SILVER SPRING, Maryland — ­­The administration’s proposal to drastically change the way it calculates whether immigrants pose a risk of becoming a financial burden on society is morally and legally flawed, said the Catholic Legal Immigration Network, Inc., in a formal comment submitted to the Department of Homeland Security Dec. 9.

CLINIC’s statement on the administration’s proposed changes to what is known as “public charge” provisions cited a lack of justification, concerns about executive overreach and failure to properly account for public health and well-being.

In the comment, CLINIC Executive Director Jeanne Atkinson said the proposal is “irreconcilable with our nation’s values, as it would create unnecessary barriers to achieving the American Dream—a dream that was not intended to be limited to only the affluent. It is also contrary to our Catholic values and faith teachings, as it would negatively affect family unity, stability, and threaten public health.” CLINIC’s comment is one of more than 210,000 submitted during a period for the public to weigh in on what is known as a Notice of Proposed Rulemaking on a rule called: “Inadmissibility on Public Charge Grounds.”

The comment described the centuries-old history of the legal definition for evaluating the risk of an immigrant requiring financial assistance from the government. It referenced the nativism reflected in some such laws and observed that the Catholic church “opposes discrimination against those from developing nations as it conflicts with the church’s support for the dignity of the human person.”

The proposed rule would radically expand who is subject to the “public charge” test and lengthen the list of benefits programs that, if used, could jeopardize someone’s immigration status. These additional public programs include non-emergency Medicaid, the Supplemental Nutrition Assistance Program (food stamps), and housing assistance. Such programs serve whole families. U.S.-born spouses and children could be harmed if families decide they must decline benefits because of the possible effect on a relative’s immigration status.

Atkinson cited CLINIC’s comment in saying “there is no rational or evidence-based reason…for issuing this proposed regulation….Based on [its] voluminous restrictive policy record, DHS’s rationale for changing this regulation is not to promote self-sufficiency in immigrants, but rather, it is the latest effort to achieve the administration’s stated goal of reducing family immigration, especially given that federal courts have enjoined most of its prior attempts.”