CLINIC Submits Comment Opposing State Department’s Interim Final Rule on Public Charge
CLINIC submitted comments in response and oppostion to the State Department’s Interim Final Rule, or IFR, titled “Visas: Ineligibility Based on Public Charge Grounds,” DOS-2019-0035; RIN: 1400-AE87. The State Department issued the IFR on Oct. 15, 2019, with the purported reason of aligning DOS’s public charge standards with those of the Department of Homeland Security. The rule went into effect on Oct. 15. However, the State Department has indicated that it will not implement the IFR until the related forms are approved by the Office of Management and Budget. CLINIC opposes the IFR because the State Department failed to provide appropriate justification and evidence-based reasons for deviating from long-standing past practices on public charge determinations and for the other reasons detailed in our comment.