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Boundless Comments on Impact of Current Immigration Policies on U.S. Military Members and Veterans

Nov 11, 2019

On behalf of Boundless, we are grateful for the opportunity to express our concerns about the impact of current immigration policies on service members, veterans, and their families.

At Boundless, we strive to empower families to navigate the immigration system confidently, rapidly, and affordably. In recent months, we have seen firsthand the adverse effect that the government’s sweeping new immigration policies have had on immigrants and their loved ones.

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Among the recent measures that U.S. Citizenship and Immigration Services (USCIS) has pursued to restrict legal immigration, the “public charge rule” could have the biggest impact. The policy would deny immigrant visas to applicants who are deemed likely to use public benefits, using a multi-factor test so confusing and subjective that it will no doubt lead to chaos and delays throughout the legal immigration system.

IMPORTANT UPDATE — MARCH 9, 2021: Both the new Department of Homeland Security (DHS) public charge rule and the Department of State (DOS) public charge policy are currently not in effect. The DHS rule was halted on March 9, 2021, while the DOS policy was paused indefinitely on July 29, 2020. This page reflects those policies, which initially took effect on Feb. 24, 2020, and will not be immediately updated according to the previous, longstanding guidance issued in 1999. Learn more.

Public charge rule keeps apart military members and their families

If enacted, the public charge rule could prove devastating to the families of U.S. citizens, including military families. In our public comment opposing the rule, we wrote that it “will prevent the families of U.S. military veterans from living together in the United States, despite DHS’s assertion that the government is ‘profoundly grateful for the unparalleled sacrifices of the members of our armed services and their families.’” My team at Boundless created the Public Charge Risk Estimator, a free tool that helps families estimate their risk of denial under the new rule. For a deeper understanding of just how complex the USCIS public charge test would be, I encourage Members of the Subcommittee to visit our website and try out the calculator for themselves.

Another pending version of the public charge rule, led by the Department of Justice, would make it easier to deport U.S. lawful permanent residents who have used public benefits to which they are legally entitled by Congress. The policy could affect thousands of veterans who are eligible to receive public benefits, including healthcare and nutritional assistance — the same benefits penalized under the public charge rule.

Roadblocks to citizenship for service members

Barriers to U.S. citizenship have also measurably worsened over time, including a policy change in Oct. 2017 that makes it harder for service members to receive expedited citizenship due to additional background checks and increased active duty requirements. Military naturalizations have since dropped by 44 percent between FY2017 and FY2018. The government has also denied more military naturalization applications, from 10 percent in FY2017 to 15 percent in FY2018.

Deny citizenship to certain military children born abroad

In a widely-criticized move, DHS announced another policy change that would deny automatic citizenship to children born to certain U.S. military members abroad. While the rule only affects relatively few individuals, it places unnecessary hurdles before military families who already have enough challenges to contend with. “In what possible universe does it make sense to make it harder for our service members overseas to do this and who want to serve overseas?” former White House policy advisor and Boundless co-founder Doug Rand told NBC.

End family-based reunification programs

In another harmful action to veterans, the government announced in August that it would terminate the Filipino World War II Veterans Parole program, which allowed family members of Filipino soldiers who supported the U.S. during WWII to enter the United States while they waited for their visas to be approved. The government gave no convincing reason for ending the program, with USCIS Acting Director Ken Cuccinelli calling out parole programs as a way for would-be immigrants to “skip the line.”

Another parole program, called Military Parole in Place (PIP), has been left alone so far, but its future is uncertain. The government is currently reviewing the program, which allows certain undocumented family members of U.S. military members to stay and work in the U.S. Although PIP hasn’t yet been terminated, members of the American Immigration Lawyers Association (AILA) have reported a higher rate of denials and long wait times for applications at local USCIS field offices.

These policies all add up to a net loss for the United States and its core values, and show a stunning disregard for the sacrifices that members of the U.S. military have made for this country. Thank you for your time and attention to these critical matters. If you have any questions regarding this letter for the record, please don’t hesitate to contact me at [email protected].


Xiao Wang

CEO and Co-Founder

Boundless Immigration Inc.

Boundless — for people who want the expertise
of an immigration lawyer, not the price tag.