How Public Charge Fears and Data-Sharing Policies May Impact Medicaid Community Engagement Requirements

The Trump administration’s recent changes to immigration and data sharing policies could make it harder for states to meet new Medicaid community engagement (CE) requirements. Those changes include:

• A Department of Homeland Security proposed rule issued on November 19, 2025 that rescinds the 2022 Biden administration public charge rule designed to expand immigrant access to public benefits and more broadly reinterprets the public charge to include consideration of any past or future benefits in order to limit access.

• A Centers for Medicare & Medicaid Services notice on November 25, 2025 stating that it will begin sharing Medicaid data with Immigration and Customs Enforcement (ICE) effective immediately.

Proposed Changes to the Public Charge Test

Public charge is an immigration test used when someone applies for a green card to assess whether they are likely to depend on government assistance. For decades, this test has focused only on cash benefits or long-term institutional care, not programs like Medicaid.

The proposed rule will rescind most of the 2022 rule and signals a shift toward a much broader interpretation. It suggests that immigration enforcement could consider any past or future use of public benefits, including programs that historically were never part of the public charge test. The proposal also hints that future policy could be set through agency guidance rather than formal rulemaking, leaving applicants with uncertainty about which benefits may count and how adjudicators will apply the standard.

When members fear that interacting with their state Medicaid agency may expose them or their families to immigration consequences, participation declines, including among those who are eligible. That means key tasks like reporting hours, submitting documentation, and responding to notices become harder to achieve for states at scale.

States working to implement CE requirements must account for this reality. Evidence from several studies show that fear, stigma, and distrust of public programs directly influence whether members take required actions. The plan to start Medicaid-ICE data sharing will further amplify these concerns, affecting enrollment, compliance, and continuity of coverage, all central to the success of CE policies.

Fear and data sharing can limit engagement, even among eligible members

Research on public benefit participation shows that members’ willingness to engage with programs is shaped as much by trust as by eligibility status. One study published in the Journal of Policy Analysis and Management found that anticipated stigma, concerns about surveillance, and expectations of poor treatment can discourage individuals from enrolling in or staying connected to Medicaid, leading to missed renewals and early disengagement. These dynamics are even more pronounced among immigrant and mixed-status families. For example, the Urban Institute found that one in seven adults in immigrant households avoided Medicaid or other non-cash benefits due to fear of immigration consequences, despite being eligible.

The administration’s plan for Medicaid–ICE data sharing heightens these concerns. Even the perception that personal information could be shared with immigration enforcement may deter eligible families from seeking coverage or completing required CE tasks. A recent study shows that nearly half of immigrant adults were concerned about health providers or officials sharing their information with immigration authorities. This environment can create a powerful chilling effect, reducing eligible members’ willingness to report CE compliance activities, respond to notices, or maintain their coverage.

In a CE context, this can result in:

• Fewer members responding to CE notices

• Reduced reporting of CE qualifying activities

• Increased churn among those who would otherwise meet requirements

• Missed deadlines due to fear of interacting with state systems

• Disproportionate impact on mixed-status families and communities of color

• Higher administrative and outreach expenses for state to reach and renew eligible individuals

• More uncompensated care

• More health conditions left untreated

Successful participation with CE by members assumes they feel safe interacting with government agencies. Data sharing between Medicaid and ICE can directly undermine that assumption.

The critical role of trust in CE implementation

CE implementation relies not only on clear rules and system design, but on whether members feel safe engaging with the program. Trust and perceived security influence whether individuals read and act on notices, report hours, document qualifying activities, or respond to follow-up requests. When members believe their information is protected and understand how it will be used, they are more likely to stay engaged and comply. States that acknowledge and address member fears are better positioned to maintain stable participation and avoid unnecessary churn.

What states can do

To strengthen trust and support member engagement, states may consider:

• Clear, transparent communication explains what data is and is not shared
• Partnerships with trusted community organizations who often serve as critical intermediaries
• Simplifying reporting processes to reduce the perceived burden or risk
• Training front-line staff and call centers to respond to fear-based questions with accuracy and empathy
• Monitoring churn and non-compliance trends to identify where fear may be suppressing participation

Need help with your outreach and engagement approach?

As states and managed care plans work on outreach and engagement strategies, Aurrera Health is here to help by assessing member-experience risks, identifying potential barriers to CE engagement, and providing strategies to strengthen communication and trust. For more information contact Lauren Block.

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Authors

Catherine Gekas-Steeby [Deputy Director] (Copy)