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ARTICLE · 24 FEBRUARY 2025

Client Alert: Latest Executive Order May Reverse Longstanding Interpretation Of PRWORA

Yesterday, the Executive Order titled "Ending Taxpayer Subsidization of Open Borders" may have upended a 1998 interpretation of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA)...

United StatesGovernment, Public Sector

Yesterday, the Executive Order titled "Ending Taxpayer Subsidization of Open Borders" may have upended a 1998 interpretation of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), commonly known as the Clinton Welfare Bill. This interpretation had exempted several community-based grant programs, including Head Start and the Section 330 Health Center Program, from requirements to collect information such as Social Security Numbers and other proof of legal status.

PRWORA was initially enacted to discourage unlawful immigration by making legal status a prerequisite for individuals to directly receive public benefits, such as Medicaid and the Supplemental Nutrition Assistance Program (SNAP). However, the 1998 interpretation of PRWORA had excluded certain grant programs from PRWORA's requirements on the grounds that the funds were awarded to community organizations rather than being provided directly to individuals or families. As a

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