Q2: What about other COVID-19 public benefits, such as for food, housing, cash assistance, rental assistance, tax credits, stimulus payments, unemployment, financial aid grants to students, Paycheck Protection Program, and student loan forbearance? *

A2: We do not consider public benefits specifically related to COVID-19 because they generally fall under either noncash benefits or special-purpose cash benefits not considered under the 1999 Interim Field Guidance. We consider only those benefits listed in the 1999 Interim Field Guidance, such as cash assistance for income maintenance (for example, SSI and TANF) and General Assistance (in other words, cash assistance provided by states or localities), as well long-term institutionalization provided at a government’s expense.

The 1999 Interim Field Guidance acknowledges that states have flexibility in administering the TANF program and may choose to provide noncash assistance such as subsidized childcare or transportation vouchers in addition to cash assistance. It indicates that such noncash benefits should not be considered for public charge purposes. It also indicates that states may also provide nonrecurrent cash payments for specific crisis situations under TANF. These payments should not be considered for public charge purposes under the 1999 Interim Field Guidance because they are not cash for income maintenance.

While the 1999 Interim Field Guidance does not provide a comprehensive list of benefits that we do not consider, cash assistance related to COVID-19 is like disaster assistance or crisis-based cash TANF, and therefore, we consider such is special-purpose cash assistance that is not cash assistance for income maintenance. Therefore, we do not consider it in public charge determinations. Also, under the 1999 Interim Field Guidance, we do not consider noncash benefits (except those supporting noncitizens receiving long-term institutional care). Therefore, we do not consider COVID-19 related food/nutrition assistance, housing assistance, tax credits, student loan forbearance, and the like, in making a public charge inadmissibility determination.