Food Over Fear: Push Back on the Proposed Public Charge Rule

1. How to Use This Model Comment

• • This model comment provides sample language only. Your comment will be far more powerful if you personalize it to reflect your organization’s mission, expertise, and the communities you serve.
  • Please do not submit the model comment verbatim. Tailoring your comment strengthens its impact and ensures DHS receives meaningful feedback.
  • If your organization primarily works on SNAP, you may emphasize the SNAP-specific harms and data.
  • If your organization focuses on child nutrition programs (e.g., School Meals, CACFP, Summer EBT) or WIC, you should highlight those impacts and shorten or remove sections that are not relevant.
  • The model comment includes optional research summaries on SNAP, WIC, and the Child Nutrition Programs. You may include as many or as few of these as are helpful, and you should select data points that resonate with your state or your experience.
  • Wherever you see highlighted brackets — e.g., [insert organization description], [insert state examples], or [select data], please replace these with your own language.
  • You may also reference state-specific SNAP impacts using the link provided in the SNAP section.

2. Sections of the Model Comment

• • Introduction and Organizational Background
    Introduce your organization, your mission, who you serve, and why this rule is of urgent concern.
  • Overview of the Proposed Rule and Why It Must Be Withdrawn
    Explain how the NPRM removes long-standing guardrails, expands what can be considered in a public charge determination, and creates fear and uncertainty.
  • Impact on Nutrition, Health, and Well-Being
    Describe how the rule would cause eligible families, including U.S. citizens, to forgo SNAP, WIC, School Meals, and other programs. Select research findings that best support your points.
  • Impact on States, Schools, Providers, and Local Economies
    Highlight the proposed rule would shift costs to states and localities, the impact on businesses, and the compounding effect of recent SNAP cuts under the budget reconciliation law (H.R. 1).
  • Historical Evidence of Chilling Effects
    Use this section if helpful to show that similar policies have previously caused steep declines in benefit participation, even among eligible families.
  • Conclusion
    Restate your recommendation that DHS withdraw the proposed rule and instead strengthen policies that support immigrant and U.S. citizen families.

3. How to Submit Your Customized Comment

• • Visit Regulations.gov: https://www.regulations.gov/commenton/USCIS-2025-0304-0001
  • Attach your customized comment as either .docx or .pdf in the “Attach Files” section of the page.
  • Complete the form and “Submit Comment.”
  • Be sure to submit your comment no later than December 19, 2025.

4. Need Assistance?

If you have questions or would like help customizing your comment, please contact Gina Plata-Nino, FRAC SNAP Director, or Kate Scully, FRAC Deputy Director of WIC. We are available to support your drafting process, help identify state-specific data, or advise on how to tailor your comments to your organization’s focus.

Find additional resources to help you craft your message:

• • FRAC Blog: Food Over Fear: Trump Administration’s Attacks Against Immigrants Continue With New Proposed Rule to Change Public Charge Criteria 
  • WIC Is A Critical Economic, Nutrition, and Health Support for Children and Families
  • Hunger & Health: The Role of the Supplemental Nutrition Assistance Program in Improving Health and Well-Being
  • Protecting Immigrant Families Public Charge Toolkit