Is Program Integrity Just Code for Anti-Immigrant?

Lawmakers on Capitol Hill speak frequently about "waste, fraud, and abuse" in federal programs. From subsidized school meals that feed low-income children to refundable tax credits that incentivize work and offset child-rearing costs, it seems to these lawmakers that the federal safety net is rife with over-payment. The term "program integrity" has recently come into vogue to address the alleged rampant exploitation of the government's assistance.

It has become clear, however, that when lawmakers discuss "waste, fraud, and abuse" and "program integrity," these are really just terms of art to justify denying immigrants (and others in need) access to federal programs. While immigrants are already explicitly barred by statute from participating in many of these programs, regardless of whether their status is lawful or not, members of Congress seem determined to limit the few programs that remain.

At the end of last year, for example, Congress enacted a $680 billion tax package that made a number of tax credits permanent and extended others. The legislation also included a "program integrity" title that imposed burdensome requirements for some immigrants who pay their taxes with an Individual Taxpayer Identification Number. Some members of congress said that this language was necessary to combat "waste, fraud, and abuse" and prevent over-payment within the Child Tax Credit and Earned Income Tax Credit. But reports consistently point to IRS capacity, paid tax preparers, and the sheer complexity of the tax code, as the true sources of error in both the Child Tax Credit and the Earned Income Tax Credit. For this reason, the only logical conclusion to draw about the purpose of the new ITIN requirement is that it is designed to prevent immigrants from more easily filing taxes, and by extension, from claiming the refundable tax credits for which they are eligible.

Similarly, the Senate Agriculture Committee recently held a mark-up of a bipartisan child nutrition reauthorization bill. The legislation also includes a "program integrity" provision to increase verification of school meal programs. It has been claimed that schools have given away roughly $20 billion in free and reduced price lunches to children who do not deserve them by virtue of not being quite poor enough. Under the new scheme, children with immigrant parents are likely to bear the brunt. The proposal increases the number of applications that would be certified directly through participation in public benefit programs like SNAP or TANF, yet U.S. citizen children with immigrant parents are not eligible for these federal programs. As a result, more of these families will receive confusing letters asking for additional proof of income, and many children will not eat lunch due to high levels of non-response. Yet there is little evidence to suggest that verification through family contact is effective at rooting out "waste, fraud, and abuse."

Attempts to deny immigrant eligibility through "program integrity" are misguided by the narrative that motivates them: immigrants are leeches on society, coming to the United States simply to enroll in public benefits. This misleading and exploitive point of view continues to be deeply harmful to those most in need. As immigrants seek to make a life in the United States and adapt to American culture and values, the pervasive idea that they do not contribute and are not part of our social contract undermines their ability to be successful.

Whatever problems may exist in our federal safety net, the answer is not to demonize the working poor and immigrants. We should not enact policies that make it more difficult for citizens and immigrants alike to cope in difficult times. We should instead be enabling full integration into civic and economic life. To achieve this, lawmakers must resist the urge to further restrict immigrant eligibility for programs under the guise of "reducing improper payments" and "program integrity." The way to genuinely limit improper payments in these programs is to make them simpler and clearer, to eliminate the need for costly professional tax and benefits help that those in need often lack access - and to ensure that those eligible for such programs receive the benefits for which they are intended.