Making Sense of Benefits Policy in 2025: Tracking Changes to Immigrants’ Access to Public Benefits

Immigrants with legal status in the United States are facing renewed and increased threats to their public benefits access in 2025. In my role as a student analyst with the Digital Benefits Network (DBN), I have spent the summer sourcing information and resources for our monthly newsletters on important topics in benefits delivery. Below are some key lessons I learned through that process. These include the impact of previous policy changes on immigrant participation in programs, and how the landscape of benefits delivery may shift due to changes to immigrant eligibility for key means-tested programs and new interpretations of the term “federal public benefits.” This blog post draws on valuable analysis, commentary, and insights from impacted groups across the benefits access and immigrants rights ecosystems.

For the DBN’s July 2025 newsletter, I highlighted research showing how immigrant groups’ participation in public benefit programs can be heavily impacted by anti-immigrant rhetoric and even the expectation of policy changes. This was evidenced by the impact of the public charge rule expansion under the first Trump administration. Enforced between 2019 and 2021, the public charge rule expansion broadened conditions for Green Card ineligibility, resulting from enrollment in public benefits programs and had a chilling effect on immigrant families’ willingness to apply for these public benefits. This lasted throughout the first Trump administration and remained even after the changes were reversed in 2021 (KFF 2023). 

 

Context from Prior Changes

Avoidance of public programs was widespread across all immigrant groups and even groups not covered by the public charge rule changes (UCLA Center for Health Policy Research, Urban Institute 2021). Researchers observed steep decreases in program participation amid rule change announcements, including a 35.6 percent decrease in Supplemental Nutrition Assistance Program (SNAP) participation among mixed-status households between 2016 and 2019, and a decrease of 260,000 child Medicaid enrollees between 2017 and 2019 (Food Research & Action Center 2021, Health Affairs 2020). 

 

H.R. 1 and Other Federal Changes

In 2025, the passage of the “One Big Beautiful Bill Act,” referred to here as H.R. 1, and other changes are shifting public benefit eligibility once again, barring many from programs for which they were previously eligible. As a result, this is having a chilling effect on the participation of still-eligible individuals (KFF 2025). Here are the largest restrictions and changes:

• Eligibility for SNAP, Medicaid, and the Children’s Health Insurance Program (CHIP) is now restricted to four groups. Under H.R. 1, only citizens, lawful permanent residents, Cuban-Haitian entrants, and residents under the Compact of Free Association between the U.S. and Palau, Micronesia, or the Marshall Islands (“COFA migrants”) qualify for these benefits programs (NILC). Consequently, many individuals who formerly qualified for benefits are now ineligible, including refugees, asylum holders, survivors of domestic violence or human trafficking, and individuals with Temporary Protected Status (NILC). They also face increased work requirements and stricter age limits for SNAP and Medicaid eligibility, further complicating the application process for immigrants unaffected by other H.R. 1 changes (League of Women Voters). 
• Medicaid and CHIP are projected to undergo almost $1 trillion in cuts over the next decade. These are the largest cuts to the programs in history (Campaign for Children). In addition to the overall cuts to Medicaid and CHIP, H.R. 1 reduces funding for Emergency Medicaid, a federal reimbursement program that provides care to immigrants who are ineligible for Medicaid by decreasing the Federal Medical Assistance Percentage (FMAP). Changing eligibility requirements guarantees that there will be a sharp increase in the number of immigrants who qualify for Emergency Medicaid. As a result, funding decreases will strain state resources and limit their ability to support constituents (Protect Our Care IL, KFF). Combined with major changes to SNAP (FRAC), these shifts transfer the cost burden of benefits delivery to individual states. This burden is exacerbated by federal pressure for states to comply with strict and costly determination processes.
• Changes to federal public benefits guidance will further limit programs available to immigrants. Along with changing eligibility requirements for existing public benefits programs under H.R. 1, five federal agencies have reinterpreted the federal public benefits definition under the Personal Responsibility and Work Opportunity Act (PRWORA), restricting immigrant access to additional programs (NILC). Notably, the U.S. Department of Health and Human Services has moved to bring 13 more programs under the “public benefits” umbrella, effectively barring immigrants from accessing more health and support services. This includes early childhood support systems, treatment centers focused on behavioral health, mental health, and substance use disorders, and the Federal Health Center program. The latter is responsible for funding Community Health Centers – the typical source of medical care for three in ten immigrant adults (KFF). In response to these changes, a number of lawsuits have been filed. As of September 2025, a preliminary injunction has been granted to a coalition of states involved in The State of New York, et al. vs The United States Department of Justice, halting enforcement or implementation of the new interpretation of federal public benefits under PRWORA in those states until the case is closed (Feldesman). In addition, changes barring immigrant access to the Head Start program have been temporarily blocked following a lawsuit filed by the Head Start association alongside other advocacy groups (Illinois Public Media Newsroom).

 

Quantifying Impacts

Early analyses that attempt to quantify the potential consequences of recent policy changes predict large increases in the number of uninsured individuals, particularly immigrants. Changes to SNAP alone would deny necessary food assistance to an estimated 90,000 immigrants with lawful immigration status (Center on Budget and Policy Priorities). Additionally, Medicaid eligibility changes under H.R. 1 will leave 1.3 million immigrants with legal status uninsured by 2034 (Newsweek). At the same time, changes to income support programs could end Child Tax Credit benefits for up to 4.5 million currently eligible children in mixed-status households, as new rules would require both parents to have Social Security numbers (Center on Poverty and Social Policy at Columbia, CBPP). Cumulatively, these changes show the difficulty of predicting the actual number of families who will be affected.

Understanding the Bigger Picture 

During this period of change in the public benefits system has revealed the crucial role of understanding the broader implications in this space. Sweeping legislative changes can overwhelm individuals looking for specific eligibility changes, worsening their impact. Seeing the number of organizations working to make these policy changes and their impacts more digestible is a source of comfort. I see the Beeck Center’s DBN as a central place to spotlight these organizations’ work. By lifting up their work, I hope this information is made more accessible to individuals and communities who stand to benefit most from it. 

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