Comment Submitted by Center on Budget and Policy Priorities

Summary: The Center on Budget and Policy Priorities (CBPP) strongly opposes the proposed revision of Form AR-11, arguing that it transforms a simple address update form into a burdensome and overbroad data surveillance mechanism. They contend that the new requirements violate the Paperwork Reduction Act, create significant administrative hurdles for both respondents and state agencies, and may chill participation in essential public benefits due to privacy concerns and fear of immigration consequences.