Wildfire engages in local, state, and national advocacy efforts.
Here are a few issues we’re keeping our eyes on – and ways that you can #IgniteLastingChange.




Notice of Proposed Rulemaking: SNAP Broad-Based Categorical Eligibility
Action needed by September 23, 2019, 11:59 pm Eastern Time 

The (USDA) has put forth a Notice of Proposed Rulemaking pertaining to Supplemental Nutrition Assistance Program (SNAP) Broad-based Categorical Eligibility (BBCE, or CatEl). The Association of Arizona Food Banks estimate this rule would immediately strip SNAP benefits from 40,000 Arizonans. It would also have a ripple effect on schoolchildren receiving free or reduced-cost school meals.

Broad-based Categorical Eligibility is a provision states can use to provide SNAP benefits to low-income households earning up to 185% of the Federal Poverty Level (FPL). Without BBCE, only those households earning 130% FPL or less would qualify for SNAP. That means a family of 3 would have to earn just $27,000 per year in order to qualify for SNAP – though we know that a living wage in Arizona is far higher than $27,000.

The USDA’s rule proposal would limit use of BBCE waivers to families receiving “on-going and substantial” Temporary Assistance for Needy Families (TANF) benefits. This could include TANF cash assistance or non-cash benefits funded through the TANF, such as child care or employment services.

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Final DHS Rule Issued: Public Charge

On August 14, 2019, The Department of Homeland Security (DHS) issued a final rule pertaining to how it determines green card eligibility. The new rule is scheduled to go into effect on October 15, 2019.

Immigration officials use the “Public Charge” test to determine if someone applying for entry or lawful permanent residency (a green card) is likely to become dependent on the government for support. Officials look at a “totality of circumstances” to make this determination, including an applicant’s financial status, health, education / skills, family situation, and whether they have an Affidavit of Support from a U.S.-based sponsor.

Previously, use of only two supportive services would negatively impact a person’s Public Charge test: receipt of government cash assistance (ex.: TANF or SSI) and/or residence in a government-funded long-term care facility.

The new rule makes substantive changes to the Public Charge test. If the rule goes into effect on October 15th as planned, negative weight will be assigned to applicants younger than 18 or older than 61, or those with an income less than 125% FPL. Use of the following benefits on or after October 15th could negatively impact a person’s green card application: Cash Assistance, government-funded long-term care, SNAP, housing assistance (such as Section 8 vouchers or rental assistance or public housing), Medicaid / AHCCCS (with exceptions for emergent medical care, pregnant women up to 60 days postpartum, children under age 21, some school-based services, and services provided through the Disabilities Education Act).

The rule also modifies the definition of “Public Charge.” The previous definition applied to applicants deemed likely to become substantially dependent on the government for subsistence. Under the new rule, a person who is deemed likely to use any of the benefits listed above for an aggregate 12 months out of a 36 month period would be considered a Public Charge. This means that use of SNAP and a Section 8 voucher at the same time for a duration of six months would count for a total of 12 aggregate months.

It is important to note that this test does not apply to all immigrants. Click here for more information about who is subject to Public Charge determination.

If you have specific questions or concerns, please consult an immigration attorney. Click here to view a directory of Arizona immigration resources.

Several lawsuits have been filed that could delay or block the rule from going into effect on October 15th. Wildfire will continue to keep you updated about advocacy opportunities pertaining to Public Charge.