8 ways to communicate strategically about proposed federal immigration rule changes

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When the Department of Homeland Security released a proposal this month that would deny green cards to immigrants who use public benefits, it sent waves of concern — and mobilization — throughout immigrant communities, public health organizations, and other social service providers.

At BMSG, with our mission rooted in the values of public health and social justice, we, too, are deeply disturbed by the far-reaching health impacts and repercussions on future citizenship applications that could result from expanding the so-called "public charge" rule.

Investing in the health of our communities, including our immigrant families, reaps benefits for everyone. But the current administration's "us versus them" rhetoric around immigration undermines the importance of our interconnection and our country's cultural diversity. Although the federal government must go through several more steps to finalize the rule, which means there are opportunities to intervene, it has already created fear. There are mounting reports of immigrant families and children dropping out of legally available health, food, and housing supportive services, all of which will impact health outcomes.

public charge communication tipsPublic health practitioners and many others across the country are speaking out against this proposed change in op-eds, letters to the editors, social media posts, and news stories. To support these efforts, we worked with Public Health Awakened to create an easy way for advocates to submit tailored comments to the Federal Register — make sure to comment before December 10!

We also developed some messaging tips to help advocates communicate effectively about the proposed federal changes and frame the issue in ways that further public health and social justice goals.

What is the public charge test?

Before developing talking points for the proposed expansion of the public charge regulation, it's important to understand what it is. Part of federal immigration law for more than a hundred years, the public charge test was designed to identify people who may use specific government programs and services that support health and well-being; until now, those programs have meant long-term nursing home care or cash-based assistance. Using the public charge test, the government can deny a person admission to the U.S. or deny lawful permanent residence (or green card status).

To deter people who are seeking to immigrate into or remain in the U.S., the current administration seeks to expand the public charge test so that it includes additional and essential health, nutrition, and housing programs. This has already created fear among immigrants and is having a chilling effect by discouraging people from using services they are legally allowed to access.

As important context, the history of the public charge test is an ugly one of discrimination. It was developed in 1882, the same year the Chinese Exclusion Act was created. Later, it was used to prevent Jewish refugees fleeing Nazi Germany from entering the U.S. It also has been used to prevent people with disabilities, LGBTQ individuals, immigrants, and unmarried women from entering the U.S. The proposed expansion threatens evidence-based programs with proven track records of success in improving health. The result: a sicker, hungrier, poorer nation.

Here are some tips and resources on the best ways to communicate about the proposed rule change:

1. Lead with your own frame, not your opposition's.

When we focus on rebuttals, we often inadvertently repeat — and reinforce — our opposition's argument. Maintain your own voice and perspective, reframe the issue, speak about why it matters to you, and explain what you envision as the solution.

For example, if we say, "Actually, data show that immigrants are not a drain and burden on our system and use fewer services than others in America," we have already primed people to think about immigrants as burdens and as "others." Instead, we can say, "Immigrants make enormous contributions to our economy, culture, and communities and use fewer services than others in America." Then, quickly move on to show what the proposed change will mean: children and families not accessing essential services and, ultimately, poorer public health for our communities.

Additionally, the archaic term "public charge" itself is problematic, as it presents the frame of immigrants as an expense to the public. If you reference the public charge test, we recommend using language such as "the proposed public charge expansion," rather than language that describes people as "public charges," which is dehumanizing. Based on advice from immigrant rights' groups, we recommend using it once to clarify which rule you are discussing, and then moving on from using the term.

2. Avoid the good/bad immigrant trap.

People come to the United States in many ways, under many circumstances, and for many reasons. However, we still see people communicating about the public charge test in a way that falls into the "good/bad" or "deserving/undeserving" language trap, such as implying that the proposed expansion is unfair because it will impact legal immigrants who "play by the rules." If we are focused on the public health impacts of immigration policy, we must be concerned with the health and well-being of all immigrants. Using divisive language will only make it more challenging in the long run for public health advocates to describe how current immigration policies are rigged against health and well-being and show why these policies need to change.

