Feldesman Client Alert: Latest Executive Order Reverses Longstanding Interpretation of PRWORA
By Edward T. Waters |Published On: February 20, 2025
Yesterday, the Executive Order titled “Ending Taxpayer Subsidization of Open Borders” overturned a 1998 interpretation of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), commonly known as the Clinton Welfare Bill. This interpretation had exempted several community-based grant programs, including Head Start and the Section 330 Health Center Program, from requirements to collect information such as Social Security Numbers and other proof of legal status. Read the full article here.
President Trump Rescinded the Sensitive Locations Policy Which Protected Schools, Churches, and Health Centers from ICE Raids
Special message from Collen Meiman, National Policy Advisor for State Associations of Community Health Centers
It’s official — the Trump Administration officially rescinded the Sensitive Locations policy, effective yesterday. Since 2011, this policy has prevented immigration officials from taking enforcement actions at health care settings, as well as other “sensitive” settings such as houses of worship, schools, weddings, and funerals. As a result, it is now possible that ICE or other law officers could show up at any of these locations – including CHCs – with an intent to enforce immigration laws.
The policy was withdrawn more quietly than expected, with only a brief mention on the Department of Homeland Security’s website. This issue has yet to be addressed in an Executive Order.
The far-left tab of the Online Resource Spreadsheet has links to several immigration-related resources, including template P&Ps, recordings of webinars, free “Know Your Rights” cards, CA PCA’s immigration page, etc.
Three Things To Do With This News:
1. Educate yourselves about your CHCs’ rights, and your patients’ rights, re: interacting with ICE and other types of law enforcement.
- This document helps explain the rights of a nonprofit organization.
- This website provides free “Know Your Rights” cards for patients in 30 different languages.
2. Develop a plan for how to respond to a potential ICE interaction at your CHC, and enshrine it via P&Ps and training.
- The CA PCA prepared template P&Ps in 2017 to assist CHCs with this process. See bullet #7 (& thank you CPCA!)
3. Work to counter the “chilling effect” that increased ICE activity could have on patients’ willingness to seek care. While there are no “silver bullet” solutions, the following strategies may help
- Making services available at locations other than your CHC site.
- Educating your patients and staff about what new policies do and don’t do, and about their rights.
- Having clear, prepared answers to tough questions. Again, see the CA PCA 2017 documents for sample Q&As.
