In a Sept. 21 decision, a federal district court in Rhode Island vacated notices issued by several agencies, including the Department of Health and Humans Services (HHS), that expanded the agencies’ interpretation of the term “federal public benefit” as it applies to the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA). The expanded interpretation limited the ability of immigrants without legal status to access grant-funded benefits, including services provided by Section 330 grant-funded community health centers.
America’s Essential Hospitals urged HHS to reconsider the notice in an August 2025 letter.
The court held that the agencies, including HHS, violated the Administrative Procedure Act by issuing their notices without first undertaking notice and comment rulemaking. Although the decision rested on procedural grounds, the court also indicated that the notices likely suffer from substantive legal deficiencies.
The court vacated the notice and enjoined HHS from implementing or enforcing it against the 21 plaintiff states through any other means.
Contact Director of Policy Rob Nelb, MPH, at rnelb@essentialhospitals.org or 202.585.0127 with questions.
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