U.S. Attorney General Pam Bondi recently issued guidance to educational institutions, state and local governments, and public and private employers reiterating the Trump administration’s January directive that all programs, policies, and activities must comply with existing federal anti-discrimination laws. 

The memorandum details that federal funding recipients may be liable for discrimination and funding revocations if they knowingly fund the unlawful practices of contractors, grantees, and other third parties. 

To minimize the legal risk of violating federal anti-discrimination laws and having federal grant funding revoked, the Department of Justice recommended the following, 

  1. Ensure inclusive access to all workplace programs, activities, and resources.  
  2. Document legitimate rationales to demonstrate that decisions are unrelated to protected characteristics. 
  3. Avoid exclusionary training programs and ensure trainings are open to all.  
  4. Include nondiscrimination clauses in contracts and specify that federal funds cannot be used for programs that discriminate.  
  5. Monitor third parties that receive federal funds to ensure ongoing compliance. 
  6. Establish clear anti-retaliation procedures and create safe reporting mechanisms and include these policies in employee handbooks and program guidelines. 

HHS Revives Task Force on Safer Childhood Vaccines 

The U.S. Department of Health and Human Services (HHS) announced the reinstatement of the Task Force on Safer Childhood Vaccines, a federal panel created by Congress to improve the safety, quality, and oversight of vaccines administered to children in the U.S. 

The taskforce will issue regular recommendations regarding the development, promotion, and refinement of childhood vaccines that result in fewer and less severe adverse reactions than those vaccines currently on the market. Recommendations will also center improvements in vaccine development, production, distribution, and adverse reaction reporting. HHS will transmit its first formal report to Congress within two years, with updates every two years thereafter. 

CMS Begins Oversight Process to Verify the Citizenship of Medicaid and CHIP Recipients 

The Centers for Medicare & Medicaid Services (CMS) initiated an oversight initiative to ensure that enrollees in Medicaid and the Children’s Health Insurance Program (CHIP) are U.S. citizens, U.S. nationals, or have a satisfactory immigration status.  

CMS is providing states with monthly enrollment reports, identifying individuals whose citizenship or immigration status could not be confirmed through federal databases, including the Department of Homeland Security’s Systematic Alien Verification for Entitlements (SAVE) program. States are then responsible for verifying individuals’ citizenship or immigration status and requesting additional documentation if needed. CMS has authorized states to take actions when necessary, including adjusting coverage or enforcing non-citizen eligibility rules.  

CMS began issuing the first set of reports on Aug. 19 and expects all states to have received a report within a month.  

Sector Updates from the Judiciary  

Supreme Court Temporarily Approves Grant Terminations  
Supreme Court narrowly agreed to allow the National Institutes of Health (NIH) to terminate $783 million in grants connected to diversity, equity, and inclusion (DEI) initiatives by a vote of 5 to 4. The court also upheld a lower court’s ruling, which blocked internal NIH guidance documents barring funding for research that does not align with the agency’s policy priorities. Specifically, the guidance prohibited funding for research connected to DEI, gender identity, vaccine hesitancy, COVID, and climate change. 

NIH’s grants were terminated following these executive orders: 

States, advocacy organizations, and researchers filed lawsuits in response, maintaining that terminating grants violates the Constitution and the Administrative Procedure Act. The District Court for the District of Massachusetts ordered the reinstatement of the grants, citing a lack of reasoned decision-making to explain the cancellations.   

However, the Supreme Court ruled that the district court lacked the authority to order the reinstatement of specific grants. The court majority opinion stated that the federal government would face “irreparable harm” if it paid the money for the grants and then was unable to recover the funds before the litigation was resolved. 

Appeals Court Upholds Significant Reductions in Foreign Aid 
The U.S. Court of Appeals for the D.C. Circuit overturned a lower court ruling after a district court determined that the Trump administration cannot suspend grants that do not comply with the president’s priorities. The appeals court determined that the nonprofit that issued the lawsuit lacked standing as they were unable to demonstrate a sufficient connection to and harm from the administration’s actions. The justices maintained that only the head of the Government Accountability Office (GAO) has the authority to file the lawsuit according to the Impoundment Control Act. 

The decision lifted a lower court’s order that had required the administration to continue processing foreign aid payments with funds Congress had budgeted. However, the judges clarified that their decision does not address the question of whether pausing foreign aid violates the U.S. Constitution by infringing on the spending power of Congress. 

Although the GAO has determined impoundment has occurred in several instances, the agency has not yet filed litigation. Recently, the GAO issued a report determining that the U.S. Department of Health and Human Services’ significant reductions in the rate of disbursement for Head Start funding constituted impoundment. Additionally, the GAO found that the National Institutes of Health’s cancellation of grants and withholding of funds violated the Impoundment Control Act of 1974. Nevertheless, the reports are nonbinding without a court order compelling the agency to release funds.  

Federal Court Prohibits HHS from Sharing Medicaid Data for Immigration Enforcement Purposes 
The U.S. District Court for the Northern District of California prohibited the Department of Homeland Security and the U.S. Department of Health and Human Services from sharing Medicaid data from the plaintiff states for immigration purposes as litigation continues. The plaintiff states include California, Arizona, Delaware, Illinois, and Maine. 

Federal Court Denies Injunction Against Alabama Law Banning DEI Programs in Public Schools  
Students and faculty filed a lawsuit against the governor of Alabama and the University of Alabama’s trustees, maintaining that a recently passed state law violates their freedom of speech by placing viewpoint-based restrictions on what can be taught in classes. S. 129 prohibits public colleges from funding or sponsoring diversity, equity, and inclusion programs.  

S. 129 defines diversity, equity, and inclusion initiatives as programs, training, or other events where attendance is based on “race, sex, gender identity, ethnicity, national origin, or sexual orientation.”  Additionally, the law prohibits public colleges from requiring students to affirm or adhere to a list of so-called divisive concepts. One example is that fault, blame, or bias should be assigned to a person based on their race or sex, or that any person should acknowledge a sense of guilt, complicity, or a need to apologize because of their race, sex, or national origin. Another is that people are “inherently racist, sexist, or oppressive, whether consciously or subconsciously,” based on their personal characteristics.  

Faculty members stated that they were unsure of how to comply with the law and stressed its potential to limit instruction on other topics, like eugenics. Nevertheless, U.S. District Judge David Proctor determined that the law does not prohibit the teaching of divisive concepts, especially because of the exemptions S. 129 names. The court determined that the plaintiffs had not met the legal burden required to issue a preliminary injunction.  

District Court Determines Florida Law Restricting Pronouns Constitutes Discrimination 
U.S. District Judge Mark Walker determined H.B. 1069, a 2023 Florida law that requires teachers to use pronouns that align with their sex assigned at birth, violates federal civil rights law. Failure to comply may result in disciplinary action, which may include suspension or termination of employment.  

Further action is paused until the 11th U.S. Circuit Court of Appeals considers a lawsuit alleging a Title VII violation against a transgender employee of a Georgia sheriff’s office, Lange v. Houston County. 

District Court Extends Preliminary Injunction Against Grant Funding Conditions  
Judge Barbara J. Rothstein recently expanded a previous preliminary injunction, preventing the Trump administration from imposing funding conditions on $12 billion of grant funding. The grants were disbursed to thirty-one cities with the intention of addressing homelessness and transit infrastructure.  

The verdict temporarily prevents nearly a dozen federal agencies from enforcing new rules that would have required cities to align with elements of the Trump administration’s policy agenda to receive funding. 

Federal Court Blocks ACA Religious Exemptions to Coverage for Contraception 
The US District Court for the Eastern District of Pennsylvania determined that the Trump administration cannot enforce religious and moral exemptions to an Affordable Care Act rule that requires all employer health plans to cover contraception and related services at no cost to employees. District Judge Wendy Beetlestone maintained that the rules were arbitrary, inconsistent, and an overreach of the agency’s authority. 

