Editors note:  Here is one more testimony sent to the US State Department in response to their federal register notice for public comment on the “size and scope” of their Refugee Admissions program for Fiscal Year 2015.  As readers know, the State Department is not allowing public review of any testimony submitted including the federal contractors’ *** testimony in which they invariably ask for more refugees.  By the way, Tennessee is a Wilson-Fish state and as such Catholic Charities of Tennessee calls the shots on who is resettled there.

May 27, 2014

Ms. Anne Richard
Asst. Secretary of State for Population, Refugees and Migration
US State Department
Washington, DC

Re: Federal Register Public Notice 8690

Dear Ms. Richard,

Please accept my written comments regarding FY 2015 U.S. Refugee Admissions Program. I recently learned that unlike prior years, there will be no public hearing this year. If ever there was a federal program that should be required to appear in public to answer questions and justify any funding, it is the one you oversee. The federal refugee resettlement program has increasingly operated without sufficient public scrutiny or meaningful input from all stakeholders.

As defined by the U.S. Office of Refugee Resettlement in the 2011 report to Congress (the last report submitted), resettlement stakeholders include: resettlement agencies, state refugee coordinators, refugee health coordinators, ethnic community-based organizations and ORR technical assistance providers.

The federal contractors’ proposed resettlement numbers are never made public prior to acceptance and award of federal funds. The very communities that are directly impacted are not considered stakeholders nor offered any opportunity prior to award for meaningful input into these decisions. This past year I spent a considerable amount of time and effort using FOIA and was still unable to have last year’s resettlement proposals disclosed.

This information should not be subject to FOIA. In fact, the information should be posted on the State Department’s website prior to acceptance and award of federal funds. There is nothing proprietary about how many people a federal contractor plans to bring to a community. Treating this information as “behind closed doors secrets” strongly suggests that the information is withheld from the public because of concern about community resistance to the federal government’s plans.

Years ago I served as a volunteer with a resettlement agency. Over time I have watched this program be transformed into an industry for government contractors with little to no oversight, transparency or accountability to taxpayers. The Cooperative Agreement which VOLAGs execute requiring that federal funds only “augment” privately raised funds is simply ignored. For example, Catholic World News reported in August 2012 that “Federal funds account for nearly 93% of USCCB’s migration/refugee budget…that over 92.5% of [their] $72.1 million budget came from federal grants and contracts while under $25,000 came from private donations.”

Nor is the USCCB the exception among the nationally contracted VOLAGs.

Federal grants include the likes of “Healthy Relationship and Marriage Research,” “Refugee Home Based Childcare Microenterprise Development Project” and “Preferred Communities” just to name a few. A rational approach to helping refugees and their children integrate more quickly into their new communities and Western culture, suggests that rather than using even more government funding to employ women in home-based childcare enclaves, the money would be better spent if at all, putting these children and mothers into existing community-based childcare settings.

While federally funded Ethnic Community Self-Help organizations and Mutual Assistance Associations are made to sound like good ideas, in reality they are yet one more avenue to funnel public dollars to refugee based organizations that use public dollars to claim refugee employment. Rather than assist refugees to integrate or even marginally, assimilate into their new communities, these organizations are designed to “ensur[e] that their charges retain strong ethnic and homeland ties.”

The per capita funding structure incentivizes resettlement contractors to increase their numbers regardless of whether it results in a lower standard of services provided to refugees. The 2012 GAO report “Greater Consultation with Community Stakeholders Could Strengthen Program” validates this position:

“Because refugees are generally placed in communities where national voluntary agency affiliates have been successful in resettling refugees, the same communities are often asked to absorb refugees year after year. One state refugee coordinator noted that local affiliate funding is based on the number of refugees they serve, so affiliates have an incentive to maintain or increase the number of refugees they resettle each year rather than allowing the number to decrease.”

Any attempt at objective discourse about how contractor resettlement business impacts the community in which they operate, is met with disdain. Local affiliate offices do not hesitate to publicly denigrate any taxpayer who raises legitimate questions about the functionality and cost of the program. Propaganda films like “Welcome to Shelbyville” are used to mislead the public and suggest that anyone who looks askance at the resettlement industry, is at best, just “unwelcoming” but more likely, a racist and a bigot.

The State Department’s blog entry dated May 27, 2011 notes that “Welcome to Shelbyville” was shown by your office, PRM, at the State Department on May 25 2011 to an audience of 120 that included representatives from NGOs, refugee resettlement agencies, the State Department, and other U.S. government agencies. Did you bother to share with them the other side of the Shelbyville story as reported in the local paper?

This “documentary” is pure propaganda for the federal program, obscures important facts about the program’s impact and worse, is used to silence legitimate concern about the resettlement industry. No federal agency should be permitted to use it.

States should have final control over resettlement activities within their state borders

Since states incur the on-going, long-term cost associated with refugees, states should have complete control over resettlement activities within their borders.

The 1981 Select Commission on Immigration & Refugee Policy (“Select Commission”), repeatedly addressed the financial impact on receiving communities. “Many state and local officials are concerned that the costs of resettlement assistance will continue beyond the period of federal reimbursement and that the burden of providing services will then fall upon their governments.”

The Select Commission seemed to well understand the fiscal issue for a federal program where the long-term costs would be passed to state and local governments. “Areas with high concentrations of refugees are adversely affected by increased pressures on schools, hospitals and other community services. Although the federal government provides 100 percent reimbursement for cash and medical assistance for three years, it does not provide sufficient aid to minimize the impact of refugees on community services.”

