The federal government released the final version of the public charge rule this week. My colleague David Bier covered it extensively while some of our other Cato research on immigrant welfare use and how to reduce it was also prominently featured. Unexpectedly, the published public choice rule contained a gem that seems to settle a long-running methodological disagreement between Steven Camarota of the Center for Immigration Studies (CIS) and myself on how best to measure immigrant use of welfare.


First, some background. Cato has published two studies of immigrant welfare use since 2013. Cato published the first such paper in 2013 that was written by Professor Leighton Ku, Director of the Center for Health Policy Research, and Brian Bruen, Lead Research Scientist & Lecturer in George Washington University’s School of Public Health and Health Services, Department of Health Policy. Their paper found that:

[L]ow-income non-citizen immigrants, including adults and children, are generally less likely to receive public benefits than those who are native-born. Moreover, when non-citizen immigrants receive benefits, the value of benefits they receive is usually lower than the value of benefits received by those born in the United States. The combination of lower average utilization and smaller average benefits indicates that the overall cost of public benefits is substantially less for low-income non-citizen immigrants than for comparable native-born adults and children.

Later in 2013, my former colleague Sophie Cole and I wrote another paper on how Congress could build a more effective wall around the welfare state by denying all benefits to non-citizens. That paper relied on some of the original empirical research by Ku and Bruen. Our ideas and others were eventually incorporated into an excellent bill introduced by Representative Grothman (R‑WI) in 2018. 


Last year, we published another paper that updated Ku and Bruen’s work with some minor changes. We expanded their analysis to the rest of the welfare state and presented findings that removed the controls from their first study. We found that “[o]verall, immigrants are less likely to consume welfare benefits and, when they do, they generally consume a lower dollar value of benefits than native-born Americans.”


Each time we’ve published these papers, Steven Camarota or others have criticized them in print. I’ve also criticized their work when they publish their immigrant welfare cost estimates. Here are just some of the exchanges. The most substantive outstanding methodological disagreement that remains between us was whether to count the welfare benefits used by individuals only or to include the welfare consumed by anybody in an immigrant-headed household too.


We’ve long thought that counting individual-level welfare consumption was the best method as welfare consumed by native-born American spouses and children is not welfare consumed by immigrants. Controlling for the unit receiving the welfare benefit is required to make apples-to-apples comparisons between native and immigrant welfare use. Since households vary in size and many contain immigrants living with natives, looking at individuals is the best way to control for that. Furthermore, a person’s eligibility for welfare and for determining the value of most welfare programs depends upon the applicant’s individual circumstances.


Camarota and CIS have long argued that the welfare consumed by an immigrant-headed household is the appropriate measure, even if that includes welfare consumed by some native-born spouses and children. Camarota argues that some of that welfare spending only occurred because of the immigrant being present here. This methodological choice matters quite a bit in the final analysis, with household measures reporting a higher welfare use rate and dollar value of consumed benefits while individual-level assessments generally find lower levels of benefit consumption.


The new public charge rule produced by President Trump’s Department of Homeland Security (DHS) sides with Cato on this dispute for the purposes of estimating future immigrant welfare use and for tallying past usage. Here is just one example of what DHS wrote:

This final rule also clarifies that DHS will only consider public benefits received


directly by the alien for the alien’s own benefit, or where the alien is a listed beneficiary


of the public benefit. DHS will not consider public benefits received on behalf of


another. DHS also will not attribute receipt of a public benefit by one or more members


of the alien’s household to the alien unless the alien is also a listed beneficiary of the


public benefit.

This isn’t a surprise as academics measure welfare use on the individual level and DHS counts welfare use by looking at individual’s immigration statuses, not by the fanciful “immigrant-headed” method which is probably statistically meaningless. However, it is nice to have President Trump’s DHS side with Cato’s methodological choices in evaluating immigrant welfare use. I look forward to CIS changing its methods in future iterations of its immigrant welfare research.