if received on or after the effective date of the final rule, detroit lions national football league ugly christmas sweater and given that this rule published on August 14, 2019, aliens will have sufficient time to disenroll from Medicaid and enroll in private
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Some commenters stated the rule would have negative consequences on families and “grand families,” including family separation. detroit lions national football league ugly christmas sweater Another commenter stated that the proposed rule could be retroactively applied so that immigrants’ receipt of benefits prior to the effective date of the rule would be considered in a public charge determination. The commenter provided readings of the proposed regulatory text against the 1999 Interim Field Guidance, arguing that SNAP, specifically, could “fall through the cracks.” Other commenters stated that this part of the rule lacked clear guidance and proved difficult to implement, providing examples and saying this section will be unfair and unworkable. A commenter requested that DHS use the “primarily dependent” standard for TANF,
SSI, and general assistance benefits received prior to the effective date of the rule. A commenter said this portion of the rule is in contrast with what many social workers have advised their clients on in the past. With respect to comments requesting time so aliens can move from Medicaid to obtaining private health insurance through the ACA marketplaces, DHS notes that it believes aliens will have sufficient time to obtain private health insurance through the ACA marketplaces. Additionally, Medicaid benefits included in the definition of public benefit will only be a heavily weighted negative factor in the totality of the circumstances if the alien receives Medicaid for more than 12 months in the aggregate, beginning 36 months before the alien filed for adjustment of status. The open enrollment period for 2020 will run from November 1, 2019 to December 15, 2019. Because USCIS will only consider benefits covered under this final rule
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