Oct. 5 Federal Update: ACF Announces Title IV-E Prevention Services Now Extend to Expectant Parents at States’ Discretion 

The Administration for Children and Families announced that federally approved evidence-based prevention services will extend to expectant parents. Through an amendment to the Child Welfare Policy Manual, the Trump Administration recognizes children before birth as “candidates for foster care,” permitting states to receive federal reimbursement for approved Title IV-E prevention services provided to expectant mothers and fathers. 

Permitting Title IV-E funds to serve expectant parents would increase access to evidence-based mental health, substance use, and parenting services, regardless of income. States have broad latitude to determine which prevention services to include in their Title IV-E plan and how candidacy is defined. While ACF guidance clarifies candidacy for expectant mothers, states are responsible for amending their plans accordingly. 

By supporting families early with evidence-based interventions that teach parenting skills and address mental health and substance use challenges, ACF hopes to strengthen the bonds between parents and children, promote stable family environments, and teach parents about healthy child development.  

Office of Refugee Resettlement Identifies Fraud in the Unaccompanied Alien Children Program 

The Office of Refugee Resettlement (ORR) released a memorandum detailing six documented forms of fraud perpetrated by various parties against the Unaccompanied Alien Children Program. ORR’s data showed that the average rate of intentional documentation fraud, regardless of the number of children assisted, remained at approximately 77% of reported Child Level Events (CLEs), or incidents, events, or observations that affect the health, safety, and wellbeing of individual children.  

Office of General Counsel received 1,669 CLE reports of fraud between Oct. 1, 2023 and Oct. 31, 2024. OGC reviewed a subset of these 1,669 reported instances of fraud and found that approximately 85% involved intentional document fraud.  

Types of fraud identified included:   

• False or fraudulent documentation of identity  
• Manipulated photographs  
• Misrepresented or unverifiable addresses  
• Fingerprint-related fraud  
• Failure to disclose household members  
• Misrepresentation of age by unaccompanied children   

The report concludes that documentation fraud by some sponsors created conditions that put children at risk and, in some instances, released them into dangerous or harmful situations. The Office of General Counsel’s review concludes that strengthened vetting requirements, such as enhanced identity checks, might have prevented some of these fraudulent practices and reduced risk to children.  

U.S. Department of Ed. and U.S. Department of the Treasury Launch Defaulted Loans Support Center  

The U.S. Departments of Education and Treasury announced the Defaulted Loans Support Center, an online portal that offers borrowers with defaulted federal student loans a streamlined way to understand the consequences of default and apply online to rehabilitate or consolidate their loans. Through the StudentAid.gov website, borrowers can complete the loan rehabilitation application online, upload documents, review an estimated payment, electronically sign their agreement, and track their progress. Additionally, borrowers can use the portal to apply online to consolidate and then access the recently extended 1% interest rate reduction by enrolling in auto pay. 

Department of Ed. Announces Improvements to the 2027-28 FAFSA Form   

Alongside the release of the 2027-2028 Free Application for Federal Student Aid form, the Department of Education shared key improvements to enhance, streamline, and modernize the financial aid process, including: 

• Ease of Renewal through pre-populated forms that include previous FAFSA data and allow parents and guardians with multiple students applying for federal aid to reuse their information across all applications  
• Immediate Responses for Pell Grant and federal aid eligibility  
• Redesigned Contributor Invite Process allowing students to invite their parent or contributor to complete their portion of the FAFSA form with a code and through text messages 
• Earnings Indicator may be used to see if graduates of colleges and universities to which students are applying for federal student aid have lower earnings than a high-school graduate   

Improvements also include fraud prevention initiatives, faster account confirmation, and clearer language.  

CMS Leads Efforts to Address Fraud, Waste, and Abuse in the Federal Health Insurance Marketplace Led to Coverage Losses for 760,000 Individuals  

The White House Task Force to Eliminate Fraud canceled approximately 315,000 unauthorized enrollments covering more than 760,000 individuals. The Centers for Medicare & Medicaid Services maintained that the efforts are expected to result in a return of roughly $2.2 billion in taxpayer-funded subsidies. The Administration promised to conduct “additional verification” on roughly 419,000 individuals to ensure they are legal U.S. residents and meet the income threshold requirements to receive benefits from the Affordable Care Act. 

