The Center for Reproductive Rights submitted a comment  in opposition to a proposed rule from the Department of Health and Human Services (HHS) that re-interprets the scope of a “federal public benefit” as defined in the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA). The new rule would limit immigrants’ access to benefits such as Head Start, Title X, and other health services offered at federally qualified health centers. The comment focused on the harm to immigrant communities and the agency’s pre-enforcement of the rule in violation of the Administrative Procedure Act (APA).

Submitted: 8/13/2025