Thank you for the opportunity to provide comments on the Department of Homeland Security’s (DHS) interim final rule (IFR), Removing 30-Day Refugee Termination Notice. The Colorado Health Foundation (“CHF” or “the Foundation”) is a statewide, nonprofit and nonpartisan philanthropic organization with a mission to improve the health and well-being of Coloradans. Through community engagement, research, grantmaking, and private sector investments, the Foundation works to ensure that everyone in Colorado has what they need to be healthy.
The Foundation recognizes DHS’s responsibility to maintain the integrity of the U.S. refugee program and address cases in which the Department determines that an individual did not qualify for refugee status at the time of admission. However, we are concerned that reducing the time refugees have to respond to a Notice of Intent to Terminate (NOIT) from 30 days to 10 days creates unnecessary risks for refugees and their families without changing the substantive standard governing termination. Refugees facing termination may need to obtain legal assistance, understand the allegations against them, locate records, secure translations, prepare written evidence, and determine whether to request an interview, all while facing the possibility of losing the legal status on which their employment and family stability depend. For these reasons, the Foundation respectfully urges DHS to withdraw this IFR and restore the 30-day response period.