CMS has also provided additional resources to review further anti-fraud efforts. The Administration also published an interim final rule, effective September 22, that would temporarily pause new Obamacare agent and broker registrations. The rule applies to all insurance navigators not currently signed up to help customers enroll in Affordable Care Act plans for 2027. Comments are due Nov. 21. 

Ahead of enrollment opening for the federal Obamacare marketplace Nov. 1, Senate leaders led a resolution to repeal a rule that would end coverage for up to two million Americans, raise out-of-pocket costs, and make it easier for insurance companies to cover fewer services. The resolution failed 51-48. 

CMS Projects Stable Pricing for Medicare Advantage and Medicare Prescription Drug Programs in 2027 

The Centers for Medicare & Medicaid Services announced projected premiums and medication costs for Medicare Advantage and Part D enrollees in 2027. 

Medicare Advantage   

• The weighted average monthly premium across all MA plans is projected to decrease from $14.37 in 2026 to $12.00 in 2027 
• Supplemental benefit offerings, including hearing, dental, and vision benefits, are expected to remain stable 

Part D   

• Average premiums for stand-alone Part D prescription drug plans are projected to rise by less than $1 per month in 2027 
• 88% of non-low-income beneficiaries will have access to a basic Part D plan that is $10.30 or less 
• 93% of non-low-income beneficiaries will have access to an enhanced Part D plan at less than $6 

H.R. 1 Provision Barring Refugees, Asylum Seekers, and Immigrants with Legal Status from Accessing Medicaid Takes Effect 

As of Oct. 1, refugees, asylees who fled persecution, victims of sex trafficking, and interpreters who risked their lives assisting U.S. service members in Afghanistan are at risk of losing Medicaid coverage due to a provision of H.R. 1. The Congressional Budget Office estimates approximately 100,000 noncitizen adults with legal status will become uninsured by 2034. 

Similarly, on Oct. 1, local governments witnessed a 25% growth in the administrative costs needed to administer the Supplemental Nutrition Assistance Program (SNAP) due to H.R. 1. However, as states work to supplement rising health care and nutrition costs, they are also experiencing marked budgetary shortfalls.  

The burden on states is mirrored by marked challenges nationwide in accessing SNAP: the Center on Budget and Policy Priorities estimates that well over 5 million individuals have likely lost SNAP benefits following the implementation of H.R. 1. 

HHS Announces Funding Awards to Support Community Health and Wellness 

The Substance Abuse and Mental Health Services Administration (SAMHSA) announced funding awards to expand access to addiction treatment. Initiatives include, $42.3 Million to Advance the “Treatment First” Model: SAMHSA awarded $42.3 million in supplemental funding to states and territories through two federal block grants, the Community Mental Health Services Block Grant and the Substance Use Prevention, Treatment, and Recovery Services Block Grant. The funding aims to advance President Trump’s Executive Order, Ending Crime and Disorder on America’s Streets, and accelerate adoption and implementation of the Best Practices Toolkit: Addressing Homelessness and Addiction through Treatment First. 

Funding will support: 

• Workforce capacity, technical assistance, and training 
• Policy development and cross-system coordination 
• Licensure, certification, and charter support 
• Technical infrastructure and outcome-measurement tools 

$247.9 Million to Expand Addiction Treatment, Overdose Prevention, and Mental Health Services: SAMHSA awarded $247.9 million in grants to expand access to addiction treatment, mental health services, and recovery support in communities nationwide. 

