Resources

Client Alerts, News Articles, Blog Posts, & Multimedia

Everything you need to know about BMD and the industry.

A Shift in Coverage: HHS Reinterprets “Federal Public Benefit” Under PRWORA

Client Alert
July 16, 2025

On July 10, 2025, the U.S. Department of Health and Human Services (HHS) rescinded a 1998 interpretation of “federal public benefit” as used in Title IV of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA). PRWORA was passed to restrict benefit eligibility for immigrants without legal status as well as many legal immigrants during their first few years in the U.S. The 1998 interpretation limited the scope of what qualified as a “federal public benefit,” allowing states to extend exemptions to immigrants for programs such as emergency services or public health.  

With this new notice, HHS intends to reverse what it calls “outdated exclusions” from the bill’s language, and newly includes the following programs as “federal public benefits” under PRWORA:

  • 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

The notice establishing the revised policy took effect immediately upon publication in the Federal Register on July 14, 2025. Comments on the proposed rule are due no later than 11:59 p.m. Eastern Time on August 13, 2025.

To learn more about “federal public benefits” under PRWORA and how this policy shift could impact your health care operations, please contact BMD Healthcare Member Daphne Kackloudis at dlkackloudis@bmdllc.com or Attorney Jordan Burdick at jaburdick@bmdllc.com.

Health LawHealthcare PolicyU.S. Department of Health and Human ServicesPRWORA
Client Alert

Key Healthcare Provisions in Ohio’s 2026–2027 Budget

July 2, 2025Ohio’s newly enacted biennial budget (HB 96) for FY 2026–2027 brings sweeping changes for healthcare providers across the state. The law includes new Medicaid eligibility requirements, reporting mandates, funding directives, and social policy provisions. Several vetoes by Governor DeWine also affect healthcare-related initiatives.Client Alert

Providers Beware: Court Sides with Insurers in No Surprises Act Arbitration

July 2, 2025On June 12, 2025, the Fifth Circuit ruled in favor of Aetna and Kaiser in two lawsuits brought by air ambulance providers challenging how insurers calculated payments under the No Surprises Act’s Independent Dispute Resolution process. The court held that unless there is clear evidence of fraud or serious misconduct, IDR decisions will stand, reinforcing the finality of the arbitration process.Client Alert

Introducing HB 281: Enforcement of Federal Immigration Laws in Ohio Hospitals

July 1, 2025House Bill 281, introduced on May 20, 2025, would require Ohio hospitals to allow law enforcement, including federal immigration agents, to enter facilities and enforce immigration laws. The bill mandates that hospitals comply with information requests and adopt formal policies, raising significant concerns about patient privacy and access to care for immigrant communities.Client Alert

Parental Consent May Soon Be Required for Minor Mental Health Services in Ohio

June 25, 2025HB 172 proposes repealing a provision in Ohio law that allows minors age 14 and older to consent to limited outpatient mental health services without parental involvement. The bill would require parental consent for all such care and remove related language from other sections of the Ohio Revised Code.Client Alert

Community Behavioral Health Providers - Supervisor Pricing Changes Begin July 1 [Corrected Date]

June 16, 2025Effective June 16, community behavioral health providers wishing to receive reimbursement at the supervisor rate must add the HP or HT Modifier to fee-for-service (FFS) claims. Find out about the new guidelines.
Older posts
Newer posts