Mobilizer: Health Care for the Homeless Action Bulletin

March 26, 2026  |  Vol. 30 No. 5 |  Archives

 

In This Issue

  • New Threat to Medicaid – FRAUD (+ advocacy action!)
  • Work Requirements Move Forward (+ advocacy action!)
  • Get Involved! Join a meeting with your lawmakers?
  • ICE Enforcement and Detention Harm Health, DHS Funding Fight Continues (+ advocacy action!)
  • This Saturday: No Kings Protest!
  • Proposed HUD Rules Threaten Housing Stability
  • Expanding Use of Guardianship
  • What (Else) We’re Reading
 
Medicaid Fraud image

New Threat to Medicaid – FRAUD

Medicaid cuts have remained a top priority for the Trump administration and Congressional leaders who recently launched fraud investigations across multiple states. While framed as oversight for the misuse of funds, these efforts are attempting to destabilize Medicaid mostly in Democratic run states. What’s happening:

  • The starting point: The investigations started in Minnesota, where the Trump administration attempted to withhold more than $250 million in funding, Minnesota pushed back, and the fight is tied up in litigation.
  • Escalating number of state investigations: Centers for Medicare and Medicaid Services (CMS) launched a new initiative, expanding the investigation to California, Florida, Maine, and New York. House Energy and Commerce Committee leadership sent letters to ten states (CA, CO, MA, ME, NE, NY, OR, PA, VT, and WA) requesting information about Medicaid program integrity, threatening vital Home and Community Based Services (HCBS) like medical respite care.
  • Additional federal action: DOGE publicly released provider-level spending data to identify potential fraud, raising concerns about patient privacy and the misuse of sensitive information.
  • New Executive Order, new White House task force: The President issued a new executive order, “Establishing the Task Force to Eliminate Fraud,” ” which targets Medicaid and other safety net programs like housing, food, medical care, and cash assistance federal benefit programs.

📢 Act Now 📢

Share our new resource, Medical Respite Care Programs Add Value to States, Hospitals & Payors, with your state Medicaid director, your budget Committee members, and other policymakers involved in Medicaid funding. Help push back against Medicaid fraud allegations and threats to life-saving services like medical respite care!

Related Reading:

  • Understanding Medicaid Home Care Amid CMS Focus on Potential Fraud and Abuse | KFF
  • Oz Escalates Medicaid Fraud Claims Against States After Focus on Minnesota | KFF
  • Fact Sheet: President Donald J. Trump Establishes the Task Force to Eliminate Fraud | The White House
 

Work Requirements Move Forward

Three months into state legislative sessions and nine months out from implementation of the work requirement provisions in HR 1, states continue to grapple with these changes. Recent analysis found that state Medicaid budgets will lose $664 billion through 2034, and implementation costs (IT and additional staff) are expected to exceed $1 billion across 25 states.

Here’s the latest on state Medicaid decisions:

  • Arkansas will begin testing work requirements this summer, but will hold off enforcement until January 2027.
  • Florida is pursuing Medicaid work requirements despite not expanding Medicaid and not being required to implement them.
  • California anticipates thousands of people experiencing homelessness will lose Medicaid coverage. Safety net clinics in LA are pushing for a new 5-year, half-cent sales tax to fill funding gaps and continue providing care.
    • Related: Deaths among unhoused LA County residents fell in 2024, marking first decline on record | LAist
  • GOOD News: Utah passed a state law codifying work requirements while explicitly exempting people experiencing homelessness.

While implementation has not yet begun, data already shows a decline in Medicaid enrollment, a trend that could significantly impact key Medicaid populations including 2 in 5 births, 1 in 4 people with SUD or mental illness, and 3 in 5 nursing facility residents.

The changes will be felt across the country. Already 1 in 3 Americans report cutting basic expenses to pay for health care, a number that will grow as coverage losses increase. 

📢 Act Now 📢

Take Action: Contact your state lawmakers and urge them to mitigate the harms of Medicaid cuts on people experiencing homelessness! Use Utah as an example of a state that has taken action to protect this population!