The rules, issued in 2018, enabled essentially all for-profit or nonprofit employers and insurers to exempt themselves from following the birth control mandate on moral and religious grounds. 

Federal Court Upholds the Constitutionality of the Medicare Drug Price Negotiation Program 
The U.S. 2nd Circuit Court of Appeals upheld a lower court ruling, determining that a pharmaceutical company could not demonstrate that Medicare drug price negotiations had caused irreparable harm. The court also upheld that the program did not violate federal law, including the Medicare Act or the Administrative Procedures Act. 

The Western District of Texas issued a similar verdict, affirming that participation is voluntary and therefore the company’s constitutional right to due process was not violated. Likewise, the Sixth Circuit Court of Appeals held that the plaintiffs lacked standing to pursue their challenge against the negotiation program in Ohio.  

The Medicare Drug Price Negotiation Program was established by the Inflation Reduction Act of 2022. The law empowers Medicare to use its considerable bargaining power to obtain lower prices for certain medicines, significantly expanding access to treatment options. 

Appeals Court Upholds Arkansas Law Banning Youth Transgender Care  
The 8th U.S. Circuit Court of Appeals upheld the Save Adolescents From Experimentation (SAFE) Act, Act 626, an Arkansas law barring doctors from providing gender-affirming care, including puberty blockers, hormones, and surgery to transgender minors. 

The decision reverses a lower court ruling and cites a similar verdict issued by the U.S. Supreme Court, which held that Tennessee’s similar law did not discriminate based on sex or transgender status. The Tennessee law, SB1, banned puberty blockers and hormone therapy for transgender teenagers.

The Circuit Court also determined the Arkansas law did not violate parents’ due process rights afforded by the Fourteenth Amendment. The judges cited a lack of historical support entitling parents to obtain medical treatment for their children that a state legislature deems inappropriate. 

Federal Court Partially Blocks Mississippi Law Restricting DEI in Practices in Public Schools 
The United States District Court for the Southern District of Mississippi blocked the implementation of certain provisions of House Bill 1193, a Mississippi state law that would have prohibited diversity, equity, and inclusion (DEI) practices in public schools.  

Specifically, the bill requires public schools to prohibit the discussion of “divisive concepts” related to race, sex, gender identity, sexual orientation, and national origin. It also requires schools to prohibit programs, courses, or offices that promote DEI, endorse divisive concepts, or ban diversity training requirements. 

However, U.S. District Judge Henry Wingate determined that the law is unconstitutionally vague, fails to treat speech in a viewpoint-neutral manner, and holds the potential to chill expression and academic freedom. As litigation continues, neither of the previously mentioned sections can be enforced. 

Nevertheless, the preliminary injunction is limited to certain provisions of the law. Schools must uphold sections of the law that prohibit preferential treatment based on race, sex, color, or national origin. Additionally, schools cannot penalize students or staff for their refusal to embrace DEI concepts. 

Federal Court Invalidates the Department of Education’s Title VI Guidance 
The U.S. District Court for the District of Maryland determined that the Education Department’s recent guidance prohibiting educational institutions from engaging with DEI initiatives was unlawful.   

The lawsuit was filed in response to guidance issued by the Department of Education. A memorandum issued Feb. 14 and a certification issued April 3 ordered schools and universities to end all “race-based decision-making” and warned of the loss of federal funding for organizations that failed to comply. 

U.S. District Judge Stephanie Gallagher determined that the memorandum and directive did not follow administrative procedure.  Judge Gallagher also ruled that the guidance violated constitutional rights by placing viewpoint-based restrictions on classroom speech. 

Subscribe to the Policy and Advocacy Radar to receive our biweekly policy roundup, which includes commentary on issues in Social Current’s federal policy agenda, opportunities to take action, and curated news and opportunities.

Across the U.S., nonprofit organizations that provide critical human services, such as foster care, mental health treatment, substance use recovery programs, and elder care, continue to face a liability insurance crisis. Coverage limitations, nonrenewal by their carrier, unaffordable premiums, and carriers exiting the market are among the critical challenges being experienced by providers, regardless of their insurance claim or loss history.

Management liability and cyber insurance costs are projected to fall in 2025 for nonprofits, according to Risk Strategies’ 2025 Insurance Trends Report. However, all other forms of insurance costs are projected to increase 10-30% for nonprofits in the coming year, particularly for general liability (+5-10%), abuse and professional liability (+15-20%), and umbrella (+20-30%) coverage. A 2025 national survey conducted by the National Organization of State Associations for Children (NOSAC) and the Association of Children’s Residential & Community Services reveals the gravity of the situation. Since 2019, respondents reported an average increase of 163% in premiums, with one quarter seeing a premium increase of 200-1800%. Such increases are unsustainable for already under-resourced nonprofits.

Drivers Behind Rising Insurance Costs

Several factors are contributing to this crisis, including:

Resulting Challenges for Providers and Their Communities

Increasing barriers to securing affordable and sufficient insurance coverage poses challenges that are experienced throughout communities.

Proposed Policy Solutions

To address this growing crisis, Social Current has proposed a set of policy solutions aimed at making liability insurance more accessible and affordable:

Without swift and strategic action, the liability insurance crisis threatens to destabilize organizations that families and communities rely on for essential care and support. Social Current emphasizes that this issue demands collaboration across sectors—including insurers, policymakers, and nonprofit leaders—to build long-term, sustainable insurance solutions. By implementing targeted reforms such as public insurance funds, federal mandates and incentives, and pooled insurance models, the sector can protect the future of human services and ensure that communities continue to receive support.

Download this spotlight on liability insurance as a PDF.

Sources and Further Reading:

Social Current Solutions

Risk Assessment & Reduction

Large-scale solutions are needed to address this complex challenge. Unfortunately, risk mitigation at the organizational level does not necessarily translate to lower insurance costs. Yet, individual organizations can reduce their exposure to liability claims through strategic risk mitigation. Social Current offers several resources to support risk management.

Nonprofit Risk Management Center (NRMC)
The Nonprofit Risk Management Center (NRMC) is a nonprofit dedicated to helping other nonprofit organizations understand and manage the various risks they face. Social Current network organizations have access to NRMC’s extensive collections of risk assessments and tools, including in-depth information on insurance coverage. For access, create an affiliate member account and choose Social Current as the affiliate.

Leadership and Organizational Development Consulting
One of the most effective risk mitigation strategies is building a risk-aware workplace culture. It’s more than just compliance; it’s about proactively prioritizing the recruitment and retention of qualified employees, alongside continuous training. Social Current offers customized leadership and organizational development consulting services designed to ensure your team is well-equipped to perform their jobs expertly and reduce risk for your organization.

COA Accreditation
COA Accreditation, a service of Social Current, provides an evidence-based framework for nonprofit organizations to reduce risks. By requiring adherence to rigorous, research-based standards, COA Accreditation requires organizations to proactively examine and enhance their operations across critical areas like legal compliance, financial management, human resources, governance, and program delivery. This systematic approach ensures the development of clear policies and procedures, robust internal controls, and a culture of accountability, minimizing vulnerabilities to legal challenges, financial mismanagement, and operational failures.

Additionally, COA Accreditation fosters continuous quality improvement and the adoption of best practices, leading to more effective service delivery and better outcomes. Achieving COA Accreditation mitigates internal risks as well as builds external credibility and trust with funders, donors, and the public, strengthening the organization’s reputation.

