Trump Administration Imposes New Restrictions on Federal Public Benefits for Immigrants
(July 15, 2025) Four federal agencies have issued coordinated guidance and notices that expand the list of federally-funded programs that are off limits to certain categories of lawfully-present immigrants. Specifically, the notice documents expand the categories “federal public benefits” that are available only to U.S. citizens, U.S. non-citizen nationals, and certain categories of immigrants defined as ‘‘qualified aliens.’’ "Qualified aliens" include immigrants with statuses such as legal permanent resident, asylee, or refugee. Lawfully-present immigrants with other statuses are excluded from these programs, as are undocumented immigrants.
The agencies that have expanded the federal public benefit programs subject to these immigrant eligibility restrictions are: the U.S. Department of Agriculture (USDA), Department of Health and Human Services (HHS), Department of Labor (DOL), and Department of Education (ED). Their actions collectively rescind a 1998 interpretation of the list of programs subject to these restrictions.
HHS has increased the number of programs it considers to be “federal public benefits” from 31 to 44. Newly included programs now subject to eligibility verification include:
- Title X Family Planning Program;
- Head Start;
- Title IV-E Educational and Training Voucher Program;
- Community Services Block Grant (CSBG);
- Health Center Program;
- Substance Use Prevention, Treatment, and Recovery Services Block Grant;
- Community Mental Health Services Block Grant;
- Projects for Assistance in Transition from Homelessness Grant Program;
- Certified Community Behavioral Health Clinics; (41) Mental Health and Substance Use Disorder Treatment, Prevention, and Recovery Support Services Programs administered by the Substance Abuse and Mental Health Services Administration not otherwise covered above;
- Title IV-E Prevention Services Program;
- Title IV-E Kinship Guardianship Assistance Program;
- Health Workforce Programs not otherwise covered under "Health Profession Education and Training Assistance” (including grants, loans, scholarships, payments, and loan repayments).
The HHS notice also clarifies that the list is not exhaustive—future programs may also fall under the definition of a federal public benefit. The new policy took effect immediately upon publication in the Federal Register on July 14 and includes a 30-day public comment period.
Department of Labor Workforce Program Implications
The DOL guidance states that grantees under key workforce development programs—including the Workforce Innovation and Opportunity Act (WIOA) Title I Adult, Dislocated Worker, and Youth programs, as well as the Senior Community Service Employment Program (SCSEP)—must now ensure that all participants are legally authorized to work in the United States. This will require updates to policies, documentation procedures, and participant verification protocols.
Implications for Aging Services Providers
These changes may significantly impact access to services for immigrant older adults and the workforce pipeline for aging services providers. LeadingAge National is reviewing the guidance documents in detail and will provide further analysis and advocacy updates in the coming weeks.
Contact: Karen Lipson, klipson@leadingageny.org.