ICE Enforcement in Healthcare Settings: Legal and Operational Considerations After the Protected Areas Era

Business immigration attorneys Elvira Rodriguez and Hadeel Abouhasira wrote an article for the American Health Law Association (AHLA) about a change in the government's policy toward immigration enforcement activities in hospitals and healthcare facilities. In January 2025, the U.S. Department of Homeland Security (DHS) rescinded guidance that classified healthcare settings as "sensitive locations" or "protected areas" subject to limits on immigration-related actions; the withdrawal means DHS will now take a case-by-case approach to enforcement in these locations. Given that the healthcare industry traditionally employs a higher number of immigrant workers, hospital administrators, physician practice managers and employment professionals can expect an increase in workplace audits, U.S. Immigration and Customs Enforcement (ICE) raids and other check-ins to ensure compliance with U.S. immigration law and policy. In their article, Elvira and Hadeel describe what business leaders need to know about what the government can and cannot do following the guidance rescission and what steps employers should take to prepare for inquiries and document compliant procedures.

READ: ICE Enforcement in Healthcare Settings: Legal and Operational Considerations After the Protected Areas Era (AHLA membership required to view)