Vermont Attorney General · September 21, 2026 · Primary source
Attorney General Clark Secures Lawsuit Win Preserving Access to Key Social Services
Summary
On September 21, 2026, a federal court granted a permanent summary judgment in favor of Vermont Attorney General Charity Clark and a coalition of 23 other state attorneys general, vacating Trump administration directives that would have required states to impose immigration status verification on recipients of programs funded under the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA). The blocked directives, issued by HHS, the Department of Education, DOL, and DOJ, would have conditioned federal funding for programs including Title X family planning clinics, Head Start, food banks, domestic violence shelters, and community health centers on immigration status checks. The ruling preserves a 30-year bipartisan interpretation of PRWORA allowing states to provide these services regardless of immigration status.
What this may mean
The permanent injunction vacates the four agency directives and restores the pre-2026 PRWORA interpretation, meaning federally funded community health centers, Title X clinics, and similar safety-net providers are not required to implement immigration status verification as a condition of receiving federal funds. Providers operating under these federal grant programs, including FQHCs, retain their prior eligibility and compliance posture without a new verification obligation. The ruling does not directly alter Medicare or Medicaid billing rules, but FQHCs and other safety-net entities that had been preparing for compliance with the now-vacated directives face no further obligation under those rules.
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