3. Tie your specific focus to broader public health impacts.

Public health has a stronger voice when we are unified. When we speak about only one program that the proposed expansion might impact without bringing in the broader context of how the entire rule expansion harms public health, we fall into the trap of working in silos. We can and should do both: Give examples of how the proposal is detrimental to housing, nutrition, health care, and other specific areas that impact health, and tie this back to the broad need for sound, comprehensive federal policy that prioritizes health, not partisan politics.

4. Be intentional about definitions and spokespeople.

Not only does the term "public charge" present the opposition frame, it's jargon. It's hard to define this complex regulation in a few sentences. Because of this, it can be easy to lean on official definitions that do little to clarify what the proposed expansion is and what the public health ramifications are, while also reinforcing dehumanizing language. For example, the U.S. Citizenship and Immigration Services (USCIS) defines public charge as an individual who is likely to become "primarily dependent on the government for subsistence…" By labeling individuals as public charges, the language repeats a frame that runs counter to our public health research and values.

In defining the regulation, seek out a public health source or language from those working on immigrant rights. Including voices of immigrant rights' groups or public health spokespeople can also help illustrate why this is a critical public health issue and why it matters. Immigrants as messengers can also use their voices and power to push back against the fear-mongering that's leading people to drop out of critical public health programs.

5. Build strong messages by including solutions and values.

Why does the proposed expansion of this rule matter? How does this go against not only public health values, but your own values as well? Whether it's interconnectedness, the idea that we are in this together, justice, fairness, dignity, unity, integrity, or something else, we need to make the values that drive our work visible in our messages.

A simple formula for effective messages is to include: the problem, the solution, and why it matters (not necessarily in that order). Advocates often spend the bulk of their time delving deep into the problem. Comments to the Federal Register should describe the public health impacts with details, data, stories, and examples, as it's important to clearly describe the public health problem to the federal administration. However, even in the comments — and especially when we are talking to the media, elected officials, partners, and our own friends and family — our aim should be to keep our values and solutions front and center. Devoting more of our letters, statements, talking points, or testimonies to the solutions and putting values up front can help others connect to the issue in a way that data or facts can't.

6. Use inclusive language.

Few of us are immune to "otherizing" language creeping into our communication. Challenging the basis for this proposed rule is both an opportunity to strengthen our message and actively work to undo the legacy of racism and oppression that is part of our nation's history by understanding how it still manifests in our work and language today.

Using terms like "them" often happens in public health reports or statements. Instead, use language that helps show interconnectedness and shared fates (e.g. "We can create a community where everyone can thrive by asking the Department of Homeland Security to withdraw the proposed expansion to the public charge test").

Watch out for terms like "needy" and "burden," even if it's to rebut false claims that immigrants use a disproportionate amount of programs and services. Terms like "alien" and "illegal" are extremely pejorative and should never be used.

And while it's part of our nation's history, equating immigrants with the "tired, poor, and huddled masses" can also paint a narrow, one-dimensional view of immigrants that diminishes the great contributions immigrant communities have made — and are making — in the U.S. Instead, use words and images that highlight people recognizing and building their power to create healthy communities.

7. Avoid passive voice.

When we use passive voice, we obscure who is (or should be!) taking action, whether it's a positive action we support or a negative action that we want to stop. Passive voice makes it sound like things just "are" when, in fact, people make them that way, and people can change them. Passive voice can also add extra words that you don't need. For example, instead of saying "the expansion of the public charge was proposed" we can say "the federal administration proposed expanding the public charge test."

8. Underscore the divisiveness of this proposed rule.

When we call out the strategies that use race to divide us, we help people see what they really believe: that unity is the key to healthy, robust communities where everyone can thrive. The administration is using the expansion of the public charge rule as an effort to divide us by making immigrants the "other." We know better. And we know that we are better — and healthier — together.

Put these tips into action by submitting a comment to the Federal Register before December 10.

Want to learn more? The Protecting Immigrant Families coalition has many resources on the public charge test. The Bay Area Regional Health Inequities Initiative has also developed messages on this issue for local health departments and their partners.

What do the proposed public charge regulation changes mean to you? Have you seen examples in the media or elsewhere of effective messages on the public charge test and its link to health? Let us know at info@bmsg.org, @BMSG, or on Facebook. And join the broader conversation about public charge and health using the hashtag #ProtectImmigrantFamilies.


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