The Department of Homeland Security has released a proposed rule that would significantly alter how public charge determinations are made, potentially resulting in millions of people losing access to health coverage. By rescinding regulations established during the Biden administration in 2022, the new policy seeks to provide immigration officers with broad discretion to consider a person’s use of public benefits, including Medicaid and the Children’s Health Insurance Program (CHIP), when evaluating their eligibility for legal permanent residency or entry into the United States. This shift moves away from the previous “bright line” standard that excluded non-cash benefits, raising concerns among health experts and immigrant advocates about a widespread “chilling effect” on participation in essential support programs.

According to research from KFF, the impact of these changes could be profound, with estimates suggesting that between 1.3 million and 4.0 million people could disenroll from Medicaid or CHIP. This group includes a significant number of U.S. citizen children living in immigrant households, with projections ranging from 600,000 to 1.8 million children potentially losing coverage. These figures do not account for those who are eligible but may now forgo enrolling altogether due to fear or confusion regarding their immigration status. Currently, approximately 13.4 million Medicaid or CHIP enrollees live in households with at least one noncitizen, highlighting the scale of the population that may feel the repercussions of this policy shift.

The history of public charge policy suggests that even those who are not legally subject to the rule may withdraw from programs out of caution. During the first Trump administration, a 2019 rule change led to a noticeable decline in participation among low-income U.S. citizen children with noncitizen household members. Research found that participation in Medicaid and CHIP for these children fell by 18% between 2016 and 2019, a rate twice as high as that seen in citizen-only households. Although the Biden administration attempted to mitigate these effects by codifying field guidance that excluded most non-cash programs in 2022, recent data indicates that fear has persisted and is once again on the rise.

Health Equity and Economic Consequences

The proposed regulations arrive at a time of heightened anxiety for immigrant communities. A 2025 survey conducted by KFF and the New York Times found that 41% of immigrant adults worry that they or a family member could be detained or deported, while 30% have limited their daily activities to avoid drawing attention to their status. Furthermore, nearly 20% of immigrant adults reported skipping or postponing medical care in the past year due to immigration-related concerns. This climate of fear is being amplified by a recent notice from the Centers for Medicare and Medicaid Services (CMS) stating it will begin sharing state-received data with Immigration and Customs Enforcement (ICE), a move that researchers say further deters enrollment.

The consequences of mass disenrollment extend beyond individual families to the broader public health and economic landscape. DHS itself has acknowledged that the rule could lead to worse health outcomes, increased emergency room usage, and a higher prevalence of communicable diseases. From a health equity perspective, these changes disproportionately affect communities of color, as one in four children in the United States lives in a family with at least one immigrant parent. Reduced access to nutrition assistance and healthcare threatens the long-term development and financial stability of these families while simultaneously increasing uncompensated care costs for hospitals and clinics.

In addition to the immediate health risks, the policy is expected to create negative spillover effects on the workforce and community stability. Reductions in health coverage and other supports can lead to increased poverty, housing instability, and lower educational attainment for the next generation. Providers may face lost revenue, and the broader economy could see reduced productivity as families lose the resources necessary to maintain their health and well-being. These findings are based on the sources provided, which detail a policy environment as of December 2025; you may wish to independently verify if these proposed changes have since been finalized or further amended.

The proposed rule represents a fundamental shift in how the United States balances its immigration priorities with its commitment to public health. While the Department of Homeland Security intends for these measures to reduce reliance on public resources, the broad discretion granted to immigration officers creates a complex landscape for families to navigate. As advocates and health systems prepare for the potential fallout, the focus remains on the millions of individuals whose access to care hangs in the balance of a changing regulatory environment.