Feldesman Memorandum re: HHS PRWORA Notice

July 15, 2025

We are looking forward to meeting with the attorneys from Feldesman, LLP, on Friday morning at 10:00.  Feldesman also prepared the document (attached) for the National Council.  It just arrived in my Inbox.

Here’s more re:  the Webinar on Friday morning.  Don’t forget to register (red ink below). 

Special ‘Members Only’ Webinar
Friday, July 18 at 10:00 

Implications of HHS Reinterpretation of ‘federal public benefit’ in PRWORA w/ attorneys from Feldesman, LLP  (Members Only)
The NYS Council will be hosting a special ‘Members Only’ Webinar on Friday morning, July 18 at 10:00 a.m. featuring our legal consultants at Feldesman, LLP.  We will review HHS’ (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. and discuss the implications of this change on our member agencies and the individuals they serve.
We have set up a Zoom meeting event for this webinar, and you can register here.  You will receive a confirm from Feldesman, LLP: https://us06web.zoom.us/webinar/register/WN_4Pn5HoEoSdWcbUMuzwX8Vw.

New Restrictions on Providing Federal Public Benefits to Noncitizens:  Implications for NYS Council Member Agencies 

Date & Time
Jul 18, 2025 10:00 AM

Description

The Department of Health and Human Services issued a notice reinterpreting the term “Federal public benefit” used in Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA). The new definition will prohibit programs funded under the Certified Community Behavioral Health Clinics Program, Community Mental Health Services Block Grant, Substance Use Prevention, Treatment, and Recovery Services Block Grant, including grant programs administered by SAMHSA, to be provided to individuals who are not U.S. citizens or “qualified aliens.” At the same time, PRWORA exempts nonprofit charitable organizations from any requirement to determine, verify, or otherwise require proof of eligibility of any applicant for benefits. Join this webinar for a discussion of who is now eligible for services, collection of data, and the provision of services under your federal funding, as well as what subsequent federal issuances we may expect.