The proposed public charge rule, issued by the United States Department of Homeland Security (DHS) on October 10, is likely to have a significant spillover effect on community health center services and capacity. If this rule is adopted, hundreds of thousands of patients could lose access to comprehensive primary and preventive health center-based care, according to a new analysis from the Geiger Gibson/RCHN Community Health Foundation Research Collaborative at the George Washington University’s Milken Institute School of Public Health (GW Milken Institute SPH).

Previous studies suggest that federal policy changes concerning the use of Medicaid can produce a chilling effect on enrollment among both eligible legal immigrants and their family members. Applying prior research about the chilling effect and its spillover impact to the proposed new public charge rule, a research team led by Leighton Ku, PhD, Professor of Health Policy and Management, determined that:

• The rule’s chilling effect could cause between 354,000 and 646,000 community health center patients to forgo Medicaid coverage.
• As a result, health center revenue would markedly decline. Total Medicaid revenue losses associated with this loss of coverage would range between $346 million and $624 million.
• These revenue losses would result in clinical staffing reductions – including physicians and nurses – of 3,400 to 6,100 FTEs.
• As health centers’ capacity for patient care declines, between 295,000 and 538,000 patients nationwide could lose access to primary care.

Community health centers are an indispensable part of the health care system, which by mission and law serve all members of their communities. The proposed public charge rule does not classify community health centers as a public benefit for the purpose of public charge determination. But this analysis demonstrates that the chilling effect created by the proposed rule could have substantial consequences for health centers, and broad and deep community-wide impact, affecting citizens and non-citizens alike.

The brief, “How Could the Public Charge Proposed Rule Affect Community Health Centers?” includes state-specific impact estimates. The study is part of the Collaborative’s ongoing policy research series and is now available on our website.