In 1982, just two years after the 1980 Refugee Act was passed, reduction in federal support started with federal cash and medical assistance reduced to 18 months. In 1988 it was reduced again to 12 months and again in 1991 to 8 months, which remains the current level. In 1986, the federal government began to reduce reimbursement to states for the state-funded portion of welfare, Medicaid and SSI, eliminating it altogether by 1991 and shifting these additional costs to the states.

The cost shift has been openly and repeatedly acknowledged by the federal government. And yet, these enduring costs are never acknowledged when calculating the true dollar cost of the program. The 2010 Senate hearing started to identify the significant costs states are forced to incur because of the federal program.

The U.S. Office of Refugee Resettlement places such a high premium on shifting refugee healthcare costs to states, that the 2013 ORR Voluntary Agencies Matching Grant Program Guidelines on page 9 states that: “ORR recognizes that weekly cash payments may make certain MG cases ineligible for the USDA Supplemental Nutrition Assistance Program (SNAP) and Medicaid. Thus, local Matching Grant Program service providers may give some of the weekly allowance in the form of vouchers if such a form of payment is in the overall best interest of the client and he/she concurs.”

In other words, circumvent the program’s rules to shift more cost to the state taxpayer. State governments that decided to expand their Medicaid programs probably did not anticipate that this year’s Department of Health and Human Services briefing on “Key Indicators for Refugee Placement” would so quickly advise considering Medicaid expansion when deciding refugee placements.

With regard to states that have withdrawn from the resettlement program, the federal government does not have the legislative authority to assign an NGO to continue the program in that state. This unconstitutional encroachment on the 10th amendment right of states is barred both by law and U.S. Supreme Court decisions and must cease.

Additionally, states should not be subject to the poor judgment exercised by the Obama administration’s decision to relax security screenings for certain groups of refugees.

“Self-sufficiency” terminology should be replaced with specific reporting on public assistance utilization, temporary v non-temporary employment and the number of refugees resettled each year who are considered to be “unemployable”

Despite documentation of high percentages of Medicaid and food stamp utilization, high “self-sufficiency” rates are reported by the refugee resettlement contractors. It is misleading to describe anyone, including refugees, as self-sufficient when they also receive publicly funded assistance in the form of food stamps, Medicaid and public housing. And still federal contractors are able to report high self-sufficiency rates for refugees as long as they do not receive cash welfare.

A January post on the “Friends of Refugees” blog posted the following about Bridge’s Knoxville resettlement operations: “A former case manager also sent us information about the agency and pointed out that the refugee employment figures are dishonest as most of the refugees have only temporary employment that does not help them to pay rent and be self-sufficient. The nature of the temp jobs also means that the refugees will be unemployed just a short time after the agency reports them employed to the federal Office of Refugee Resettlement (ORR) at 90 days and 180 days. (This, however, is a problem throughout the refugee program, and it doesn’t seem that the the ORR has much of an interest in requiring that resettlement agencies report if refugees are working at temporary or non-temporary jobs.)”

Public health issues should be resolved before funding more initial resettlement

TB among resettled populations has been a particular public health concern. It was reported in 2009 that the sharp increase in Minnesota’s active TB cases was tied to refugee resettlement. Because latent TB is not a bar to refugee admission, health officials have expressed concern about cases of drug-resistant TB being documented in communities with high refugee resettlement.

In 2012 the CDC reported that TB in “foreign-born persons increased to 63% of the national case total,” a percentage that has risen steadily since 1993.

More recently it was reported that “immigrants and those who travel to other countries frequently have the highest TB occurrence,” and that “many of these cases–approximately 450,000–are the drug-resistant form of TB that has developed from improper medication usage and medical protocols.”

In April, 2012, the U.S. Office of Refugee Resettlement circulated a grant announcement titled “Strengthening Surveillance for Diseases Among Newly-Arrived Immigrants and Refugees” since it appears that there is no comprehensive tracking of this particular segment of public health concerns. More government money to throw at a government created problem.

Reports of depression and PTSD are now being reported as reasons that some refugees are unable to work. Among Bhutanese refugees that are being resettled, the CDC has documented a troubling statistic; a suicide rate higher than the national and global average. One explanation offered has been the lack of jobs and the resulting stress of unemployment not matching expectations of life in the U.S.

Conclusion

Public funds are spent, hearings are held, reports are published and yet, nothing is done proactively to respond to the problems and issues that are highlighted.

The federal agencies involved in refugee resettlement have enabled the growth of an industry
layered with ever multiplying federal grants but extraordinarily lax on transparency and accountability. Currently, the U.S. refugee resettlement program is administered in derogation of a state’s right to withdraw from the federal program and a state’s right to set state level funding prerogatives.

Proposed resettlement plans should be made publicly available before any award of funding and be subject to public comments and public hearings. Moreover, the U.S. Office of Refugee Resettlement is at least two years delinquent in submitting the required annual report to Congress. No funding should be appropriated until all reporting requirements are met. Importantly, the last annual report dated 2011, noted the increased difficulty in finding employment for non-English speaking refugees, especially in light of higher unemployment rates among Americans, a situation that has not improved much since then.

Rather than compounding the problems already identified, it may be time to temporarily suspend the resettlement program and focus on the health and employment needs of refugees already here. At the same time, an objective examination of security screening measures should be undertaken.

Please ensure that a copy of the entire written record is timely made available to the public.

Respectfully submitted,

Joanne
Tennessee

Endnote:  All of our posts on this year’s public comment period may be found in our category entitled “Testimony for 5/29/2014 State Dept. meeting” here.

If you have testimony you wish us to publish, see my e-mail address in the right hand sidebar.

***The contractors: