How ICE Is Using Medicaid Data to Find Immigrants and What It Means for Immigration Enforcement and Community Trust
This week, a federal judge’s ruling has cleared the way for U.S. Immigration and Customs Enforcement (ICE) to access limited Medicaid data to aid interior immigration enforcement, a policy shift with serious privacy and public-health implications. This development represents a significant expansion of the data tools available to immigration authorities and comes amid broader efforts to ramp up enforcement inside U.S. communities.
The New Enforcement Tool: Medicaid Data
In early January 2026, a federal judge allowed ICE to resume using certain Medicaid data to locate individuals suspected of living in the U.S. without legal status. Under the order, the Centers for Medicare and Medicaid Services (CMS) may share biographical and contact information, such as addresses, phone numbers, dates of birth, Medicaid IDs, and immigration or citizenship status, with ICE for enforcement purposes. Health records and sensitive medical details remain legally protected and excluded from the data sharing.
While Medicaid eligibility generally excludes undocumented immigrants, some states provide coverage regardless of immigration status or through emergency care programs. That enrollment information creates a potential lead for immigration enforcement officials seeking to locate people in removal proceedings.
Policy Reversal and Legal Battles
This change marks a stark reversal of longstanding CMS assurances that Medicaid data would not be used for immigration enforcement. Previously, federal policy maintained that information collected to determine eligibility for health coverage programs would not be shared with immigration authorities.
In 2025, more than 20 states sued the federal government, arguing that sharing Medicaid data violated privacy laws and deterred people from seeking medical care. Earlier court rulings temporarily blocked data sharing, but the latest decision permits limited access to basic demographic and contact data while litigation continues.
Advocates warn that even limited access to Medicaid enrollment information could have a chilling effect on public health. Immigrant families, and even U.S. citizens in mixed-status households, may delay or avoid seeking medical care out of fear that their personal information could be used in immigration enforcement. Such deterrence can undermine community health initiatives, public trust, and disease prevention efforts. Critics also raise concerns that using benefits data to target individuals for enforcement blurs the line between civil immigration enforcement and surveillance. Privacy laws, including the Privacy Act of 1974, require clear limitations on how personal data collected for one purpose may be used for another. Multiple attorneys general and civil rights groups assert that the data sharing could violate these safeguards.
Enforcement Strategy Evolution
This development reflects a broader shift in ICE enforcement tactics — moving beyond traditional reliance on local law enforcement or criminal records and toward data-driven targeting. Programs like ELITE and other analytics platforms have already drawn scrutiny for how administrative data is translated into enforcement leads without individualized probable cause. For attorneys and community advocates, the use of Medicaid data by ICE represents:
New hurdles in advising clients on how public benefit usage may intersect with enforcement risk.
Potential arguments in removal defense (e.g., data reliability, privacy violations, due process challenges).
Heightened client fear and mistrust of government programs, affecting outreach and intake.
It is essential for legal practitioners to stay current on how administrative data sources intersect with immigration enforcement strategies.
The court’s decision to allow ICE access to certain Medicaid data underscores a growing trend toward data-intensive immigration enforcement. While limited to basic biographical information, this policy shift raises deep privacy, public-health, and civil-liberties concerns. As litigation continues, the balance between enforcement objectives and constitutional safeguards will remain at the forefront of legal and policy debates.
If you or a loved one have concerns about how benefits data might be used in immigration enforcement, consult with an experienced immigration attorney. Protecting your legal rights and understanding how enforcement tools are evolving is more important now than ever.