IWS Update

This month, the IWS team has been responding to several notices of proposed rulemaking (NPRMs) or changes issued by the Biden Administration.  

• On July 13th, the U.S. Department of Housing and Urban Development (HUD) announced its plan to use private sources of rental data in the agency’s annual Fair Market Rents (FMRs). This innovation by HUD could produce more accurate estimates of rental costs in cities and counties across the U.S., in turn making it easier for people who receive a housing choice voucher (HCV) to find an affordable unit. CLASP responded in support of HUD’s proposal.  
• The U.S. Department of Agriculture (USDA) proposed a rule in late June disallowing state agencies from collecting race and ethnicity data by observation. In our response, CLASP supported the Biden Administration’s decision, encouraging states to co-define racial and ethnic categories with community members and be more mindful of racial trauma by, for example, clarifying that applicants’ identities will not impact their access to benefits.  

We have also submitted comments supporting Washington State’s request to provide continuous coverage of Medicaid-eligible children up to age 6. We are now turning to recent proposals from the Centers for Medicare and Medicaid Services related to Section 1557, which is the clause of the Affordable Care Act (ACA) that protects people from discrimination, and streamlining Medicaid enrollment/renewals.  

On September 9, the Department of Homeland Security (DHS) published a final rule detailing how the agency will administer the public charge ground of inadmissibility. The finalized rule closely tracks the long-standing guidance that was in place from 1999 to February 2020, when the Trump Administration upended the existing public charge policy. The rule will go into effect on December 23, 2022. Until then, the 1999 field guidance remains in effect. CLASP released a statement thanking the Biden Administration for its work on this rule and the many immigrants, service providers, and advocates who have fought against the previous administration’s weaponization of public charge – that means you! We couldn’t have gotten here without all of you. 

The Biden Administration officially announced its student loan forgiveness plan, which would provide between $10,000 and $20,000 in debt relief to college students and graduates. Importantly, people who did not graduate college but took out federal loans are also eligible. As CLASP’s Executive Director Indi Dutta-Gupta explained in an interview with CNN, "About 40% of people with student debt have no college degree.” In addition, Biden’s plan would make much-needed revisions to the income-driven repayment program for undergraduate loans, reducing the percentage of income used to determine a federal borrower’s monthly loan payment from 10 to 5 percent. The plan would also cover the borrower’s unpaid interest so their balance will not grow. Although the Biden Administration’s plan will fully relieve about one-third of borrowers’ debts, it doesn’t go far enough. The average Black borrower owes $53,000 four years after graduation, while the average white borrower owes $28,000. Therefore, canceling $50,000 of student loan debt per borrower would immediately increase the wealth of Black Americans by 40 percent, according to a brief from the Roosevelt Institute.