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HHS Policy Change Could Impact Head Start and Other Programs

July 11, 2025

Written by Tara Thomas, AESA Government Affairs Manager

On July 10, the U.S. Department of Health and Human Services (HHS) announced it is reinterpreting eligibility provisions for certain programs. Under this new interpretation, services will no longer be provided to undocumented immigrants, even in programs where immigration status has not historically been a barrier to access—including Head Start.

This reinterpretation goes into effect immediately, but a 30-day public comment period is now open.

Many advocates argue this policy shift may violate Plyler v. Doe, and there is hope that a strong, coordinated response through the comment process could halt or amend the implementation of this rule.

In addition to Head Start, the following programs are also impacted by the HHS action:

  • Certified Community Behavioral Health Clinics

  • Community Mental Health Services Block Grant

  • Community Services Block Grant (CSBG)

  • Health Center Program

  • Health Workforce Programs (including grants, loans, scholarships, and loan repayments)

  • Mental Health and Substance Use Disorder Treatment, Prevention, and Recovery Support Services Programs

  • 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

We will keep you updated as we learn more.

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