While it has been widely reported that a preliminary injunction has prevented implementation of the new public charge rule at USCIS, some may not be aware that the U.S. Department of State is planning to implement a similar rule. The Interim Final Rule went into effect on October 15, 2019. However, DOS has stated that it will not implement the Interim Final Rule until a new Form DS-5540 is published. The Foreign Affairs Manual has also not yet been updated. For now, applicants and practitioners continue to proceed under the traditional “public charge” framework.