Knowledge and Insights Center Resources

Business, Media, & Research Databases
From thousands of premium journals to the latest social sector news and media, Social Current Impact Partners and KIC subscribers have access to a wealth of evidence-based resources to support them in addressing any leadership challenge.

About the Knowledge and Insights Center
Social Current’s Knowledge and Insights Center equips social sector professionals with the research and resources they need to stay current on trends, implement best practices, and improve their organizations. It specializes in vetting information sources and systematizing information so that it is easy to understand. Gain access to the Knowledge and Insights Center by becoming a Social Current Impact Partner or purchasing access.

Download this spotlight on liability insurance as a PDF.

On Aug. 7, President Trump signed an executive order to strengthen the oversight and coordination of agency grantmaking as a means for increasing the accountability of the use of public funds. The order directs each agency head to designate a senior appointee to create a process to review new funding opportunity announcements and discretionary grants to ensure that they are consistent with agency priorities and the national interest. The order also encourages the use of plain language and interagency coordination to promote consistency and eliminate redundancy.

The executive order specifies that discretionary awards are not to be used to fund, promote, encourage, subsidize, or facilitate any initiatives that compromise public safety or promote anti-American values, racial preferences, illegal immigration, and the denial by the grant recipient of the sex binary in humans or the notion that sex is a chosen or mutable characteristic.

For future discretionary grant agreements terms and conditions, the order encourages language to prohibit recipients from directly drawing down general grant funds for specific projects without the affirmative authorization of the agency. It also recommends requiring grantees to provide written explanations or support, with specificity, for requests for each draw down.

For existing discretionary grants, the order directs agencies to revise their terms and conditions to permit their termination if an award no longer effectuates the program goals or agency priorities. In the case of a partial termination by the recipient, language should be standardized to include the grant’s termination if the agency determines that the remaining portion of the federal award will not accomplish the purposes for which the award was made.

Federal Agencies Pause Policies Restricting Eligibility of Certain Public Benefits

The Departments of Labor, Education, Justice, and Health and Human Services recently released notice of restricted eligibility for specific populations of immigrants and citizens receiving public benefits through the Personal Responsibility and Work Opportunity Reconciliation Act of 1996. The named benefits include programs that increase access to community mental health care, nutrition, housing support, and early childhood education.

Lawsuits were filed by 20 states and the District of Columbia in response, alleging federal agencies did not follow the required rulemaking process in issuing new immigration verification requirements.

The plaintiffs reached an agreement with the Trump administration to temporarily pause the policies’ enforcement until Sept. 3. The agreement is effective for the District of Columbia and the following states: New York, Washington, Rhode Island, Arizona, California, Colorado, Connecticut, Hawaii, Illinois, Maine, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Jersey, New Mexico, Oregon, Vermont, and Wisconsin.

Senate Committee Approves FY 2026 Labor, HHS, Education Appropriations Bill

On July 31, the Senate Committee on Appropriations approved the FY 2026 Labor, Health and Human Services, Education, and Related Agencies Appropriations Act by a vote of 26 to 3.

The bill increases discretionary funding for the U.S. Department of Health and Human Services by $446 million, compared to FY25. Key funding increases were approved for the Child Care and Development Block Grant, Head Start, and IDEA Special Education State grant programs. Additionally, the bill increases funding for the Substance Use Prevention, Treatment, and Recovery Services Block Grant, State Opioid Response grants, and the 988 Suicide Prevention Lifeline. It restores dedicated funding for the LGBTQ+ youth specialized services line.

The Senate Committee on Appropriations voted to maintain funding for the Administration for Community Living and increase funding for the Low Income Home Energy Assistance Program (LIHEAP). For further information, read the detailed summary of the bill published by Vice Chair of Appropriations Sen. Patty Murray (D-Wash).

Head Start Approves Temporary Supplemental Funds for Nutrition and Healthy Eating

The Administration for Children and Families released program instructions outlining the process for Head Start grant recipients to request one-time supplemental funding to promote nutrition services and healthy eating for enrolled children and families. Funds may be allocated toward food service upgrades, materials, supplies and equipment, nutrition education resources, or non-recurring personnel costs.

Grant recipients are encouraged to assess programmatic and community nutrition and health needs and consider the immediate, interim, and long-term impact and associated costs. Applications will be reviewed on a rolling basis and the priority deadline is Aug. 22.

Senate Holds Hearing to Address Elder Abuse & Neglect

On July 30, the U.S. Senate Special Committee on Aging held a hearing to discuss elder abuse and neglect. Senators and witnesses emphasized the importance of preventive approaches and maintaining a comprehensive network of support, especially since several instances of older abuse and neglect remain undetected.

Specifically, witnesses discussed the importance of Area Agencies on Aging to ensure older adults have access to necessary resources and opportunities for support through trusted relationships. They recommended equipping multidisciplinary teams with specialized training to grow community awareness and increase support for caregivers. Witnesses also encouraged the reauthorization of the Older Americans Act and strengthening the enforcement of federal standards in nursing facilities.

Sector Updates from the Judiciary

District Court Pauses Conditions on Domestic Violence Grants
The U.S. District Court for the District of Rhode Island issued a temporary restraining order to prevent the U.S. Departments of Health and Human Services and Housing and Urban Development from enforcing certain grant requirements. Specifically, the policies enabled the departments to deny funding for programs that support diversity, equity, and inclusion initiatives.

The temporary restraining order is effective for a coalition of 22 organizations that filed the lawsuit as the court considers an injunction.

District Court Dismisses Lawsuit Against Sanctuary Policies
The U.S. District Court for the Northern District of Illinois dismissed a lawsuit filed by the Trump administration that alleged sanctuary policies obstruct federal efforts to enforce immigration laws. While sanctuary cities do not have a single definition, they typically refer to a broad range of policies that limit cooperation with federal immigration enforcement actions.

The Trump administration argued Illinois’ city, county, and state laws restrict information sharing with federal law enforcement officials and prevent immigration agents from identifying certain individuals.

Judge Lindsay Jenkins determined that the U.S. lacks standing to sue over sanctuary policies, as Illinois’ decision to enact the sanctuary laws is protected by the 10th Amendment. The 10th Amendment reserves any power for the states that is not explicitly granted to the federal government or denied to the states through the U.S. Constitution.

District Court Issues Nationwide Injunction Against Birthright Citizenship Executive Order
The U.S. District Court for the District of Massachusetts issued a nationwide injunction to pause an executive order that would restrict birthright citizenship to newborns with at least one parent who is a U.S. citizen or green card holder.

The lawsuit was filed by 18 states, alleging that they would suffer significant financial harm if the executive order were to take effect and citing the complexities of a patchwork system of citizenship.

Appeals Court Dismisses Lawsuit Challenging Washington Law Regarding Care for Transgender Youth
The U.S. Court of Appeals for the Ninth Circuit determined that parents do not have the legal authority to file a lawsuit against a Washington law that addresses the rights of transgender runaway youth who seek gender-affirming care at shelters.

The 2023 state law, SB 5599, excuses shelters from notifying parents whose children seek gender-affirming treatment and reproductive health services when the shelters have concerns that a notification could lead to parental abuse or neglect.

The lawsuit also addressed legislation governing outpatient treatment without parental consent and the obligations of state health officials to work with parents of runaway children.

District Court Pauses Medicaid Cuts to Planned Parenthood
The U.S. District Court for the District of Massachusetts issued a preliminary injunction against a provision of the recently enacted tax and spending bill, H.R. 1. The provision would prevent Planned Parenthood and its members from receiving Medicaid funding if they continue to provide abortions.

U.S. District Judge Talwani determined that the law likely violates the U.S. Constitution by specifically excluding Planned Parenthood’s health centers due to their status as abortion providers. The judge maintained that the law also violates Planned Parenthood members’ equal protection rights under the U.S. Constitution’s Fifth Amendment.

