CMS Plans to Share Data with ICE Could Exacerbate Immigrant Families’ Fears About Accessing Health Coverage and Care
The Centers for Medicare and Medicaid Services (CMS) issued a notice that it will begin sharing Medicaid data it receives from states with Immigration and Customs Enforcement (ICE) for immigration enforcement. Examples of information it will share include, “citizenship and immigration status, location, and phone numbers, and, in specific cases, other information on a case-by-case basis as permitted by law.” The notice will take effect following publication in the Federal Register on November 25, 2025, with no public comment period. However, CMS indicates that it will proceed with the policy when a preliminary injunction that prohibits Medicaid data sharing with ICE in some states is lifted. CMS issued this notice despite earlier policy and public guidance included on state and federal websites indicating that information collected by Medicaid agencies will only be used for program administration and not for immigration enforcement.
This policy change will likely exacerbate immigrant families’ fears about health officials and providers sharing information with ICE, increasing their reluctance to access health coverage or care. The KFF/New York Times 2025 Survey of Immigrants shows that, prior to this notice, about half (51%) of immigrant adults were “very concerned” or “somewhat concerned” that health officials or health care providers may share their information with ICE or CBP (Figure 1). These fears may contribute to individuals delaying or avoiding medical care. About one in seven (14%) immigrant adults, including 48% who are likely undocumented and 20% who are parents, say that they or a family member have avoided seeking medical care since January 2025 due to immigration-related concerns.
Medicaid is jointly administered by the federal government and states, and states must share certain information with CMS for program administration. State Medicaid agencies collect and maintain personal and health information for applicants and beneficiaries to determine eligibility and provide care. Undocumented immigrants are not eligible for Medicaid or other federally-funded coverage, but payments for emergency services may be made to hospitals on behalf of individuals who are otherwise eligible for Medicaid but for their immigration status. States include information about these payments in their reports to CMS. Some states provide health coverage to some immigrants regardless of immigration status using state-only funds. However, states are not required to submit this state-only program information to CMS. States cannot require applicants to provide citizenship or immigration status for any family or household members not applying for coverage.
In June 2025, there were reports of the Trump administration sharing personal and health data for noncitizen Medicaid enrollees with the Department of Homeland Security despite concerns about violations of federal and state data privacy protections. In August 2025, a federal court in California temporarily blocked the data sharing in 20 states that filed a lawsuit against the administration.
This data sharing notice immediately follows the Trump administration’s notice of proposed changes to public charge rules, which will also likely increase immigrant families’ reluctance to access health coverage and care. It comes against a backdrop of efforts to reduce access to health coverage and care for immigrant families, increase immigration enforcement, and restrict immigration, which have increased fears among immigrants and negatively impacted their health.