National WIC Association

Weekly WIC Policy Update

October 22, 2018

Public Charge Template Comments Now Available
The US Department of Homeland Security (DHS) has requested the public’s comments on its proposed rule expanding the public charge test. The proposed rule would penalize immigrants if they access Medicaid, SNAP, or housing-assistance programs. The heightened risk to an individual’s immigration status would continue to disincentivize eligible families from accessing any public benefit program, including WIC.

The comment period is open until December 10, 2018, and your comments can be directly submitted to DHS here. Already over 22,000 individuals have commented on this proposed change since the public comment period opened on October 10!

Although WIC is not explicitly mentioned in the proposed rule, DHS has asked for the public’s input on whether any additional use of benefits by immigrants should be considered in public charge review. There remains a risk that WIC participation could be included in the final rule, and so we urge the WIC community to speak out now! You are the best voice to elevate WIC’s public health success, demonstrating the immense value that WIC contributes to mothers, children, families, and communities. DHS must learn through your public comments why WIC participation should not be considered in immigration determinations or the public charge test. Remember: Regulatory commenting is not lobbying. The federal government is actively soliciting your input to inform its decision-making.

To assist you in forming a comment, NWA has created template comments. In addition, NWA has drafted guidelines for concerned participants (available in other languages - see below) who may wish to comment in an individual capacity. Please note that DHS will accept comments only in English or with an accompanying English translation. These templates, along with other public charge resources such as talking points and the FAQ document, are also posted on NWA’s Immigration Resources webpage. Please direct any questions about the comment process to Brian Dittmeier at

Translations of NWA Template Comments Addressing Public Charge:

Election Day - November 6 - Approaches
This is a reminder to mark your calendars for Election Day - two weeks from tomorrow! There are important races throughout the US, including federal elections for Congress, gubernatorial races in 36 states, and state legislative and local races in many more.

Early voting is open in some states. This website provides information about early and absentee voting, voter-identification requirements, and other information specific to your state. Make sure to form a plan for voting and that you afford adequate time to submit your ballot.

You may wish to verify on your state elections website that you are currently registered to vote. Voter registration periods remain open in some states. Check today that you are registered to ensure that you have a say on Election Day!

WIC Votes
Early voting has already started in some states. If you have successfully voted in the election, we want to hear about it! Snap a selfie of yourself with your “I voted” sticker, and post it to Facebook and/or Twitter using the hashtag #WICVotes. This will connect you with all of the others in the WIC community who have also exercised their democratic right to help elect WIC advocates to federal, state, and local positions. If you have any questions, please email Brian at Please keep in mind that some states prohibit cell phone use (including taking photos with them) within polling places.

Congress in Recess Until Election; WIC Funding to be Addressed After Election
The House of Representatives has been in recess for weeks, but the Senate has similarly concluded its pre-election business after striking a deal to confirm lower-court judges two weeks ago. No major legislative debate is expected before the election, and the earlier passage of a continuing resolution until December 7 means that spending bills, including WIC funding through the agriculture appropriations bill, will not be addressed until later in November. Members are expected to be in their districts through the election.

This is one of the best times to engage with your member of Congress! Contact the offices of your representative or senator to learn about district visits and events in your area. It is important for members of Congress to understand all that WIC does to improve the quality of life for their constituents because that knowledge will inform their willingness to support, fund, and promote the program in the future.

Note: Attending a constituent event and sharing the broad, positive impacts of WIC in a local community is not lobbying. Lobbying requires that you ask a legislator to take a specific position on a piece of legislation. Remember the simple rule: Bragging beats begging.