Use these resources to support your outreach:

  • Fact Sheet: Homelessness and Medicaid: What’s the Connection?
  • Fact Sheet: Impact of Medicaid Work Requirements for Unhoused People
  • Letter to States: H.R. 1 Implementation Recommendations to Ease Burden on People Experiencing Homelessness

Related Reading:

  • Implementing Medicaid Work Reporting Requirements: Defining A ‘Serious Or Complex Medical Condition’ | Health Affairs
  • Checking All the Boxes: A Survey of Medical Frailty Definitions in Alternative Benefit Plans and Section 1115 Work Requirements Demonstrations | NHeLP
  • CMS Releases Guidance on Changes to Eligibility Redeterminations for Medicaid Adult Group Enrollees
  • Lawmakers, Health Groups Resist Their States’ Rural Health Fund Plans | kff
  • A Look at the Intersection of SNAP and Medicaid as States Implement Medicaid Work Requirements | KFF
 
Stephanie Wroten, CEO of Duffy Health Center, and colleagues meeting with legislator

Photo credit: Stephanie Wroten, CEO, Duffy Health Center with Congressman Keating (February 2026)

Get Involved! Meet With Your Lawmakers

Want to meet with your elected officials—either in your work capacity or as a private citizen? Sign up to join virtual meetings by filling out this google form to indicate your interest. Laura Brennan, our Senior Policy Manager, will reach out as opportunities become available with your Representative and Senators.

 

ICE Enforcement and Detention Harm Health, DHS Funding Fight Continues

Congress is no closer to ending the Department of Homeland Security partial government shutdown as negotiations between Democratic leadership and the White House have stalled. As discussions continue, the need for ICE and CBP reform remains clearer than ever with new reporting highlighting the health impacts across the country.  

Reports from detention facilities show detainees receive inadequate medical care, particularly pregnant and postpartum individuals who report limited access to treatment, unsafe conditions, and a lack of follow up care. And, despite federal policy that says this group of individuals should only be detained under limited circumstances, ICE deported 363 pregnant, postpartum, and nursing immigrants between January 1, 2025 and February 16, 2026 – severing access to care and increasing trauma.

Across the country, fear of ICE continues to deter many people from accessing care, underlying the importance and need to continue advocating for sensitive locations. In communities with high ICE presence like Minneapolis, providers warn that enforcement actions pose a threat to the health care system and have gone as far as to set up a shadow medical system to help patients access care safely at home.

Related Reading:

  • Pregnant in ICE Detention: Handcuffs and Pleas for Medical Care | NYTimes (gift link)

📢 Act Now 📢

Congress must keep hearing from us: NO DHS funding without restrictions on ICE. This includes clear protections that prohibit ICE enforcement at or near sensitive locations (clinics, hospitals, shelters, school, places of worship) so people can safely access care.  

Call your elected officials today using the Capitol switchboard (202-225-3121) and urge them to oppose any DHS appropriations package that does not include these protections. Make it clear that access to care must be protected. Use our latest fact sheet to learn more about sensitive locations and why they’re critical.

 
Protest sign and American flag

This Saturday: No Kings Protest!

On Saturday, March 28, communities across the country will come together again for No Kings 3, a nationwide day of protest. As our communities remain under attack, costs push people out of housing and away from health care, we must stand with our neighbors and demand change.

Find a protest near you, make a sign, and have your voice be heard!

 

Proposed HUD Rules Threaten Housing Stability

The Department of Housing and Urban Development (HUD) published three proposed regulations that could significantly impact housing access and stability for tens of thousands of people:

