Aug 14, 2018

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CCLP testifies in support of TANF grant rule change

CCLP's Emeritus Advisor, Chaer Robert, provided written testimony in support of the CDHS rule on the COLA increase for TANF recipients. If the rule is adopted, the cost of living increase would go into effect on July 1, 2024.

Letter: Remove the citizenship question from the 2020 Census

by | Aug 14, 2018

Editorial note: On Aug. 3, Claire Levy, Executive Director of Colorado Center on Law and Policy, submitted this letter to Jennifer Jessup, Departmental Paperwork Clearance Officer for the Department of Commerce in Washington, D.C. The letter is regarding a proposal to add the citizenship question to the 2020 Census.

Dear Ms. Jessup,

Colorado Center on Law and Policy (CCLP) respectfully submits the following comments on the 2020 Census proposed information collection. CCLP is a nonpartisan nonprofit organization that promotes justice and economic security for low-income Coloradans. Our trusted research and policy analysis relies heavily on U.S. Census data, which informs and motivates state and local policies.

We strongly oppose the addition of a citizenship question to the 2020 Census. Asking an untested question about citizenship status will increase fear in immigrant communities and decrease Census participation. This will lead to under-counting of low-income and immigrant communities. Many in these communities rely on critical health and social programs to meet their basic needs, programs whose funding is distributed based on Census data. Inaccurate data will not only further the unequal distribution of wealth in our state, but will also skew reporting and analysis for the next decade. For these reasons, we urge the Department of Commerce to remove the citizenship question from the 2020 Census form.

Changing the U.S. Census requires extensive testing, review and evaluation over a 5-year period to ensure change is necessary, and will produce quality, useful information. Adding a citizenship question without rigorous testing undermines the processes put in place to ensure accurate data, equitable funding and a fairly representative government. An untested citizenship question will drive up costs as the Census Bureau struggles to develop new communications and outreach strategies with little time remaining, plan for an expanded field operation, and track down the millions of households that will be more reluctant to participate because of this controversial question. The uncertainty of adding an untested question is compounded by use of computer and internet responses, which together will depress response rates, cost additional taxpayer money, and thwart an accurate, inclusive 2020 enumeration.

The federal government uses census-derived data to direct at least $800 billion annually in federal assistance to states, localities and families. About 61 percent of all funding guided by Census data is related to health programs. CCLP is particularly concerned about the impact on funding for Medicaid and the Children’s Health Insurance Program (CHIP), which improve access to care and health outcomes and reduce disparities. The data used to calculate the federal funding states receive to run their Medicaid and CHIP programs are derived from the Census, so extensive under-counting of low-income immigrant communities and communities of color could put Medicaid and CHIP funding in jeopardy. Any cuts to funding would almost certainly translate to fewer services for people are eligible to receive coverage through these programs, putting access to care and health outcomes at risk for low-income children, adults and people with disabilities, including citizens.

CCLP is also concerned with funding for community health centers. Census data are used to calculate which areas qualify for funding for health center programs that provide integral physical, mental, behavioral and oral health care in medically underserved areas and for people who lack health insurance or otherwise struggle to afford care. Migrant health programs are particularly at risk, as under-counting of migrant populations, most of whom are poor, could impact funding for these important health programs.

Finally, the undercounting associated with the addition of a citizenship question could risk funding for SNAP, WIC, the federal school lunch program and Section 8 housing vouchers, which support low-income communities to access the food and housing they need to maintain their health and wellbeing.

Even though the Census is required to protect the personal information of respondents, asking a question about citizenship will spark fear among immigrant communities that information they provide might be used to target them or their families for detainment, deportation and other forms of family separation. This persistent fear, in and of itself, harms the mental and emotional health of children and families and may make people less likely to seek mental, physical, behavioral, oral or other health care services when they need them. Currently, immigrant communities participating in pilot data collection report being afraid that their data will not be kept private and could be used for immigration enforcement or shared with other government agencies for targeting of them, their families and their communities. In sum, asking about citizenship status in a climate of fear and mistrust can only heighten suspicions and harm mental health, depress response rates, cost additional taxpayer money and thwart an accurate, inclusive 2020 enumeration.

If people can’t trust that the data they report to the Census are confidential, they may be less likely to report personal information accurately and completely or participate at all. This is especially true for communities that face specific risks related to their citizenship status, like deportation or public charge determinations. Unfortunately, these are some of the same communities who have historically been undercounted in the census – namely Latino, Asian, African American, Native American, and Middle Eastern communities and immigrants. Adding a citizenship question will only compound existing struggles with collecting accurate census data on these populations, compromising the accuracy of the census for all communities.

The request to add a citizenship question has drawn intense opposition from an ideologically broad group of business leaders, state and local officials, social scientists and civil and human rights advocates who know how much is at stake with a fair and accurate census. This groundswell of opposition has included more than 160 Republican and Democratic mayors, six former directors of the Census Bureau and two former Commerce Secretaries from Republican and Democratic administrations, 171 civil and human rights groups, more than 600 faith leaders, more than 120 of members of the U.S. House of Representatives and many others representing a diversity of political ideologies and communities. We join these groups in our deep-seated concern that an untested citizenship question will compromise implementation of the 2020 Census, jeopardize the quality and accuracy of census data for all communities and perpetuate harm against immigrant communities and communities of color, specifically.

A full, fair and accurate census is absolutely critical for the functioning of many key health programs and for the health and wellbeing of all communities. For the reasons discussed above, we strongly oppose asking about citizenship status in the 2020 Census and urge the Department of Commerce to remove the proposed citizenship question from the data collection forms.

