NYS Council Member Alert: PRWORA Exemption Removed, Effective Immediately – NYS Council for Community Behavioral Healthcare

NYS Council Member Alert: PRWORA Exemption Removed,
Effective Immediately

July 10, 2025

Please read the headline article in the Client Alert below from our attorneys at Feldesman, LLP. No details from the state on implementation at this point.

According to our attorney Adam Falcone (I told him I didn’t quite understand the implications of this announcement) this means that all of the services on the list (in the information below) are considered “federal public benefits” and none may be furnished to undocumented individuals. The problem for many provider types (to this point) is that they do not typically check immigration status and most do not want to begin asking clients about this for many obvious reasons including the chilling effect it has on individuals seeking care.

We will have more about this shortly. We know that this could mean a significant shift in program administration for some or many of our member agencies.

Note for our FQHC members — Feldesman is doing a Webinar on July 16 on this topic (see yellow highlighted information below).

You can read the HHS press release here: https://www.hhs.gov/press-room/prwora-hhs-bans-illegal-aliens-accessing-taxpayer-funded-programs.html

And full text of the Notice here: https://www.hhs.gov/sites/default/files/prwora-notice.pdf

Stand by for more.

Here’s the list I mentioned above (embedded in the Client Alert below):

HHS identified the following programs as satisfying the statutory definition of “Federal public benefit”:

Certified Community Behavioral Health Clinics
Community Mental Health Services Block Grant
Community Services Block Grant (CSBG)
Head Start
Health Center Program
Health Workforce Programs not otherwise previously covered (including grants, loans, scholarships, payments, and loan repayments).
Mental Health and Substance Use Disorder Treatment, Prevention, and Recovery Support Services Programs administered by the Substance Abuse and Mental Health Services Administration
Projects for Assistance in Transition from Homelessness Grant Program
Substance Use Prevention, Treatment, and Recovery Services Block Grant
Title IV-E Educational and Training Voucher Program
Title IV-E Kinship Guardianship Assistance Program
Title IV-E Prevention Services Program
Title X Family Planning Program

CLIENT ALERT
Feldesman attorneys are tracking all Executive Orders, actions, and court cases impacting recipients of federal funding. Stay tuned for continued analysis and industry updates.

HHS Reinterprets “Federal Public Benefit,” Major Impacts for Health Centers and Head Start

On Wednesday, July 10, 2025, the U.S. Department of Health and Human Services (HHS) announced a significant policy change by issuing a notice (0991-ZA57) setting forth its revised interpretation of the term “Federal public benefit” as used in Title IV of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), 8 U.S.C.

Specifically mentioned in the notice are Head Start, the Health Center Program, and Certified Community Behavioral Health Clinics, among others.

NYS Council Member Alert: PRWORA Exemption Removed,Effective Immediately

NYS Council Member Alert: PRWORA Exemption Removed,
Effective Immediately