While litigation continues, the U.S. Department of Health and Human Services cannot apply the provision to exclude any of Planned Parenthood’s health centers from Medicaid reimbursements.

District Court Pauses Termination of LGBTQ+ Health Research Grants
The U.S. District Court for the District of Maryland issued a preliminary junction, blocking the cancellation of more than $800 million in National institutes of Health (NIH) LGBTQ+ health research grants. The grants funded research considering issues related to gender dysphoria, mental health, and HIV/AIDS care.

The lawsuit was filed by the American Association of Physicians for Human Rights against the NIH and Department of Health and Human Services. The plaintiffs alleged that by targeting only certain, predominantly LGBTQ+-related research projects for funding cuts, the NIH engaged in unlawful discrimination.

Subscribe to the Policy and Advocacy Radar to receive our biweekly policy roundup, which includes commentary on issues in Social Current’s federal policy agenda, opportunities to take action, and curated news and opportunities.

Social Current is excited to introduce the newest cohort of our Executive Leadership Institute, our yearlong leadership development program held in partnership with Loyola University Chicago’s Quinlan School of Business. 

This dynamic group of leaders is helping to shape the future of the social sector. They represent a diverse cross-section of human and social services organizations, all united by a shared commitment to helping all people thrive. 

The participants will learn from experts, receive guidance from mentors, and apply their learning to projects that strengthen their organizations. We’re excited to support this cohort on this next step in their leadership journey. 

Learn more about the Executive Leadership Institute online. To stay in the loop about our 2026-2027 institute, share your email.

Announcing the 2025-2026 Executive Leadership Institute Cohort

Randy Bendle

Operations Director, Alaska Family Services, Inc.

Victoria Dawson

Vice President of Operations, Family Service Association

Milton Fonseca

Director of Performance and Quality Improvement & Director of Operations, Volusia County Advocate Program, Inc.

Dr. Devon Goetze, MPA, PhD

Director of Housing Services, Auberle

Celeste Hurley

Executive Director, Violence Free Futures, Inc.

Vanessa Kucera

Deputy Director, Chief Operating and Financial Officer, MYSI Corporation

Iris Lopez

Division Chief Community Based Services, Hillsides

Amanda Masterson

CEO, Boys & Girls Haven

Christine Roerig

Director of Marketing, Shelter Inc

Michelle Saint Hilarie

Senior Statewide Program Director, Child & Family Resources, Inc.

Meleah Spencer

CEO, The Kitchen Inc.

Tony Weaver

Vice President, Clinical and Housing Services, Wayfinder Family Services

The 2025 edition of updates to the standards for COA Accreditation, a service of Social Current, is now available. These targeted enhancements to the standards are the result of our annual update process and include changes based on ongoing collection and analysis of feedback received from our network, collaboration with diverse groups of subject matter experts, and a review of research and professional literature on identified trends and evolving practices.

Our collaborative update process is designed to ensure the standards remain up-to-date, research-based, and field-informed, promoting improved outcomes for individuals, families, and communities.

Who’s Affected

These changes impact private, public, and Canadian organizations seeking COA accreditation or reaccreditation. The 2025 edition of updates will not impact organizations that are currently pursuing accreditation or re-accreditation and have already been assigned standards in the MyCOA portal.

When It Is Happening

Standards assignments for COA Accreditation using the new standards began July 28, 2025.

What’s Changing In Our Standards

Download the adult day standards for private, public, and Canadian organizations to see the 2025 updates that were made to this fully revised section.

Download the case management standards for private, public, and Canadian organizations to see the 2025 updates that were made to this fully revised section.

Download the child and family services standards for public organizations to see the 2025 updates that were made to portions of this section to reflect new federal licensing rules for kinship caregivers.

Download the early childhood education standards for private, public, and Canadian organizations to see the 2025 updates that were made to this fully revised section.

Download the foster and kinship care standards for private and Canadian organizations to see the 2025 updates that were made to portions of this section to reflect improved practice for working with kinship caregivers.

Download the for-profit administration and financial management standards for private and Canadian organizations to see the 2025 updates that were made to this fully revised section.

Download the vocational rehabilitation standards for private, public, and Canadian organizations to see the 2025 updates that were made to this fully revised section.

Download the workforce development and support standards for private, public, and Canadian organizations to see the 2025 updates that were made to this fully revised section.

In response to feedback from our network, we are also releasing a collection of revisions throughout the COA Accreditation standards to provide clarity and/or remain current with trends in the field. Highlights include:

  • Clarifying CPR training requirements
  • Changes to training requirements related to working with individuals with intellectual or developmental disabilities
  • Updates focused on promoting fairness, dignity, respect, and equal opportunity for all staff and persons served

Download a copy of the additional revisions for private, public, and Canadian organizations to see the 2025 updates that were made throughout the standards.

Our Standards Update Process

The 2025 COA Accreditation standards updates reflect changes made based on evolving practices, ongoing review of relevant literature, and the continuous feedback we receive from our network, including volunteer reviewers and accredited organizations. More specifically, updating the 2025 Standards involved:

Questions?

If you are currently pursuing accreditation or re-accreditation, please reach out to your accreditation coordinator.

If you are seeking accreditation for the first time, join an introductory webinar or contact Joe Perrow, senior manager of network engagement and growth at Social Current.

For additional information about COA Accreditation standards, please contact Melissa Dury, director of standards at Social Current.

The U.S. Departments of Health and Human Services and Education significantly reduced their workforce following a Supreme Court ruling that permitted the Trump Administration to proceed with its restructuring plans as litigation continues. 

The U.S. Department of Health and Human Services has reduced its staff by about 25% as it tries to consolidate its 28 divisions into 15 and reduce its 10 regional offices to 5. 

A limited primary injunction restricted layoffs in specific agencies, including the Centers for Disease Control and Prevention, the Food and Drug Administration’s Center for Tobacco Products, the Office of Head Start, and the Office of the Assistant Secretary for Planning and Evaluation. 

Additionally, the Supreme Court overruled a lower court and permitted the Department of Education to proceed with its plans to terminate as many as 1,400 employees, nearly a third of its workforce. 

President Trump Signs an Executive Order Addressing Homelessness  

On July 24, President Trump signed an executive order, Ending Crime and Disorder on America’s Streets, redirecting federal funding to provide unhoused individuals suffering from serious mental illness or addiction with assisted outpatient treatment and care from treatment centers and similar facilities. The order redirects federal resources toward programs treating substance use. It also enables state and local governments‘ to implement “maximally flexible civil commitment, institutional treatment, and ‘step-down’ treatment standards that allow for the appropriate commitment” of unhoused individuals who are a danger to themselves or others.  

Recipients of federal housing and homelessness assistance who engage in illegal practices or practice harm reduction and safe consumption efforts may have their funding frozen. The order encourages all actions, to the greatest extent permitted by law, to end support for housing first policies that deprioritize accountability and fail to promote treatment, recovery, and self-sufficiency. 

The order permits recipients of federal funding for homelessness assistance to collect health-related information that the Secretary of Housing and Urban Development determines is necessary and effective to operate programs successfully. The data may then be shared with law enforcement authorities to provide appropriate care or to connect individuals with public health resources. Additionally, the order prioritizes funding for the expansion of drug and mental health courts. 

Senate Appropriations Committee Approves Transportation-HUD Bills 

The Senate Appropriations Committee voted 27 to 1 to approve the Fiscal Year 2026 Transportation, Housing and Urban Development, and Related Agencies Appropriations Act. 

The bill significantly increases funding for rental assistance programs, including through a $1.3 billion increase for tenant-based Section 8 vouchers compared to fiscal year 2025. The bill also appropriates $30 million for new incremental vouchers available to youth within, and those aging out of, the foster care system. 

