DHM Comment on Immigration Policy

Dear DHM,

In collaboration with the Social Medicine Core, the Division may, on occasion, make official comments about policies, proposals, legislation, initiatives, etc. which may potentially impact our patient population or our ability to provide high-quality, safe, effective, and equitable care. These comments will be sent to the Division by email and posted on the website. When appropriate, we may write formal letters to key stakeholders.

Please see below for our comment regarding a proposed change which could adversely impact our patients. Please let me know if you have any questions or concerns about this or any future comments.


Division of Hospital Medicine at UCSF Health

(written in conjunction with the DHM Social Medicine Core)

We are writing in regard to a potential modification in immigration policy which could impact our patient population. Specifically, the federal government has proposed to expand the criteria used to determine if an immigrant is likely to become a “public charge.” A “public charge” is formally defined as someone one who is primarily dependent on the government for subsistence.

Current immigration policy values self-sufficiency—if an immigrant is likely to become a “public charge,” his or her immigration application may be denied. Historically, this determination considered the use of certain cash benefits such as supplemental security income or long-term care benefits. The proposed expansion, however, would now consider the use of additional public benefits such as non-emergency Medicaid, Medicare Part D Low-Income subsidy program, and various housing support services (e.g., Section 8 Housing Choice Voucher Program). Immigrants seeking to become “legal permanent residents” or “greencard” holders and individuals seeking to immigrate to the United States who use these benefits may have their immigration applications denied.

A concern is that the policies proposed in this rule would deter immigrant families from accessing health and human service programs that keep them healthy and productive like Medicaid and the Supplemental Nutrition Assistance Program (SNAP). Widespread confusion about which benefits are and are not included in the public charge determination could also lead to families avoiding programs that are not part of this proposed rule. The chilling effect could jeopardize the health of millions of families.

In addition, with this proposed expansion, patients with medical conditions that require hospitalization may face difficulties in the immigration application process. We hope all our patients view us as a resource for them and their communities, and never fear that accessing medical services (both in and out of the hospital) could jeopardize their livelihood in this country. We in the Division of Hospital Medicine are committed to ensuring safe and high-quality health care for all who choose to come to UCSF regardless of their immigration status. We denounce the proposed rule and support Chancellor Sam Hawgood’s statement voicing UCSF’s stance on this issue.

We encourage you to comment on this change during the 60-day public comment period, which ends December 10. In your comment, highlight your credentials and share your story and those of your patients/friends/family members who might be affected by the proposed rule change. Linked are some additional tips for submitting an effective comment.

We also encourage you to sign up for UCSF Advocates, which will notify you of UCSF educational, clinical care, and research advocacy efforts locally and nationally.


Brad Sharpe

Bradley A. Sharpe, MD
Professor of Clinical Medicine
Division of Hospital Medicine
University of California San Francisco (UCSF)