Doctors Without Borders Médecins Sans Frontières (MSF) submitted the following comment in opposition to the rule proposed by the Department of Homeland Security (DHS) and the Executive Office for Immigration Review (EOIR) on Circumvention of Lawful Pathways, CIS No. 2736-22; Docket No: USCIS 2022-0016; A.G. Order No. 5605-2023.
MSF is writing to strongly object to the proposed rule on the “Circumvention of Lawful Pathways” and demand that it be withdrawn entirely. The proposed rule, published on February 23, 2023, would establish a “presumption of ineligibility” for asylum for most noncitizens who cross the southwest land border of the US without authorization. Based on its expertise and experience working with asylum seekers and migrants in Mexico, MSF is extremely concerned about the devastating impacts this sweeping rule would have on the physical and mental health of people seeking safety. The implementation of the rule would only exacerbate humanitarian needs and unsafe conditions along the US-Mexico border and in other locations on the migration route. MSF urges the concerned US government agencies to withdraw the proposed rule. The Biden administration should instead focus on restoring full access to asylum at ports of entry, in line with US law and international obligations.
MSF and its interest in the issue
MSF is an independent international medical humanitarian organization that delivers neutral and impartial emergency aid to people affected by armed conflict, epidemics, natural and human‐made disasters, and exclusion from health care in more than 70 countries. We were awarded the Nobel Peace Prize in 1999. The decision to offer assistance in any country or crisis is based solely on our independent assessment of needs. Our financial independence allows us to provide aid free from any governmental influence that could be used to further political or military goals. MSF is currently responding to some of the world’s most severe humanitarian crises, including in Afghanistan, Syria, Yemen, Democratic Republic of Congo, and South Sudan.
Since 2012, MSF has been actively addressing the health needs of tens of thousands of asylum seekers, migrants, and forcibly displaced people across the region—including in Mexico, Honduras, Guatemala, Panama, Peru, and Haiti. Our teams provide comprehensive primary health care, mental health, social services, and health promotion activities.