The bill provides $4.5 billion for Homeless Assistance Grants, a $479 million increase above fiscal year 2025. Key allocations include $100 million toward new, permanent supportive housing, $107 million for new investments to address youth homelessness, and $52 million for new supports for survivors of domestic violence. 

For further information, the U.S. Senate Committee on Appropriations published a summary of key provisions within the bill. 

https://www.appropriations.senate.gov/imo/media/doc/fy26_thud_senate_bill_summary.pdf

HHS Issues Guidance Regarding DEI Initiatives to SSBG, CCDBG, and CBG Recipients 

The Office of Community Services (OCS) strongly encourages all recipients of entitlement awards funded by Title XX of the Social Security Act to review all Intended Use Plans, pre-expenditure reports, and expenditures and services under these programs, including those made by subrecipients or contractors. Recipients are advised to ensure that they do not support diversity, equity, and inclusion (DEI) initiatives or any other initiatives that discriminate on the basis of race, color, religion, sex, national origin, or any other protected characteristic.  

Likewise, the Office of Child Care (OCC) strongly encouraged all recipients of formula awards funded by the Child Care and Development Block Grant (CCDBG) Act to review all plans, services, strategies, and expenditures under these programs, including those made by subrecipients or contractors. 

OCC and OCS recommend recipients take prompt action to conduct reviews for compliance with all applicable laws. Individuals are strongly encouraged to review budgets, budget justification narratives, program goals, and other materials to ensure that federal funds are not used for unlawful DEI initiatives. Expenditures found to be out of compliance with federal law may be subject to enforcement in accordance with applicable law and the terms and conditions of the award. 

Congress Rescinds Public Broadcasting and Foreign Aid 

Congress recently passed H.R. 4, the Rescissions Act of 2025. The bill rescinds $9 billion in previously appropriated funds, including approximately $1.1 billion for the Corporation for Public Broadcasting and $8 billion in foreign aid. 

The House passed the bill by a vote of 216 to 213, and the Senate, 51 to 48. 

Congressional leaders stressed the importance of public radio in offering cultural, informational, and educational programming. They also highlighted its unique ability to provide individuals with access to vital emergency alerting and reporting in times of crisis. 

Moreover, the reductions in foreign aid directly impact the receipt of emergency shelter, water, health care, and family reunification for refugees and countries experiencing natural disasters and conflicts. 

CMS Works to Reduce Duplicate Enrollment in Medicaid/ACA Exchange Plans 

The Centers for Medicare & Medicaid Services (CMS) is partnering with states to reduce duplicate enrollments through three key initiatives. 

For Individuals Enrolled in Two or More Medicaid Programs, CMS will request that states verify eligibility. 

For Individuals Enrolled in Medicaid or CHIP and a Subsidized Federally Facilitated Exchange (FFE) Plan, CMS will request that individuals disenroll from Medicaid or CHIP if no longer eligible, end their subsidy (with the option to end their coverage), or notify the Exchange that the data match is incorrect. After 30 days, the FFE will end the subsidy for individuals who still appear to be enrolled in both Medicaid or CHIP and an Exchange plan with a subsidy. 

For Individuals Enrolled in Medicaid or CHIP and a Subsidized State-Based Exchange (SBE) Plan, CMS will provide SBEs with a list of individuals who are potentially enrolled in the state’s Medicaid or CHIP and a subsidized Exchange plan and ask SBEs to determine whether these individuals are dually enrolled, and if so, to implement a process, similar to the federal Exchange, to recheck eligibility. CMS will work with states to prevent individuals from losing coverage inappropriately. 

U.S. Department of Education Issues a Dear Colleague Letter Regarding H.R. 1 Implementation 

The U.S. Department of Education recently issued a Dear Colleague Letter outlining amendments to the Higher Education Act of 1965 through H.R. 1 that were enacted immediately.  

Additionally, the letter provided notice that the Department is currently developing a schedule of loan reductions for part-time students. Reductions in the annual loan limit required by H.R. 1 will be made in proportion to the degree to which the student is not enrolled full-time, rounded to the nearest percentage point. Public comments will open later this year. 

CMS Restricts Workforce and Multiyear Eligibility Waivers 

The Centers for Medicare & Medicaid Services (CMS) recently issued two letters to states detailing that the agency does not anticipate approving new or extending existing section 1115 demonstration authorities, which expand continuous eligibility. CMS also stated that it does not anticipate approving new or extending existing Medicaid-funded workforce initiatives for training or employment-related activities. 

CMS highlighted the importance of the policy change to preserve these vital programs for the most vulnerable Americans by removing costly initiatives that are estimated to require more than a billion dollar investment.  

HUD Terminates PAVE Task Force 

The U.S. Department of Housing and Urban Development (HUD) and the Office of Information and Regulatory Affairs (OIRA) announced the termination of the Property Appraisal and Valuation Equity (PAVE) task force. The decision aligns with a recently issued executive order, Ending Radical and Wasteful Government DEI Programs and Preferencing. 

The task force was established to address systemic biases in the home appraisal process, particularly in the evaluation of properties in Black and Hispanic neighborhoods. However, HUD determined that by reducing the regulatory hurdles that lenders, appraisers, and other program participants face, the Federal Housing Administration will be better able to serve American homebuyers and homeowners. 

House Judiciary Subcommittee Examines Nonprofit Misuse of Federal Funds 

On July 15, the House Judiciary Subcommittee on Oversight held a hearing entitled, “How Leftist Nonprofit Networks Exploit Federal Tax Dollars to Advance a Radical Agenda.” Witnesses and representatives discussed the exploitation of federal tax dollars by nonprofits. They alleged nonprofits leveraged federal grants from the U.S. Agency for International Development and the Justice Department to fund causes fundamentally opposed to the national interests of Americans. 

Witnesses emphasized the importance of transparency, highlighting the substantial amount of federal funding received. They also detailed ideological perspectives espoused by nonprofits and the promotion of initiatives misaligned with the consensus of American citizens. Witnesses offered the examples of universities, museums, public broadcasters, and USAID as key institutions. 

Certain representatives highlighted the critical role of nonprofits in serving vulnerable populations, including by confronting transnational crime and supporting victims of trafficking and sexual abuse. The minority witness also highlighted the selection process and ongoing monitoring for nongovernment organizations that request and receive federal funding for programs such as law enforcement training, victim/witness assistance, and rule of law programming in countries professionalizing their criminal justice response. 

Homeland Security Committee Considers Nonprofit Involvement in Immigration Challenges Through the Biden Administration 

On July 16, the House Homeland Security Committee held a hearing entitled “An Inside Job: How NGOs Facilitated the Biden Border Crisis.” Representatives and witnesses discussed the vulnerability of unaccompanied minors to trafficking, exploitation, and forced labor. They stressed inadequate border security, frequency of falsified records, and a broad failure to aid and monitor unaccompanied minors properly. 

Witnesses and several representatives alleged that non-government organizations misused federal funds to aid in and incentivize illegal immigration. They recommended oversight to ensure proper stewardship of federal funds and promote clear, continuous communication with local governments. Specifically, witnesses recommended a complete forensic audit of all Office of Refugee Resettlement contracts exceeding $100 million, mandated transparent public disclosures, and independent federal oversight. 

Certain representatives stressed the harm of funding reductions and pauses. They highlighted the essential role of non-profits as non-political entities in serving vulnerable and marginalized communities. Representatives additionally raised concerns about the practices of U.S. Immigration and Customs Enforcement, including their detainment of American citizens, agents’ failure to identify themselves in arrests, and conditions of detention centers. 

