Given the current climate and immigrant experiences with ICE, this notice has a chilling effect on immigrant and mixed-status households. Knowledge that information shared to obtain healthcare may be shared with both DHS and ICE may prevent these individuals and families from accessing healthcare as well as any other government-provided services requiring data collection if they know that their data may be shared in the future. This may mean decreased usage of services related to basic needs (e.g., healthy food), healthcare, housing and more. These actions may translate to worse health outcomes and have rippling effects as family members may need to leave work or school in order to care for loved ones. Additionally, lower healthcare usage also may reduce revenue for hospitals, medical supply and pharmaceutical companies, and other entities needed to maintain healthcare infrastructure, particularly in rural communities.
A written policy statement issued by a government agency or executive official that provides guidance, clarification, or direction on implementing laws or policies. Memos do not have the force of law but can influence policy interpretation and enforcement.
Who It Impacts: Federal agencies, policymakers, and sometimes regulated industries. Memos can shape how agencies enforce laws, impacting businesses, healthcare providers, and other stakeholders.
Who Is Not Impacted: Memos do not create binding legal requirements for the general public, though they can influence enforcement priorities that indirectly affect individuals and organizations.
Summary
This notice establishes that Centers for Medicare and Medicaid Services (CMS) will share information with the Department of Homeland Security (DHS) and U.S. Immigration and Customs Enforcement (ICE). Potential information shared include biographical details, immigration and citizenship status, contact information and location data. CMS will securely share the minimum amount of information necessary and ICE may request additional information on a case-by-case basis.
Impact Analysis
Legal Challenges
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Take Institutional Action
- Collaborate with others. Partner with community health centers, legal services, community health workers, care navigators, and immigrant-serving organizations to deliver accurate information and support to eligible individuals and families.
- Provide services without collecting identifying information. Support food pantries, food banks, clinics, and health centers that are willing and able to provide services without collecting identifying information to mitigate how this notice may deter eligible individuals from accessing services.
Associated or Derivative Policies
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Policy Prior to 2025
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Additional Resources
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