Barriers Mount for Undocumented Residents Seeking Health Care

By: Ranier Simons, ADAP Blog Guest Contributor

The Trump Administration’s aggressive posture on immigration is exerting chaotic uncertainty on many aspects of the lives of undocumented residents and those without permanent citizenship. This includes health care, where recent actions could result in a public health crisis. Federal and state actions are adversely affecting health care access for affected populations, including threatening HIV-related care. Many stakeholders are speaking out about the consequences of the President’s executive order targeting federal benefits for those deemed to be living in the country illegally. There is also litigation being pursued in an attempt to mitigate present and potential harms. Adverse effects on the undocumented population’s access to healthcare are a population health problem for all.

Photo Source: BBC

In February 2025, the President issued an executive order to eliminate all federal benefits for illegal immigrants as part of his ongoing campaign deriding fiscal waste, fraud, and abuse (Samuels, 2025). The utility of the order is unclear, as noncitizens, except for refugees and in some instances of emergencies, were already ineligible for federal benefits like Supplemental Nutritional Assistance Program (SNAP) and Temporary Assistance for Needy Families (TANF) (Broder & Lessard, 2024). 

It does pose as a deterrent for anyone seeking to enter the country illegally to access assistance and benefits. The order also requests improvements to eligibility verification systems and requires people found to be improperly obtaining federal benefits to be referred to the Justice Department and Homeland Security (Samuels, 2025). Without a clear indication of what programs are being specifically targeted, the order creates instability due to uncertainty. It also potentially leads to concerns about healthcare access.

In July, in alignment with the February executive order, HHS reversed a Clinton-era interpretation of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) (HHS, 2025). This interpretation enabled individuals without permanent legal status to access specific federal benefits, such as Head Start and community health centers, including federally qualified health centers (FQHCs). The new HHS policy reversal states that undocumented individuals can no longer benefit from taxpayer-funded programs, such as FQHCs, and a list of other initiatives (HHS, 2025). 

Federal regulations require community health centers, such as FQHCs, to provide care to all residents within their service area. The HHS reversal conflicts with the federal Health Center Program as authorized in Section 330 of the Public Health Service Act (PHSA). It leaves community health facilities in an unstable position. Shawn K. Frick, CEO of the Community Health Center Association of Connecticut, stated, “The notice from the U.S. Department of Health and Human Services raises significant questions about how community health centers in Connecticut and across the country can continue to meet their legal and moral obligations” (Carlesso, 2025).

Community health centers are dedicated to providing comprehensive care for all individuals to maintain public health. Connecticut health care leaders are concerned about how the conflicting messaging could negatively impact their ability to provide quality care. Currently, they do not inquire about a person's legal immigration status. If they eventually are told they have to verify status before providing care, many residents will fall out of care. Moreover, centers are not equipped to effectively verify status, which would add to the administrative burden of community health centers. In Connecticut, providers are already reporting that patients are cancelling appointments and requesting to be changed to telehealth services to avoid physically coming into treatment out of fear of deportation (Carlesso, 2025).

Photo Source: USA Today

Connecticut practitioners are also concerned about potentially having to deny care to people receiving care under the Connecticut HUSKY for immigrants program, giving government-sponsored health benefits to undocumented persons, such as 15,600 children who are enrolled in the program (Carlesso, 2025). Preventive healthcare prevents public health from deteriorating to poorer states of health, which require more expensive intervention. Keeping people healthy is beneficial for both public health and the local and state economies. 

People who do not maintain their health issues advance to disease states that result in high emergency room utilization. Senate Minority Leader Stephen Harding, R-Brookfield, and Sen. Heather Somers, R-Groton, expressed that the U.S. Department of Health & Human Services (HHS) announcement does not ban services for undocumented residents. They feel it simply means that undocumented residents can seek care at FQHCs, but will have to pay for it completely themselves without any taxpayer-funded assistance (Carlesso, 2025). Presently, Connecticut practitioners are not denying any care nor interrogating for legal status. However, the uncertainty of future guidance is already negatively affecting the vulnerable populations in need of care. 

This month, twenty state Democratic attorneys general (AGs) and the District of Columbia sued the Trump Administration over the HHS policy change (Goldman, 2025). They argue that the administration overstepped and violated administrative law. They also emphasized the serious harm to public health and the lack of resources for programs such as homeless shelters, overdose emergency services, and more to perform eligibility verifications at the point of services (Goldman, 2025). New York Attorney General Letitia James said in a statement, "These programs work because they are open, accessible, and grounded in compassion…This is a baseless attack on some of our country's most effective and inclusive public programs, and we will not let it stand” (Goldman, 2025). 