Senate Subcommittee Discusses Educational Choice and Literacy 

On July 23, the Senate Committee on Health, Education, Labor, and Pensions’ Subcommittee on Education and the American Family held a hearing to discuss educational choice and literacy. The hearing centered family empowerment, the challenges the education system faces, and the need to support students in achieving academic success. 

Certain senators and the Vice President of the Board of Education for the San Diego Unified School District expressed concern in response to the increasing privatization of K-12 education. They jointly stressed the importance of investments in evidence-based strategies and support for students with the highest needs, including those with disabilities. 

Sector Updates from the Judiciary 

Federal Court Upholds State Restriction of Chemical Abortions 

The U.S. Court of Appeals for the Fourth Circuit determined that West Virginia is permitted to restrict access to the abortion-inducing drug, Mifepristone. The verdict isthe first federal appeals court’s ruling that Mifepristone may be subject to state restrictions prohibiting its use. 

The Court of Appeals held that Congress did not specifically indicate that the U.S. Food and Drug Administration had exclusive regulatory power over the medication. Additionally, the majority stressed states’ historic and sovereign right to protect the health and safety of their citizens. 

Court Pauses a Mississippi Education Law Prohibiting DEI Programs and Curriculum  

The U.S. District Court for the Southern District of Mississippi temporarily blocked HB 1193, a Mississippi law that prohibits the state’s public schools and universities from teaching “divisive concepts,” determining it likely violates the First Amendment. The law also prohibits the establishment or maintenance of diversity, equity, and inclusion (DEI) offices, programs, trainings, or activities.  

Judge Wingate determined that the law’s restrictions are excessively broad, and its vague language may be construed for arbitrary enforcement, fostering a risk that protected speech would be silenced. He also emphasized the harm that plaintiffs would experience through the threat of funding withdrawals and the pace and breadth of programmatic shutdowns. 

The temporary restraining order will remain in effect until the court rules on the plaintiffs’ motion for a preliminary injunction. If the preliminary injunction is successful, the law will not be enforced while litigation is occurring. 

Federal Appeals Court Upholds Constitutionality of Birthright Citizenship 

The 9th U.S. Circuit Court of Appeals determined that a recently issued executive order, Protecting the Meaning and Value of American Citizenship, is unconstitutional. The order denies citizenship to any individual born in the U.S. if they do not have at least one parent with permanent legal status. 

The court affirmed the necessity of a nationwide preliminary injunction issued by a lower court. The majority cited the executive order’s violation of the Citizenship Clause of the Constitution, precedent from previous litigation, and decades of Executive Branch practice. U.S. Circuit Judge Bumatay dissented, arguing that the states lacked a legal right to bring the lawsuit.  

Subscribe to the Policy and Advocacy Radar to receive our biweekly policy roundup, which includes commentary on issues in Social Current’s federal policy agenda, opportunities to take action, and curated news and opportunities.

The second half of 2025 will be replete with contrasts for the social sector. Opportunities to build trust, promote workplace wellness, and leverage technology will be met with serious threats from funding reductions, policy changes, and chronic workforce shortages. Navigating this reality requires a clear understanding of the forces at play.

To help you lead with confidence, Social Current’s latest report highlights the key trends that our subject matter experts and Knowledge and Insights Center staff are following closely in the third quarter of 2025:

Download the full trend report for insight and related Social Current solutions.

Specialized Research Tools for Human and Social Services

Social Current’s Knowledge and Insights Center offers a robust resources portal, which includes a digital clearinghouse library with over 20,000 records; aggregated research and business databases; diverse topic collections and library guides; original content summarizing complex information; and coaching that helps users maximize these resources.

As you plan for 2025 and beyond, make sure you’re utilizing all the tools in your toolbox. For more information about available tools and support, visit our website or contact the Knowledge and Insights Center.

Social Current has selected LifeWorks as the 2025 Innovative Impact Award winner for its Travis County Transformation Project. Based in Austin, LifeWorks serves youth and young families—many of whom have experienced homelessness—through its housing, mental health, education, and workforce services.

LifeWorks logo

The Travis County Transformation Project is a pre-arrest diversion program that deflects youth from juvenile justice into community-based respite services, case management, family counseling, and restorative healing circles to build well-being and prevent recidivism. The program is a partnership between LifeWorks, the Excellence Project, and the Travis County District Attorney’s Office. It specifically targets youth ages 15-16 who have been involved in physical conflict with caregivers, which is the most common reason youth end up in Travis County’s juvenile justice system.

Youth who agree to participate are never charged and do not touch any aspect of the traditional juvenile justice system. Instead, youth and their caregivers participate in holistic supportive services that help resolve underlying stressors that contribute to conflict, including housing instability and food insecurity, while building healthy conflict resolution skills and connecting to a broader network of community support.

“I am thrilled to recognize LifeWorks for their innovative efforts to provide community-based support as an alternative to juvenile justice involvement,” says Jody Levison-Johnson, president and CEO of Social Current. “Their results are inspiring—a testament to holistic and asset-based approaches, as well as community collaboration.”

In the first 18 months of operation, the Transformation project achieved an impressive 94% reduction in recidivism (3% for project participants compared to 49% of youth receiving traditional juvenile justice interventions). This program is an innovative approach that has been designed in collaboration with impacted youth and families to address their self-determined needs and goals. It combines the local expertise of LifeWorks and the Excellence Project with best practices from other justice diversion programs and a youth-specific adaptation of the evidence-based Circles of Peace restorative justice model.

Through additional collaboration with evaluators at The University of Texas at Austin and New York University Center for Violence and Recovery, they are documenting and evaluating approaches and producing materials for replication. The Transformation Project is actively seeking to expand its reach locally and to encourage replication in other communities.

Learn More at SPARK 2025

LifeWorks will be recognized at the SPARK 2025 conference, Oct. 20-21 in Chicago, and staff will share their expertise in a workshop about the project. Join their session to hear from LifeWorks, the Excellence Project, and the Travis County District Attorney.

Child, Family, and Community Well-Being is an area of focus for SPARK 2025 workshops. Other sessions in this focus area address building continuums of care to help youth succeed, using data to drive positive service outcomes, and cost-effective strategies for evaluation studies.

Register for SPARK 2025 by Sept. 20 to receive the early bird rate.

Through COA Accreditation, a service of Social Current, we seek to empower organizations to implement best practice standards to improve service delivery and achieve better outcomes for individuals and communities. COA Accreditation provides a framework to help organizations manage resources, incorporate best practices, and strive for continuous improvement.

We believe there is rich expertise in our field, so we ground the COA Accreditation process in our human and social services community. Our volunteer peer reviewers conduct our site visits and finalize accreditation decisions.

We are proud to spotlight the latest Volunteer of the Quarter: Lori Welcher-Miles.

About Lori Welcher-Miles

Lori Welcher-Miles is a dedicated public servant and retiree of the Illinois Department of Children and Family Services (DCFS) with over 31 years of distinguished service. During her tenure, she held multiple leadership positions, including deputy director of Intact Services, overseeing operations across Cook County and the northern, central, and southern regions under the Bureau of Operations. She also served as regional administrator of Intact Services for Cook County and the northern region and as public service administrator (PSA) for the Agency Performance Teams (APT) for four years. In addition to her DCFS service, Lori worked part-time at Timberline Knolls Residential Treatment Center, supporting girls and women on their path to lasting recovery from eating disorders, mood disorders, trauma, and substance abuse. 
 
Since February 2000, Lori has held PSA roles encompassing broad administrative oversight, including: 

Lori holds a master’s in social work from Loyola University Chicago and a bachelor’s in criminal justice from Southern Illinois University Carbondale. Lori is a Licensed Social Worker (LSW), bringing professional expertise in social work to her roles. 

