Comment Submitted by Legal Council for Health Justice

Summary: Legal Council for Health Justice strongly opposes the proposed changes to Form AR-11, arguing that the expansion into collecting employment, education, and public benefits information exceeds the form's purpose and creates a "chilling effect" on access to vital health and social services. They contend that the proposal violates the Paperwork Reduction Act, infringes on privacy, and potentially violates the Tenth and Eleventh Amendments by overstepping federal authority into state-managed programs.