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Association Comments on DACA Proposed Rule

America’s Essential Hospitals submitted comments on a proposed rule to strengthen and preserve the Deferred Action for Childhood Arrivals (DACA) policy, which is critical to the nation’s health care workforce.

As demonstrated during the COVID-19 pandemic, a steady and reliable supply of health care practitioners is critical to the nation’s response to public health crises. Preserving the DACA policy and protecting it from arbitrary changes can ensure continuity for hospitals and health systems, which rely on immigrants to strengthen their workforce.

The Department of Homeland Security (DHS) intends to use the notice-and-comment rulemaking process to formally codify the DACA program. The program has been subject to a legal challenge, in part, on the basis the Obama administration violated the Administrative Procedure Act because it bypassed the rulemaking process to establish the program in 2012.

In its comments, the association expressed its appreciation of the administration’s commitment to strengthening the DACA program. America’s Essential Hospitals urged DHS to formally add the DACA policy to its regulations through the notice-and-comment rulemaking process, which will provide additional stability for DACA recipients, the health care workforce, and the broader economy by removing uncertainty about the policy’s future.

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.

About the Author

Abigail Painchaud is a policy associate at America's Essential Hospitals.

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