Q&A

Who is your role model and why? 

My mother has always been my greatest role model. She embodies strength, resilience, and compassion. Watching her navigate life’s challenges with grace and determination taught me the importance of hard work, integrity, and showing up for others no matter the circumstances. She didn’t just speak her values, she lived them daily, and that left a lasting impression on how I lead, serve, and carry myself personally and professionally. Her example continues to inspire me to lead with purpose and heart. 

What led you to become a COA Accreditation volunteer? 

My journey toward becoming a COA Accreditation peer reviewer began with the state agency where I worked. It underwent the accreditation process multiple times, and I was always invited to participate in the interview portion, which gave me a firsthand look at how COA Accreditation promotes accountability, quality improvement, and best practices across human services. That experience sparked a genuine interest in the accreditation process and its impact on service delivery. Shortly after, my manager encouraged me to consider becoming a peer reviewer. I applied in 2008 and have had the privilege of volunteering with Social Current and contributing to a mission I deeply believe in and learning from diverse agencies across the country.  

What are your strongest beliefs about the value of accreditation? 

I strongly believe that accreditation is a powerful tool for continuous improvement, accountability, and service excellence. It creates a structured framework that helps organizations reflect on their practices, identify gaps and build on their strengths. I also believe that ensures agencies not only meet minimum standards but strive to exceed them in ways that truly benefit the individuals and communities they serve.  

What excites, surprises, and/or challenges you the most about the work you do as a COA Accreditation volunteer? 

What excites me the most about being a COA Accreditation peer reviewer is the opportunity to engage with a wide variety of agencies, each of which has its own unique mission, culture, and approach to service delivery. What often surprises me is how open and transparent agencies are during the review process. The most challenging aspect is that each agency operates within different resources and policies, so its important to approach each review with empathy, fairness, and critical thinking. 

Share a memorable place, person, or experience from a site visit. 

One of my most memorable site visits was to Monterey, California, where I had the pleasure of working alongside two seasoned peer reviewers. They were incredibly down to earth, kind, and full of wisdom. After a full day of meaningful work, we took a walk along the beach and ended our evening with dinner on a heated patio overlooking the water. The scenery was breathtaking, and the conversation was genuine. 

What advice would you give someone interested in being a COA Accreditation volunteer? 

My advice is to approach the role with an open mind, a willingness to learn, and a genuine commitment to quality in human services. I would also encourage them to really lean into the learning process because you will gain just as much as you give—new perspectives, professional insights, and lasting connections with passionate mission-driven peers. 

Learn more about how to become a peer review volunteer and apply online.

H.R. 1 is expected to have profound and lasting effects on the social service sector. Among the most consequential changes are deep funding cuts to Medicaid, along with new, burdensome requirements that make it more difficult for people to enroll, re-enroll, and maintain coverage. According to an analysis from the Congressional Budget Office, these changes are projected to result in the loss of Medicaid coverage for 16 million individuals by 2034. 

The bill also imposes new eligibility requirements for the Supplemental Nutrition Assistance Program (SNAP) and ties state funding to administrative error rates, which is expected to further restrict access. Information from the Congressional Budget Office estimates 3 million individuals will lose access to SNAP as a result. 

Medicaid and SNAP are foundational to our nation’s safety net, protecting the health and well-being of millions. Reduced funding and access will directly harm individuals and families, while placing an unsustainable burden on the social service organizations that support them. 

For further information, Social Current has published a brief overview, highlighting the most impactful provisions of the bill; a detailed summary, which details expected impacts to the sector; and the recording of the July 10 webinar about the bill. 

Loans Enrolled in the SAVE Plan Will Begin Accruing Interest Aug. 1 

The U.S. Department of Education recently announced that interest accrual for borrowers with loans in the Saving on a Valuable Education (SAVE) Plan will restart August 1. 

The Department announced that it will begin direct outreach July 10 to the nearly 7.7 million borrowers enrolled in the SAVE Plan, with instructions on how to move to a legal repayment plan and begin making qualifying payments. 

The announcement arrives as student loan policies are expected to change rapidly due to H.R. 1, the federal budget bill. H.R. 1 phases out Pay as You Earn (PAYE), Saving on a Valuable Education (SAVE), and the Income-Contingent Repayment (ICR) Plan. Borrowers will need to choose either the Repayment Assistance Plan, a new income-based plan, or the amended Income-Based Repayment Plan between July 2026 and July 2028.  

Social Current’s detailed summary of H.R. 1 offers key information regarding the Repayment Assistance Plan and the amended Income-Based Repayment Plan.

Expected Changes to Public Student Loan Forgiveness Eligibility 

The U.S. Department of Education recently concluded its negotiated rulemaking session to ensure employers involved with the Public Service Loan Forgiveness Program are not engaging in activities with a substantial illegal purpose. 

The Department made 15 substantive changes to the regulatory language according to feedback from the committee. Although the Department has not publicly released the changes, it will now draft a Notice of Proposed Rulemaking in the Federal Register for public comment, which is expected to be released before November 1. 

HHS and the Department of Agriculture Amend Program Eligibility for Immigrants Lacking Permanent Legal Status

The U.S. Department of Health and Human Services rescinded a 1998 interpretation of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA). 

The Department claimed the act improperly allowed immigrants lacking permanent legal status to access certain social service programs. HHS’ revised policy will take effect immediately upon publication in the Federal Register.  

Key programs that will be formally classified as federal public benefits and have restricted eligibility include:

The Department of Health and Human Services has published a complete list of programs. 

The departments of Education and Labor have issued similar notices.

Similarly, the Department of Agriculture released the following programs to be formally classified as federal public benefits and restrict eligibility: 

ACF Opens State Applications for Redesigned Welfare Pilot Programs 

The Administration for Children and Families released a request for applications for the Temporary Assistance for Needy Families pilot.  

The pilot will choose up to five states to test innovative approaches aimed at promoting work and reducing government dependency. According to ACF, the redesigned pilot reflects the Trump Administration’s commitment to “reshaping welfare programs to encourage employment, personal responsibility, and strong families.”  

The application will allow states to propose alternative performance measures that prioritize employment outcomes, earnings progression, and reduced reliance on Temporary Assistance for Needy Families (TANF), Medicaid, and Supplemental Nutrition Assistance Program (SNAP) benefits — rather than the current work participation rates. 

The pilot program will operate for six years, with the first year dedicated to establishing baseline data and negotiating performance targets. Applications are due August 15, 2025. The pilot program for the selected states will begin on October 1, 2025.   

Children’s Bureau Issues Updated Guidance 

The Children’s Bureau stressed the importance of complying with the executive order, Ending Illegal Discrimination and Restoring Merit-based Opportunity, through recently issued guidance. The Bureau strongly encouraged all recipients of entitlement or formula awards funded by titles IV-B or IV-E of the Social Security Act or the Child Abuse Prevention and Treatment Act to review all plans, services, strategies, and expenditures under these programs, including those made by subrecipients or contractors, to ensure that they do not support diversity, equity, and inclusion initiatives or any other initiatives that discriminate on the basis of race, color, religion, sex, national origin, or another protected characteristic. 

Senate Agriculture Committee Approves Appropriations Bill

On July 10, the Senate Agriculture Committee unanimously passed its agriculture appropriations bill, the Fiscal Year 2026 Agriculture, Rural Development, Food and Drug Administration (FDA), and Related Agencies Appropriations Act. The bill contains notable changes from the previously passed House version, increasing funding for the Women, Infants, and Children (WIC) Program by $603 million and the Commodity Supplemental Food Program (CSFP) by $36 million. It maintains the full Cash Value Benefit for fruits and vegetables. The bill also fully funds all mandatory nutrition programs for fiscal year 2026, including SNAP, School Lunch Program, School Breakfast Program, and Summer EBT.

