Bloomberg published a recent article on how the Trump administration’s proposal to radically reinterpret the obscure “public charge” provision is contrary to the administration’s pledge to reduce paperwork and other regulatory burdens. As I previously wrote here, the Trump proposal would require immigration officials to predict whether an immigrant who is otherwise eligible for a green card might receive even small amounts of supplementary assistance (like SNAP and Medicaid) at any time in the future.

The Bloomberg article does a good job of highlighting some of the new burdens the proposal would place on visa applicants. Unfortunately, the article underestimates the impact of the proposal by saying that “it is expected to affect some 383,000 people annually.”

Four broad categories of people will be directly subject to the proposed test:

• People in the United States seeking to adjust their status and become “lawful permanent residents” (LPRs, or “green card” holders): 383,000 people annually;

• People outside the United States applying for family, diversity, and certain employment-based visas to become LPRs: 500,000–600,000 people annually;

• People outside the United States applying for a “nonimmigrant” visa to temporarily stay in the United States: roughly 9–11 million annually; and

• “Nonimmigrants” in the United States applying for an extension of stay or change of nonimmigrant status: about 516,000 people annually.

People in the first two categories — particularly the ones who are otherwise eligible for green cards to reunite with spouses or other family members — are the most at-risk under the proposal. All together, some 900,000 to 1 million people annually will be directly subject to the radical new test.

Nonimmigrants are generally ineligible for the kinds of benefits (including Medicaid and SNAP) that the proposal says will make someone a “public charge.” But they are still likely to face a lot more hassles and burdens under new test.

Beyond the 900,000 to 1 million people directly subject to the new test, there will be at least 1 million US citizens annually that could be impacted by the test. These are the husbands, wives, and other relatives who are sponsoring those 900,000 to 1 million people seeking green cards. When immigration officials use the new test to deny a green card to an otherwise eligible person, they will be separating families on a scale even more massive than has been the case to date.

Finally, as the Department of Human Services acknowledges, the proposal will have many other negative impacts, including on local economies, heath care providers, and others.