HAP and Pennsylvania Providers Voice Health Care Consequences of Proposed “Public Charge” Immigration Policy
December 11, 2018
Pennsylvania hospitals and statewide organizations representing health care providers that serve Pennsylvania patients urged federal policymakers to reconsider a proposed immigration policy that will have direct consequences for the health of millions of lawfully present families and, in turn, impact the health of all citizens and communities.
A new policy issued by the U.S. Department of Homeland Security (DHS) could impact the ability of legal (lawfully present) immigrants to get a green card or become a citizen based on the extent to which they access and rely upon public benefits.
HAP submitted a formal public comment letter to DHS and joined a coalition of 15 organizations representing Pennsylvania health care providers in expressing a unified voice of concern of hospitals, health systems, community health centers, post-acute providers, physicians, and behavioral health providers.
Under the DHS proposal, when conducting a “public charge” determination, where the government considers if a legal immigrant is primarily dependent upon the government, the types of programs that the government considers would be expanded to include Medicaid, the Medicare Part D low-income subsidy, Supplemental Nutrition Assistance Program (food stamps or SNAP), and select housing programs. The public charge analysis would review the amount and length of time an individual received public assistance, and consider personal characteristics such as age and health status.
Broadening the definition of public benefits that are considered in the public charge determination and the scope of the review is anticipated to prompt legal non-citizen immigrants and their family members to disenroll or forgo health care and food benefits. This will increase the number of uninsured and result in adverse public health consequences.
Studies evaluating the impact of the proposal anticipate the rule will:
- Increase the number of uninsured by virtue of patients disenrolling from coverage
- Lead to poorer health outcomes as patients do not seek needed health care
- Reduce revenue and resources relied upon by health care providers, including significant reductions in Medicaid payments
An analysis by Manatt Health, Medicaid Payments at Risk for Hospitals Under the Public Charge Proposed Rule, estimates that 4.4 million noncitizen adults and children who receive Medicaid or Children‘s Health Insurance Program (CHIP) coverage, as well as 8.8 million citizen adults and children with Medicaid or CHIP coverage who are the family members of a noncitizen, are potentially affected.
Based on 2016 data, an estimated $17 billion in hospital payments could be at risk under the public charge proposed rule. Hospital payments to Pennsylvania could be reduced by as much as $216 million and the Philadelphia/Camden/Wilmington core-based statistical area, including 85 hospitals, would be disproportionately impacted facing a $232 million impact.
An analysis by the Milken Institute School of Public Health speaks to similar dynamics impacting patients and communities served by health centers. Based on conservative assumptions of the impact on legal noncitizen immigrants, the consequences for Pennsylvania specifically include:
- 8,000 legal immigrant health center Medicaid patients disenrolling from their coverage
- $7.6 million loss in Medicaid revenue for Pennsylvania health centers
- Nearly 8,000 fewer Pennsylvania patients served by Community Health Centers
- 83 full-time equivalent medical staff at Pennsylvania health centers impacted by staff reductions
In the joint letter, Pennsylvania health care provider organizations wrote:
The financial impact of a significant loss of Medicaid payments and an increase in uncompensated care will place a significant strain on hospitals and other providers already managing tight margins. Safety-net providers and health care providers in communities with large immigrant populations will be particularly hard-hit, affecting not only their fiscal health but their ability to serve the broader community.
The coalition letter also highlighted concern regarding the impact to access to healthy foods cautioning that the proposed policy will also chill access to food assistance programs that play a key role in stemming food insecurity. Families that face food insecurity are sicker, need more health care and ultimately generate more health care spending.
Turning back progress in addressing food insecurity will set back population health efforts by health care providers who are improving health outcomes and reducing health care expenditures.
The public comment period for the proposed rule closed on Monday, December 10. Thousands of organizations across the country echoed the concerns raised by Pennsylvania health care organizations.
HAP will continue to engage with likeminded stakeholders to advocate for access to health care coverage and food assistance programs, and keep the Pennsylvania Congressional delegation abreast of developments with respect to the proposed public charge policy.
Please contact Jeff Bechtel, senior vice president, health economics and policy, or Laura Stevens Kent, vice president, federal advocacy, with questions regarding the rule.