  1. Restricting HUD assistance for “mixed status” families: This proposed rule would limit HUD housing assistance to only U.S. citizens and eligible noncitizens (generally legal permanent residents). It would require all people living in any Section 8 or public housing units (or other types of HUD-assisted housing) to verify their citizenship status. If finalized, this rule will displace many families who cannot verify their eligibility and will create significant administrative burdens for case managers. 
    • Comments due: April 20. Note: Template language you can use to draft your own letter will be coming out shortly!
    • Related Resources:
      • Advocacy leader: Keep Families Together
      • Toolkit: HUD Mixed-Status Rule Toolkit (from Protecting Immigrant Families) Coalition
      • Administration Plan Targeting Immigrants Would Take Away Rental Assistance, Create New Barriers | CBPP
      • Ranking Member Maxine Waters and Representatives Velázquez, Vargas, and Garcia Urge HUD Secretary Turner to Withdraw Cruel Rule Targeting Mixed-Status Families
  1. Establishing an OPTIONfor work requirements and time limits in HUD housing: This proposed rule would give public housing agencies (PHAs) the option to implement work requirements up to 40 hours per week for “work-eligible” adults and allow PHAs to establish term limits of no less than 2 years for non-elderly, non-disabled families. 
    • Comments due: May 1. Note: Template language you can use to draft your own letter will be coming out shortly!
    • Related Resources:
      • Work Requirements and Time Limits in Rental Assistance Programs Will Worsen Housing Instability | NHLP, CLASP, NLIHC, Justice in Aging
      • Rental Assistance Time Limits Would Place More Than 3 Million People — Half of Them Children — at Risk of Eviction and Homelessness | CBPP
  1. Revoking 30-day notice of eviction for nonpayment of rent: Currently, HUD-assisted tenants must receive at least 30 days’ notice before being evicted for nonpayment of rent. This rule would revert back to pre-2021 policies (which had been loosened due to COVID). Starting on March 30, 2026, public housing needs to give “at least 14 days’ notice,” while project-based Section 8 programs must comply with the provisions of the lease and State laws. Those living in Section 8 Rehab SROs, only 5 working days’ notice is required. 
    • Comments due: April 27 - but note this will have already taken effect at that time.
 

Expanding Use of Guardianship

The Department of Veterans Affairs (VA), in partnership with the Department of Justice (DOJ), is launching a new initiative to expand the use of guardianship for veterans, specifically targeting those experiencing homelessness. Under guardianship, the government can assume control of where an individual lives, who they see, their assets, and what medical care they receive. A related but separate pilot, Project Safe Harbor, will test this model at five VA sites (Boston, Los Angeles, Tampa, San Antonio, and Hines).

These efforts come after staffing cuts at the VA eliminated thousands of medical positions and reduced access to therapists and other critical services. With this context, expanding access to guardianship rather than investing in critical, voluntary providers, raises series questions about the Department’s MO. The initiative also reflects a broader federal trend toward more coercive and punitive responses to homelessness and behavioral health, including:

  • DOJ’s FY25 Public Safety and Mental Health Initiative ($45 million): Requires civil commitment, prioritizes locations that criminalize homelessness, and prohibits any community that is friendly to immigrants from receiving funds.
  • SAMHSA Assisted Outpatient Treatment (AOT) Program Grant - While not new, these grants existed under Biden and Trump previously, this grant requires awardees to be in a community that cooperates with ICE, punishes drug users, participates in encampment sweeps, and includes prohibitions on “anti-American activities” (TBD on what that means).

Important note: Guardianship processes are governed at the state level. It is unclear whether the VA or DOJ have the legislative authority to advance this initiative.

Related Reading:

  • Despite Their Successes, Some Mobile Crisis Response Teams Are in Crisis | KFF
 

What (Else) We're Reading 

  • More than 150,000 uncounted COVID-19 deaths occurred early in the pandemic, a study finds | AP
  • Utah lawmakers plan to fund governor’s homelessness overhaul — if cities, counties pay up | DesertNews
  • Fact Sheet: Overdose Deaths Decline Due to Public Health Interventions | Drug Policy Alliance
  • To Avoid Care Disruptions, Know When the Clock Runs Out on Your Prior Authorization | KFF
  • Lawmakers add ID requirement to Indiana’s needle exchanges | AP
  • Newsom threatens California counties for failing to use his new mental health court | AP News
  • Summary of Constitutional Protections for Harm Reduction Programs | DPA + NPHL
  • Drug smoking can lead to severe burns, complicating harm reduction efforts | Stat
  • Dual Hazards of Homelessness and Climate Change | Georgetown Environmental Law Review
  • Judge blocks US government from slimming down vaccine recommendations | AP
 

We hope to see you in Orlando in June!

Register Today!
 

Laura Brennan
Senior Policy Manager
National Health Care for the Homeless Council

lbrennan@nhchc.org

Your support is crucial!
All our advocacy work — including this newsletter! — is funded by dues from NHCHC's members and private donations. Consider joining the Council or donating to support this work!

 
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