Respectfully submitted,

Claire Levy
Executive Director
Colorado Center on Law and Policy

Recent articles

CCLP testifies in support of Clean Slate updates

Bethany Pray, CCLP’s Chief Legal and Policy Officer, provided testimony in support of House Bill 24-1133, Criminal Record Sealing & Expungement Changes. CCLP is in support of HB24-1133, as it is one of our priority bills.

CCLP testifies in support of TANF grant rule change

CCLP's Emeritus Advisor, Chaer Robert, provided written testimony in support of the CDHS rule on the COLA increase for TANF recipients. If the rule is adopted, the cost of living increase would go into effect on July 1, 2024.


To maintain health and well-being, people of all ages need access to quality health care that improves outcomes and reduces costs for the community. Health First Colorado, the state's Medicaid program, is public health insurance for low-income Coloradans who qualify. The program is funded jointly by a federal-state partnership and is administered by the Colorado Department of Health Care Policy & Financing.

Benefits of the program include behavioral health, dental services, emergency care, family planning services, hospitalization, laboratory services, maternity care, newborn care, outpatient care, prescription drugs, preventive and wellness services, primary care and rehabilitative services.

In tandem with the Affordable Care Act, Colorado expanded Medicaid eligibility in 2013 - providing hundreds of thousands of adults with incomes less than 133% FPL with health insurance for the first time increasing the health and economic well-being of these Coloradans. Most of the money for newly eligible Medicaid clients has been covered by the federal government, which will gradually decrease its contribution to 90% by 2020.

Other populations eligible for Medicaid include children, who qualify with income up to 142% FPL, pregnant women with household income under 195% FPL, and adults with dependent children with household income under 68% FPL.

Some analyses indicate that Colorado's investment in Medicaid will pay off in the long run by reducing spending on programs for the uninsured.


Hunger, though often invisible, affects everyone. It impacts people's physical, mental and emotional health and can be a culprit of obesity, depression, acute and chronic illnesses and other preventable medical conditions. Hunger also hinders education and productivity, not only stunting a child's overall well-being and academic achievement, but consuming an adult's ability to be a focused, industrious member of society. Even those who have never worried about having enough food experience the ripple effects of hunger, which seeps into our communities and erodes our state's economy.

Community resources like the Supplemental Nutrition Assistance Program (SNAP), formerly known as Food Stamps, exist to ensure that families and individuals can purchase groceries, with the average benefit being about $1.40 per meal, per person.

Funding for SNAP comes from the USDA, but the administrative costs are split between local, state, and federal governments. Yet, the lack of investment in a strong, effective SNAP program impedes Colorado's progress in becoming the healthiest state in the nation and providing a better, brighter future for all. Indeed, Colorado ranks 44th in the nation for access to SNAP and lost out on more than $261 million in grocery sales due to a large access gap in SNAP enrollment.

See the Food Assistance (SNAP) Benefit Calculator to get an estimate of your eligibility for food benefits.


Every child deserves the nutritional resources needed to get a healthy start on life both inside and outside the mother's womb. In particular, good nutrition and health care is critical for establishing a strong foundation that could affect a child's future physical and mental health, academic achievement and economic productivity. Likewise, the inability to access good nutrition and health care endangers the very integrity of that foundation.

The Special Supplemental Nutrition Program for Women, Infants and Children (WIC) provides federal grants to states for supplemental foods, health care referrals, and nutrition information for low-income pregnant, breastfeeding and non-breastfeeding postpartum women and to infants and children up to age five who are found to be at nutritional risk.

Research has shown that WIC has played an important role in improving birth outcomes and containing health care costs, resulting in longer pregnancies, fewer infant deaths, a greater likelihood of receiving prenatal care, improved infant-feeding practices, and immunization rates

Financial Security:
Colorado Works

In building a foundation for self-sufficiency, some Colorado families need some extra tools to ensure they can weather challenging financial circumstances and obtain basic resources to help them and their communities reach their potential.

Colorado Works is Colorado's Temporary Assistance for Needy Families (TANF) program and provides public assistance to families in need. The Colorado Works program is designed to assist participants in becoming self-sufficient by strengthening the economic and social stability of families. The program provides monthly cash assistance and support services to eligible Colorado families.

The program is primarily funded by a federal block grant to the state. Counties also contribute about 20% of the cost.


Child care is a must for working families. Along with ensuring that parents can work or obtain job skills training to improve their families' economic security, studies show that quality child care improves children's academic performance, career development and health outcomes.

Yet despite these proven benefits, low-income families often struggle with the cost of child care. Colorado ranks among the top 10 most expensive states in the country for center-based child care. For families with an infant, full-time enrollment at a child care center cost an average of $15,140 a year-or about three-quarters of the total income of a family of three living at the Federal Poverty Level (FPL).

The Colorado Child Care Assistance Program (CCCAP) provides child care assistance to parents who are working, searching for employment or participating in training, and parents who are enrolled in the Colorado Works Program and need child care services to support their efforts toward self-sufficiency. Most of the money for CCCAP comes from the federal Child Care and Development Fund. Each county can set their own income eligibility limit as long as it is at or above 165% of the federal poverty level and does not exceed 85% of area median income.

Unfortunately, while the need is growing, only an estimated one-quarter of all eligible children in the state are served by CCCAP. Low reimbursement rates have also resulted in fewer providers willing to accept CCCAP subsidies.