​UPCEA today joined over 150,000 groups and individuals submitting comments on the Trump administration’s proposal​ to overhaul how the government evaluates whether a would-be immigrant is “not likely to be a public charge”—that is, not likely to use public benefits such as food stamps or Medicaid, a requirement of many visa categories and green card applications.

The administration’s proposed new definition would require an extended investigation into an immigrant’s history and job prospects, and give wide-ranging discretion to the U.S. Citizenship and Immigration Services (USCIS) to reject an immigrant’s application for admission or for an extension or change of status, as well as reject applications from non-immigrants such as international students seeking student visas.

At issue is how the government looks at public benefits an immigrant has already used or is likely to use. While only cash benefits are considered right now, the new approach would include Medicaid, SNAP (food stamps), Section 8 and other housing benefits, and Medicare Part D subsidies for low-income earners.

In comments submitted on behalf of UPCEA and 30 other higher education associations, ACE expressed concern over how the proposed change would impact American students with immigrant family members as well as international students, including graduate and professional students who upon graduation may become legally employed in the United States.

While the associations are “deeply troubled” that the scope of the definition will include programs like SNAP and Medicaid, their comments focused on Title IV federal student aid programs and international students on F-1 and J-1 visas.

“Under current law, federal student aid is only available to U.S. citizens or green card holders, with very few exceptions. Nevertheless, we have heard anecdotal reports of students who are U.S. citizens turning down financial aid packages because they are concerned that receiving educational assistance may adversely impact their non-U.S. citizen family members’ applications for admission or legal residency,” the groups wrote.

Although Title IV programs are not included in the definition, the associations are asking that they be specifically excluded to help curb a potential chilling effect on first-generation American college students.

On the international student and scholar issue, the groups believe the expansion of public charge to apply to non-immigrants, including F-1 students, J-1 exchange visitors, and H-1B specialty workers, will create further delays in visa processing and discourage international students and scholars from coming to the United States, exacerbating a downward trend in international student enrollment at American colleges and universities. They are also asking for F-1 and J-1 student and exchange visitors to be explicitly excluded.

To read the full letter, click here​.