are damaging to people across the country – and not just in health care.  One way to push back on these harmful policies is to submit public comment in opposition to these proposed rules.  While we may not be able to stop these cruel and inhumane changes, we can at least speak up.

We have been doing just that in the past months.

What is rulemaking anyway?

When the federal government implements a law or policy, sometimes rules and guidance must be laid out by the agency in charge.  For example, when the Affordable Care Act passed, there was years of rulemaking by the Department of Health and Human Services to implement the new law.

Anyone can speak up during the rulemaking process – each proposed rule has to be posted for the public to comment.  And that’s exactly what we’ve been doing – speaking up and pushing back on proposed rules that would harm Connecticut residents.

For more on rulemaking, check out this in-depth look at “What is rulemaking?

Changes to how the Official Poverty Measure is calculated

One proposal we commented on wants to change the way the Official Poverty Measure is calculated.  The change will, if implemented, mean that far fewer people will qualify for important programs, such as Medicaid and SNAP (formerly known as food stamps), despite the fact that they may need health insurance, nutrition help, or assistance from other programs.

Read our comment

Changes to “mixed status” rules for housing assistance

Housing is tied in many ways to health – a healthy and safe home is critical for your well-being.  Another proposal we commented on wants to essentially evict “mixed status” families from housing assistance programs, like Section 8 and public housing.  “Mixed status” families are those where one or more person is ineligible for housing assistance due to their immigration status.  The rule forces “mixed status” families the impossible choice of splitting up or lose their housing assistance and potentially become homeless.

You can read more about the rule in this post by the National Low Income Housing Coalition.

Read our comment

Changes to “public charge” rules

Another proposal we commented on focused on immigration and something known as “public charge.”  When an immigrant is applying for a green card (or lawful permanent resident status), part of what determines whether they are approved or not is whether they have been or will become a “public charge” or reliant on the state.

Enrollment in certain public programs had been permissible to help newly arrived families get on their feet – such as Medicaid or SNAP – but the proposed rule wants to change that by penalizing use of these programs.  In other words, immigrants who are legally eligible for Medicaid and SNAP are likely to not use these programs – even if they need them for critical health care or nutrition – because it puts their opportunity for a green card at risk.

Just this week, the “public charge” rule was finalized and goes in effect October 15, 2019.  This harmful rule will have damaging implications for health and health coverage.  Connecticut State Attorney General William Tong has joined other states to sue to block the rule, and various leaders in the state have voiced their opposition.

This fact sheet from Protect Immigrant families has more on the public charge rule.

Read our comment

Changes to the Health Care Rights Law

Most recently, public comment was due on proposed changes to the Health Care Rights Law (Section 1557 of the Affordable Care Act), weakening protections for LGBTQ people, women, people of color, people with disabilities, and those whose primary language is not English.  Connecticut officials spoke out about this issue in a press conference last week.

For more on the proposed changes to the Health Care Rights Law, check out the National Women’s Law Center’s blog on 6 Ways the Trump Administration Is Promoting Discrimination in Health Care

For a complete timeline of how the White House Administration is undermining the ACA, check out the Center on Budget and Policy Priorities’ Sabotage Watch.

Read our comment

We’ll stay in the fight, any way we need to

Federal comment is a critical way that all of us can speak up against the implementation of policy that harms the health and well-being of all Connecticut residents.  We continue to push back as new rules are proposed that could hurt state residents and we continue to also keep track of other action.