Attempting to bar noncitizen residents from certain lifesaving care services provided through federal funding is literally a matter of life and death for people living with HIV/AIDS (PLWHA). The Ryan White HIV/AIDS Program (RWHAP) is the only means by which undocumented PLWHA are able to receive their care and antiretroviral medication. Without care, they would lose viral suppression, progress to advanced disease states, and would also be at risk for increasing transmission rates. The RWHAP does not require proof of citizenship or residency (Mercer, 2025).

However, state laws have the potential to endanger the ability of undocumented PLWHA to receive HIV care from the RWHAP. Idaho passed HB135, which required people to prove their legal status before accessing public benefits such as HIV testing, other communicable disease testing, and HIV treatment programs, both federal and non-federal. (Mercer, 2025). The ACLU of Idaho, the National Immigration Law Center, and several other parties filed a lawsuit to request a temporary restraining order (TRO) to prevent Idaho from enforcing HB135 in regard to HIV treatment. A federal judge granted the TRO, which means that, for now, noncitizen PLWHA in Idaho will not be denied their lifesaving medication and care. (Mercer, 2025). However, if the injunction is not continually extended or made permanent, or if the state legally appeals and the decision is reversed, then access could be lost. The future of lifesaving HIV care access through RWHAP for undocumented PLWHA is uncertain, with the potential conundrum of states pursuing legislation in conflict with the federal RWHAP requirements of providing care for all, regardless of legal status.

Photo Source: Georgetown Univ. McCourt School of Public Policy

People living without permanent legal status are also losing access to healthcare as a result of Medicaid rollbacks. California, Illinois, and Minnesota are reversing the Medicaid expansions that the states previously enacted, which allowed thousands of undocumented immigrants to access Medicaid coverage (Nguyen & Shastri, 2025). The changes are due to budgetary constraints coupled with looming cuts to federal Medicaid funding. California is not removing any adult immigrants from the rolls, but new enrollments will cease in 2026, and adults under 60 years of age will be required to pay a $ 30 monthly fee. Illinois will be rescinding coverage to adult immigrants without legal status aged 42 to 64, and Minnesota’s new budget cuts Medicaid coverage for all undocumented adults (Nguyen & Shastri, 2025). Children in Minnesota will remain covered, but adults will need to purchase private health insurance. Patients will lose coverage for life-sustaining and preventive care, and providers will lose revenue due to lost billing from the program.

The current administration’s targeting of healthcare access of undocumented immigrants in the name of fiscal responsibility does not generate savings, justifying the damage that will result in regard to public health. Moreover, potentially requiring community health centers to verify legal status is an expansion of federal efforts to identify undocumented individuals for the purposes of deportation. The outcome of existing lawsuits will set precedents and provide a positive or negative trajectory for the public health of undocumented residents.

[1] Broder, T., Lessard, G. (2024, May 1). Overview of Immigrant Eligibility for Federal Programs. Retrieved from https://www.nilc.org/resources/overview-immeligfedprograms/

[2] Carlesso, J. (2025, July 15).HHS ban on serving undocumented clients a ‘fundamental shift,’ CT health centers say. Retrieved from   https://ctmirror.org/2025/07/15/ct-health-centers-undocumented-immigrants/

[3] Goldman, M. (2025, July 21). States sue over citizenship curbs on Head Start, clinics. Retrieved from https://www.axios.com/2025/07/21/states-sue-trump-public-benefit

[4] Mercer, O. (2025, July 1). Federal Judge Blocks Idaho Immigration Law Affecting HIV Program Access. Retrieved from https://www.visaverge.com/immigration/federal-judge-blocks-idaho-immigration-law-affecting-hiv-program-access/

[5] Nguyen, T., Shastri, D. (2025, July 21). 3 Democrat-led states have rolled back Medicaid access for people lacking permanent legal status. Retrieved from https://apnews.com/article/medicaid-immigrants-california-illinois-minnesota-ice-f43d5681a6e9d45d274790c2eae716ee?utm_campaign=KHN%3A%20First%20Edition&utm_medium=email&_hsenc=p2ANqtz-8GpW2rskV94yxV8zgIxLwBJHqYTLYFuHf0Ec0s8bO1rTORv8fR7tl7vcUtRPiM_WxLN4QbolpLKXOrUaKFljag-siC6Q&_hsmi=372382415&utm_content=372382415&utm_source=hs_email

[6] Samuels, B. (2025, February 19). Trump signs order targeting any federal benefits going to those in the country illegally. Retrieved from https://thehill.com/homenews/administration/5154614-trump-order-federal-benefits/

[7] U.S. Department of Health and Human Services (HHS). (2025, July 10). Press Release: HHS Bans Illegal Aliens from Accessing its Taxpayer-Funded Programs. Retrieved fromhttps://www.hhs.gov/press-room/prwora-hhs-bans-illegal-aliens-accessing-taxpayer-funded-programs.html

Disclaimer: Guest blogs do not necessarily reflect the views of the ADAP Advocacy Association, but rather they provide a neutral platform whereby the author serves to promote open, honest discussion about public health-related issues and updates.