For nearly thirty years, there has been a shared understanding — across party lines — that programs keeping families healthy, safe, and learning should not be turned into tools to police immigration status. That understanding has just been abandoned. On July 14, 2025, the Department of Health and Human Services (HHS) released sweeping new guidance under the 1996 welfare law known as the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA). This change marks a major break from precedent, jeopardizing more than $27 billion in federal programs and millions of people who rely on them. 

The new interpretation expands the list of federally funded health, education, and social service programs that must now restrict access based on immigration status. This means trusted community spaces — early learning centers, community health centers, mental health clinics — risk becoming immigration checkpoints. The list includes programs that are cornerstones of thriving communities: Head Start early childhood education, Title X family planning, child welfare and kinship care assistance, mental health and substance use treatment, the Community Services Block Grant, and community health centers that provide affordable, lifesaving care. Even U.S. citizen children could be turned away simply because their parents are not considered “qualified immigrants” under the narrow definition in PRWORA. 

For immigrant communities, this is not an isolated blow — it is one more assault in a relentless series of attacks that make daily life a minefield of fear. Families already live under the constant threat of deportation, with parents afraid to leave home for work or school drop-off because they may be stopped, detained, or kidnapped by ICE agents. Immigration processing fees have climbed beyond the reach of many working families, delaying or derailing applications for visas, green cards, or citizenship. Policy shifts have threatened to reverse legal statuses previously granted, throwing lives into uncertainty overnight. These communities — who contribute billions in taxes, build businesses, care for children and elders, and power industries from agriculture to health care — are being relentlessly targeted. And now, the very programs that help families stay healthy, safe, and stable are being weaponized against them. 

The harm this will cause is not theoretical. These programs provide critical supports at every stage of life. Head Start prepares young children for school while supporting parents with education, health care, and parenting resources — giving families a stronger foundation for the future. Title X family planning enables people to decide if and when to have children, leading to healthier pregnancies and better economic stability. Child welfare programs protect children from abuse and neglect, preventing trauma and reducing the need for costly foster care. Mental health and substance use programs help people heal, re-enter the workforce, and contribute to their communities. Community health centers provide preventive and primary care, reducing emergency room visits and long-term health costs. Denying access to these lifelines not only harms individuals — it weakens entire communities. 

History tells us exactly what happens when immigration checks are added: fear drives eligible people away. After PRWORA was first enacted in the late 1990s, participation in many programs dropped sharply among refugees and U.S. citizen children in mixed-status families, even though they remained eligible for those programs. This “chilling effect” persists today, with families avoiding medical care, nutrition assistance, and shelter because they fear it could put them on ICE’s radar or jeopardize their immigration status. 

The new guidance forces local providers into an impossible position. HHS has not explained how eligibility verification should work. Nonprofit service providers cannot be forced to verify immigration status, but without clear rules, many will feel pressured to do so. That means overhauling enrollment systems, retraining staff, and managing sensitive documents — without new funding. With the threat of penalties under the False Claims Act for mistakes, some providers may turn people away just to be “safe.”  

There is no justification for this rushed change. The prior policy stood for 27 years under administrations of both parties, including the entire first Trump term. Claims that delaying implementation would harm citizens or “qualified” immigrants are misleading — the real crisis is decades of underinvestment in the safety net, not the participation of immigrant families. Yet HHS has allowed only 30 days for public comment on a policy that will affect millions and fundamentally alter the way essential programs operate. 

The consequences will be immediate and devastating. Families will lose access to health care, mental health and substance use treatment, domestic violence survivor services, and early education. Children denied Head Start are less likely to succeed in school and more likely to face economic hardship later in life. Communities will shoulder higher emergency care costs, increased homelessness, preventable illnesses, and the long-term damage of pushing more families into crisis. 

The Coalition on Human Needs has urged HHS to halt this harmful policy, restore the 1998 guidance, and work with the communities it impacts. You can read our comment here. These are our neighbors, co-workers, and friends — people who help build and sustain this nation. Using essential programs to target them is both cruel and self-defeating. When families can meet their basic needs without fear, we all thrive. This policy does the opposite; that is why CHN and many expert groups have urged Secretary Kennedy to reverse course and prevent needless harm.