The Senate Agriculture Committee also allocated $1.715 billion for rental assistance, an increase of $73 million over fiscal year 2025. It also continues rural housing preservation efforts, including the decoupling pilot program, multifamily housing technical assistance, and preservation financing.

For further information, Vice Chair Patty Murray (D-Wash.) issued a summary of key provisions within the bill.

Sector Updates from the Judiciary 

Supreme Court Upholds Agency Workforce Reductions 

The Supreme Court lifted a lower-court order that temporarily prevented the Trump Administration from laying off tens of thousands of federal workers.  

The nation’s largest union of federal workers, the American Federation of Government Employees, filed the lawsuit alongside 11 nonprofit organizations and 6 local governments. 

The plaintiffs alleged that in issuing the executive order, Implementing the President’s “Department of Government Efficiency” Workforce Optimization Initiative, the Trump administration circumvented congressional approval for its reorganization plans.  

Solicitor General Sauer claimed that the president does not require special permission from Congress to exercise the essential presidential power of overseeing federal agencies. He additionally highlighted the directive to agencies to ensure that they do not eliminate any of the functions that statutes passed by Congress require.  

In issuing their verdict, the justices determined that the administration is allowed to launch reorganizations as litigation continues. However, they maintained that the ruling does not speak to the legality of any agency plans for restructuring or shrinking the workforce.  

Affected agencies include, but are not limited to, the Departments of Agriculture, Energy, Health and Human Services, and Veterans Affairs, as well as the IRS, Small Business Administration, and Environmental Protection Agency.   

The district court will now determine the legality of the layoffs. 

The decision follows the United States District Court of the Northern District of California’s verdict, temporarily preventing the reductions in force from occurring. US District Judge Illston maintained agencies would not be able to perform the tasks mandated by Congress if the reductions in force continued. 

The decision also arrived shortly after a US District Court for the District of Rhode Island stopped mass firings and restructuring at the US Department of Health and Human Services from proceeding. Judge DuBose determined the proposed cuts violate the Administrative Procedure Act as they are arbitrary, capricious, and unsupported by the evidence. The court also upheld the irreparable harm the plaintiffs are expected to experience as they will not be able to continue offering federally funded health programs. The order paused 40 reduction in force actions underway at 17 agencies. 

Federal Court Upholds Birthright Citizenship  

The U.S. District Court for the District of New Hampshire blocked the enforcement of an executive order prohibiting birthright citizenship. Judge LaPlante issued a preliminary injunction nationwide and certified a class action lawsuit, including all children who will be affected. 

The executive order limits birthright citizenship to individuals with at least one parent who is a U.S. citizen or permanent resident. The order also denies citizenship to children whose mothers are temporarily in the U.S., including those visiting under the Visa Waiver Program or as tourists. Students and individuals whose fathers are not citizens or lawful permanent residents would be excluded as well.

HHS Ordered to Restore Data Removed Due to “Gender Ideology” Executive Order 

The U.S. District Court for the District of Columbia ordered the Department of Health and Human Services to restore webpages and datasets that were removed in response to the executive order, Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government. 

Doctors for America filed the lawsuit, maintaining that providers relied on the data and websites to perform routine patient care tasks. They highlighted the expanse of data removed, including information about prescribing HIV medication and contraception and caring for patients with opioid dependency. 

Doctors for America alleged that, in removing essential documents, the government had failed to provide adequate reason or notice. Judge Bates affirmed the decision to remove documents failed to consider the impact on physicians and neglected to follow the procedures that Congress has prescribed, ordering the data be restored. 

Federal Court Upholds DOGE’s Access to Labor and Health and Human Services Data 

The U.S. District Court for the District of Columbia permitted the Department of Government Efficiency (DOGE) to retain access to computer systems and data at the Labor and Health and Human Services Departments. 

Unions and nonprofits previously issued a lawsuit due to DOGE’s lack of legal authority in accessing the data and their violation of the Administrative Procedure Act. However, Judge Bates determined that the plaintiffs failed to show the required harm for a preliminary injunction. The court cited a lack of evidence that personnel will imminently misuse or publicly disclose sensitive information. 

Litigation on Our Radar 

IRS Seeks Non-Enforcement of the Johnson Amendment 

The IRS recently responded to a lawsuit filed by two Texas churches and an association of Christian broadcasters that sought a broad exemption to the Johnson Amendment. The plaintiffs requested that they would be able to endorse candidates to their members while maintaining their tax exempt status, maintaining that nonprofit nonpartisanship violates the First Amendment right to free speech.

If successful, the request would overrule a longstanding protection for nonprofits. The Johnson Amendment states that charitable nonprofits, foundations, and religious organizations that maintain a 501(c)(3) status may “not participate in, or intervene in (including the publishing or distributing of statements), any political campaign on behalf of (or in opposition to) any candidate for public office.” 

In response to the lawsuit, the IRS wrote that if a house of worship endorsed a candidate to its congregants, the IRS would view that not as campaigning but as a private matter. The IRS and the plaintiffs asked the federal judge to stop the Johnson Amendment from being enforced against the parties filing the lawsuit.

The IRS’ statement signals a dangerous precedent. If the Johnson Amendment is not fully enforced, its legal and cultural authority could erode—along with the nonpartisan foundation of our sector. While the case centers on religious organizations, the implications may extend far beyond houses of worship. Weakening the Amendment could open the door to widespread politicization of nonprofit work. 

Social Current remains resolute in advocating for the full enforcement of the Johnson Amendment. For further information, we have recently issued a statement, stressing the amendment’s importance for the nonprofit sector and warning of the harm a weakened version would have.

16 States File a Lawsuit to Restore Mental Health Grants 

A coalition of 16 states filed a lawsuit against the Department of Education after approximately $1 billion in federal mental health funding was abruptly discontinued. 

The withdrawal of funds is expected to cause the dismissal of school-based mental health employees, defund scholarships for college students preparing to serve as mental health professionals in K-12 schools, and eliminate critical mental health services offered by schools. 

The state attorneys general argue that discontinuing the multi-year grants violates federal law and regulations. They are requesting that the funding be restored immediately. 

Cities Challenge CMS Rule Expected to Significantly Reduce Coverage  

The cities of Baltimore, Chicago and Columbus, Ohio, along with a coalition of health care professionals and small businesses, filed a lawsuit against the recently issued Patient Protection and Affordable Care Act; Marketplace Integrity and Affordability Final Rule. 

The rule is intended to address waste, fraud, and abuse in the Patient Protection and Affordable Care Act (ACA) eligibility and enrollment systems alongside rising “improper enrollment and health care costs,” according to CMS. HHS maintains the rule closes loopholes, strengthens oversight, and ensures taxpayer subsidies go to individuals who are truly eligible. 

The lawsuit stresses the barriers the rule would create in accessing affordable insurance coverage, leading to an increased population of underinsured and uninsured Americans. The plaintiffs cite the harm expected to follow maximum annual cost-sharing limitations and stricter income-verification measures required by the rule. They also highlighted the hardships expected to follow the required premium increases for exchange plans, which would reach up to $714 per year for an average family, as well as the shortened enrollment period, which would be reduced by two weeks.

The plaintiffs warn that the rule will cause at least 1.8M Americans to lose ACA coverage and result in higher premiums and out-of-pocket costs. 

The plaintiffs are requesting that the rule be blocked before it takes effect on August 25 due to its violation of the Administrative Procedure Act. 

Subscribe to the Policy and Advocacy Radar to receive our biweekly policy roundup, which includes commentary on issues in Social Current’s federal policy agenda, opportunities to take action, and curated news and opportunities.