Learn about upcoming & final federal rules, submit your comments, & more.
Learn about upcoming & final federal rules, submit your comments, & more.
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Mobilizer
May 31, 2019 | Volume 23, No. 5 | Archives
HCH Advocacy in Action
Last week Health Care for the Homeless (HCH) community members from all over the country convened at our national conference in Washington, D.C. During the conference, HCH advocates (including those with the lived experience of homelessness) met with over 100 offices on Capitol Hill to discuss substance use disorder policy, affordable housing investments, health center funding, and Medicare for All. Did you go to a meeting on Capitol Hill? Let us know how it went!
HCH Advocates from Maryland, Ohio, and Texas on Capitol Hill during the 2019 Conference.

The conference, the meetings on Capitol Hill, and the Rally for human rights at the closing, served as a much-needed reinvigoration for the work ahead. This summer we face many disturbing proposed and finalized rules from the Administration that compromise our nation’s values of dignity, equality, respect, and independence. HCH advocates know that it can often feel like an impossible task to achieve health care and housing as human rights. Yet, this last week reminded us: we will never stop fighting until these human rights are available to ALL. We invite you to join us in this fight. Start by taking action on the two proposed rules open for comment (learn how below under Two PROPOSED Rules Currently Open for Comment). As our Sr. Policy Director, Barbara DiPietro, said at the closing of the Rally, “Revolution starts in the hearts and minds of the people. Let’s all stand up. Let’s all speak out. Let’s all demand what is ours by RIGHT.”
HCH Advocates at the Rally for Human Rights outside of the White House at #HCH2019
Federal Rules
What is "Rule Making?"
When federal agencies want to create a new policy, they must publicly publish the details of the proposed new policy (often called a “proposed rule”) and allow stakeholders 60 days to submit comments (called a “public comment period”). After the comment period closes and before finalizing a rule, the agency must review the comments and—ideally—take into consideration the feedback received and make revisions before finalizing the rule (though the agency is not required to make any changes). Final rules can be challenged in court, which may halt or delay their implementation. Comments submitted during the public comment period are often used in the court proceedings. Thus, it is critical that those on the front lines of housing and health care submit comments on rules that affect their work in order to build the case against harmful changes.
There are currently numerous rules being proposed that would limit access to health care and housing for people experiencing homelessness—two that are currently in the public comment period and ripe for action now are outlined below.
Two Proposed Rules Currently Open for Comment
  • Proposed Rule Would Prohibit “Mixed-Status” Immigrant Families from Living in Public Housing: This rule would prohibit families that include someone who is undocumented from living in public and other subsidized housing, despite the fact that ineligible immigrants are already not allowed to benefit from federal housing subsidies. The rule would directly affect over 100,000 people through evictions, and put tens of thousands of families and children at increased risk of homelessness. 

    Take Action by submitting comments: our partners at the National Low Income Housing Coalition and the National Housing Law Project have resources, fact sheets, social media guides, templates, and instructions for commenting. Individuals (yes you!) and organizations can submit comments. Comments are due by July 9, 2019.
Submit Comments
  • Proposed Rule Would Shrink Poverty Line: This rule proposes to change the way poverty is calculated for low-income households, using a lower rate than is currently used. Hence, fewer people would be considered “poor.” It is estimated that over half a million would lose eligibility for Medicaid, and thousands more would lose eligibility for SNAP/food stamps, housing assistance, and other programs.

    Take Action by submitting comments: our partners at the Coalition on Human Needs have a portal and home page with step-by-step guides, comment templates, and resources. Individuals (yes you!) and organizations can submit comments. Comments are due by June 21, 2019.
Submit Comments
Two Proposed Rules Open for Comment Soon
  • (Upcoming) Proposed Rule Would Weaken Equal Access to Shelter and Housing for LGBTQ People: This rule would overturn existing protections under the Equal Access Rule for LGBTQ individuals seeking shelter and allow homeless shelters to write policies that prevent individuals from entering shelters based on their sex and gender identity. The Equal Access Rule is critical to ensure safe access to shelter for LGBTQ people experiencing homelessness, survivors of violence, and those fleeing disasters. Mark your calendars: for now, follow updates from the National Low Income Housing Coalition and keep an eye out for the proposal and templates in our next Mobilizer. The rule is expected to be released and open for comments in the coming months.

  • (Upcoming) Proposed Rule Would Roll Back Protections for LGBTQ Patients in Health Care: This rule would repeal protections in the Affordable Care Act’s section 1557 that prohibit discrimination in health care settings based on sex, gender identity, immigration status, and other factors--all done under the guise of religious freedom. If implemented, this rule would allow health care providers and insurance companies to deny access to health care for those who are LGBTQ. Mark your calendars: for now, follow updates from our partners at the National Health Law Program and keep an eye out for the proposal and templates in our next Mobilizer. The text of the proposed rule is available here. It will be published on the federal register and open for comments soon. 
Three FINAL Rules
  • Religious Freedom in Health Care Rule is Finalized: This final rule establishes an extensive set of new rules that will make it easier for health care workers to refuse to provide care that violates their religious or moral beliefs, which could include the provision of birth control, treatment related to HIV, the provision of Narcan or Suboxone for those with opioid use disorder, services related to LGBTQ care, immunizations, or any other service that may conflict with an individual belief. All health care providers, to include health centers, will be significantly impacted by this rule.  An overview is available in Health Affairs, and we await updates on a court challenge issued earlier this month in California. As we learn more we will share information on the impact to the HCH community.  Read our comments on the proposed rule. 
  • Title X Final Rule is Blocked by a Federal Court: This final rule, known as the “domestic gag rule” will prohibit clinics that refer or provide abortions from receiving family planning funds through the Title X program. Following lawsuits from Planned Parenthood, the American Medical Association, and multiple states, a U.S. District Judge issued an injunction to stop the rule from taking effect as the lawsuits are in progress. Read more from Vox. As we learn more we will share information on the impact to the HCH community. Read our comments on the proposed rule. 

  • Public Charge Rule to Be Finalized this Summer: This rule allows a legal immigrants' use of public health insurance, nutrition, and other programs to be considered as a negative factor in their applications for legal permanent residency. While the final rule isn’t expected until later this year, there are disturbing reports of the chilling effect keeping people away from care. Our partners released a fact sheet on how to talk with your patients and community members about public charge. If you’ve noticed an impact, please let us know.  Read our comments on the proposed rule.
What We're Reading
New Resource
Check out our new policy brief, Medical Respite Care Programs and the IHI Triple Aim Framework, and register for the accompanying webinar on June 5.
Read the Brief
What's Next
Mark your calendars for Congress’ recess during the month of August. This is the best time of the year to invite your members of Congress and/or their D.C. staff to visit your program, see the work you’re doing on the ground, and talk with you about the changes needed to make improvements. Next month, the Mobilizer will include invitation templates and tips on making the visit a success but we encourage you to reach out to your Congress member’s office ASAP.  Let us know how we can help.
Did you receive Mobilizer as a forwarded email or hear about it via social media? Register now to receive our action alerts each month!
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Regina Reed, MPH
National Health Policy Organizer
National HCH Council
Baltimore, MD
rreed@nhchc.org
(443) 703-1337 
This publication and all HCH advocacy are funded by dues from Organizational Members of the Council and by private donations. Consider joining the Council to support this work.
PO Box 60427 | Nashville, TN 37206 US
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