Funding will be directed to: 

• Expand access to medications for opioid use disorder  
• Strengthen school-based mental health support 
• Expand trauma treatment for children and families 
• Equip first responders and communities to reverse overdoses  

The Indian Health Service (IHS) awarded $3.5 million to 14 Tribal and urban Indian communities to support Tribal access to nutritious food through the Produce Prescription Pilot Program. The investment aims to support the establishment and implementation of locally driven produce prescription programs, reduce food insecurity, increase access to and consumption of fruits, vegetables, and traditional foods, and promote whole-person health and well-being. The announcement came shortly after IHS announced $ 2.3 million in awards to expand the Community Health Aide Program and support access to high-quality, community-based care. 

The Health Resources and Services Administration (HRSA) announced nearly $19 million in funding to expand access to healthcare through telehealth and innovative technologies. The awards aim to increase access to nutrition services, expand the use of emerging technologies to improve healthcare delivery, and strengthen the healthcare workforce in rural communities and other areas with limited access to care. HRSA announced additional awards shortly after to expand access to dental care for children with neurodevelopmental disorders. 

Sector Updates from the Judiciary 

Supreme Court Allows Expanded Voter-Verification Database  

The Supreme Court approved the Trump administration’s expansion of a federal centralized database to verify voters’ citizenship ahead of the Nov. 3 elections. The verdict overturns a lower court’s ruling, finding the initiative necessary to help states and local agencies properly administer the midterm elections, while rejecting privacy concerns.  

The lawsuit involves the Systematic Alien Verification for Entitlements (SAVE) database, established by Congress in 1986 to help confirm the immigration status of people applying for public benefits. The expansion, announced through an executive order, includes information from the Social Security Administration. 

Federal Court Permits Changes to Title X Grant Funding for Pregnancy Prevention Efforts 

The U.S. District Court for the Middle District of Pennsylvania dismissed a lawsuit challenging changes to how Title X grants are awarded. 

Congress established the Title X grant program in 1970 to serve low-income or uninsured individuals, including those who make too much to qualify for Medicaid but may not otherwise have access to family planning and reproductive health services.  The most recent notice of funding opportunity would shift the focus of the Title X grants from expanding access to services such as contraceptives to achieving healthy pregnancies and strengthening family formation. It also directs clinics to promote natural family planning methods. 

U.S. District Judge Jennifer P. Wilson determined that the family planning organizations that filed the lawsuit, the National Family Planning and Reproductive Health Association and the Family Health Council of Central Pennsylvania, did not present a “sufficiently concrete harm.”   

Federal Court Stops Teen Pregnancy Prevention Program Grant Funding From Lapsing Amid Litigation   

The United States District Court for the District of Columbia granted an order preventing teen pregnancy prevention funding from lapsing while a lawsuit challenging the Trump administration’s policy change continues. 

The lawsuit follows a previous order ruling against the cancellation of 53 existing Teen Pregnancy Prevention Program grants. The grants, totaling approximately $68 million, were canceled suddenly in June due to “misalignment with agency priority.”   

The Teen Pregnancy Prevention Program supports local initiatives proven to reduce teen pregnancy, prevent sexually transmitted infections, and support healthy relationships. Research has associated teen pregnancies with reduced education attainment, a greater likelihood of poverty, and worsened health outcomes. Likewise, poverty and child abuse and neglect have been associated as risk factors for early pregnancies.   

The administration introduced a replacement framework for curricula in July, shifting resources toward “reproductive goals counseling,” anatomy, fertility tracking, and abstinence rather than contraceptives.  

The order follows a letter from several members of Congress expressing concern for undistributed grant funding. 

Federal Court Prohibits Recently Imposed Conditions on Sexual Assault and Domestic Violence Grants 

The U.S. District Court for the District of Rhode Island rejected conditions restricting federal grants related to sexual assault and domestic violence programs, which would have led organizations found in violation to face the potential withholding of funds, contract termination, and award termination.

The conditions centered on immigration status, gender identity, and the inclusion of diversity, equity, and inclusion initiatives. Judge Melissa R. DuBose found the Department of Justice failed to consider the harm that grant recipients would face and to adequately explain its decision to condition grants. 

The grants were created through the Violence Against Women Act, part of the Violent Crime Control and Law Enforcement Act of 1994, to help organizations that support victims through legal services, housing assistance, and crisis counseling. 

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