As Surveillance of Immigrant Communities Expands, How Can Nonprofits Respond?

The Donald Trump administration has expanded the enforcement of immigration laws beyond government agencies traditionally responsible for that task, including the IRS, Medicaid, the Department of Education, and Housing and Urban Development (HUD). This move represents a profound shift in the state-level role at the local level, as institutions created to guarantee social rights are being transformed into instruments of surveillance.

Nonprofit organizations that defend immigrant rights must sustain the trust of immigrant communities while facing a national apparatus that has turned social agencies into tools of immigration control. On top of this, nonprofits must also contend with the Trump administration’s decision to rescind sanctuary space status—not only for courts, churches, and schools, but also for frontline community organizations that provide essential services and once held that protection.

“Although the context is different, many of the same patterns remain. By understanding the fears of our clients and of immigrants and refugees in the US, we’ve seen that many try to minimize being in public spaces or places they perceive as high risk. What is most troubling about this moment and the policies being implemented is that sensitive locations—churches, synagogues, courthouses, and nonprofit offices where immigrants once felt safe—are no longer safe for them,” Noah Gottschalk, chief external relations officer at HIAS, said to NPQ in an interview.

“The challenge and the mistrust are not directed at nonprofits, but at the system as a whole.”

This perspective is shared by Adriana Cadena, executive director of the Protecting Immigrant Families Coalition, who told NPQ that the long‑standing “protected areas” policy—keeping immigration enforcement away from schools, hospitals, churches, and other community spaces—had been essential to ensuring that people could meet their basic needs without fear.

“The administration’s decision to reverse that policy has weakened the country,” she said, “by discouraging both US citizens and immigrants from accessing essential services and exercising their fundamental civil rights.”

The Rollback of Protections

For decades, the Department of Homeland Security (DHS) instructed Immigration and Customs Enforcement (ICE) to avoid enforcement actions in designated “sensitive locations.”

In 2021, the Joe Biden administration broadened this protection to include schools of all levels, healthcare facilities, places of worship, playgrounds and bus stops, social service centers, such as shelters and food pantries, disaster response sites, ceremonies such as weddings and funerals, and public gatherings like parades or demonstrations.

The guidance also extended to surrounding areas—entrances, sidewalks, and parking lots—and added restrictions on enforcement in courthouses. The Trump administration has not clarified whether all of these memos were formally rescinded or if new guidance will be issued, but it has explicitly stated that ICE may now conduct enforcement in schools and churches.

“The challenge and the mistrust are not directed at nonprofits, but at the system as a whole. To help people feel safer, beyond offering virtual trainings, we’ve made sure to explain the protocols we follow for handling their information,” Gottschalk explained.

The IRS, for example, has shared taxpayer addresses with ICE, generating errors that have impacted thousands of citizens.

He pointed out that the immigrant community is increasingly relying not only on established nonprofits but also on more ad hoc mutual aid groups, informal networks that may not be formally registered as 501c3 organizations but still play a vital role in bridging gaps and building connections.

Claudia Werman Connor, US regional representative at Church World Service, told NPQ that the rollback of protections for sensitive locations represents one of the most significant enforcement shifts in recent years, turning schools, hospitals, places of worship, and service centers into potential enforcement zones.

“At the local level, we see that many of the people we serve are now afraid to come forward for services. The demand for immigration legal support has skyrocketed, while participation in food programs and other essential services has dropped because people fear showing up,” she explained.

Extensions of Power

The rollback of protections for sensitive locations reflects a broader pattern in the administration’s approach to immigration enforcement, one that extends beyond ICE operations and into the very institutions meant to safeguard social rights and the most vulnerable. The instrumentalization of these agencies affects not only undocumented immigrants but US citizens in mixed‑status families, who see their access to housing, health care, and education threatened. The IRS, for example, has shared taxpayer addresses with ICE, generating errors that affected thousands of citizens.

Medicaid has been pressured to reveal immigration status, leading families to avoid hospitals and medical services. The Department of Education investigates universities that grant scholarships to undocumented students, while HUD is advancing a regulation that would reform a decades‑old rule allowing ineligible individuals to reside with eligible family members receiving rental assistance. This change threatens to break apart households and leave thousands of US citizen children homeless.

The new HUD proposal represents a sharp departure from long‑standing housing policy. For decades, mixed‑status families—households with members both eligible and ineligible for citizenship—have been allowed to live together under prorated rental assistance, meaning subsidies are calculated only for those who qualified. For example, an undocumented grandparent can reside in a home with US citizen children who are eligible for support, with the benefit adjusted accordingly.

The National Association of Housing and Redevelopment Officials (NAHRO) said in a statement: “Evicting a mixed‑status family would not automatically create equivalent assistance for a new household. Instead, it forces families to choose between separation and homelessness.”

NAHRO, whose mission is to create and preserve affordable housing while supporting local agencies that administer programs fairly and efficiently, envisions “thriving communities with affordable homes for all.” According to NAHRO, the proposed HUD rule not only does not advance this vision, but it also casts a wide net that risks home stability of eligible US citizens, shifting the focus to immigration enforcement, and imposing additional costs on local governments that will likely outweigh any speculative savings.

“As a coalition, the big impact we’ve experienced has been borne by our 800-plus member organizations,” said Cadena of the Protecting Immigrant Families Coalition. “Our mission is improving access to health, food, and other basic needs programs for the 28 percent of America’s population living in immigrant families. There’s a certain level of trust required for any family to use health and social services, and the administration turning IRS, HUD, HHS, USDA, and other agencies into ICE surrogates has really undermined that basic trust.”

Erosions of Trust

The KFF/New York Times 2025 Survey of Immigrants, conducted between August 28 and October 20, 2025, and published on November 18, 2025, revealed the extent of fear among immigrant communities in the United States. Based on interviews with 1,805 immigrant adults, the survey found that 51 percent were “very” or “somewhat” worried that health officials or medical providers might share their information with immigration authorities such as ICE. This finding, reported by The New York Times and KFF, underscores how distrust of public institutions has become a structural barrier to healthcare access and safety for mixed‑status families.

“If there is permission to share data, that alone would already have huge impacts. Many immigrants would be afraid and would avoid using health care.”

Leonardo Cuello, a research professor at Georgetown University’s Center for Children and Families, explained to NPQ that historically there has been no mechanism through which Medicaid shares beneficiary information with ICE, since health data has always been protected for healthcare purposes only.

However, in 2025, the Trump administration announced that the Department of Health and Human Services (HHS) would begin sharing data with the DHS, which includes ICE. Cuello noted that this decision prompted a lawsuit filed by California and dozens of other states to block the data exchange between the two government agencies. As he clarified, Medicaid data flows from individuals to state programs, then to federal HHS, which now claims authority to share it with DHS. Currently, in the roughly 29 states not involved in the litigation, HHS can freely share data, while in the 22 states participating in the lawsuit, data sharing is limited by judicial restrictions.

“If data sharing occurs, care will be dramatically impacted. In fact, even if they didn’t actually share data, if there is permission to share data, that alone would already have huge impacts. Many immigrants would be afraid and would avoid using health care,” Cuello said.

The result is an erosion of trust. Families that once relied on public programs for stability now fear that the very institutions meant to protect them could expose them to deportation. This “chilling effect” is evident in hospitals where patients avoid emergency rooms, in schools where scholarships are questioned, and in housing where thousands of citizens risk losing their homes.

The Costs Nonprofits Pay

Given this context, nonprofit work must adapt to the realities on the ground. Werman Connor highlighted that her organization is increasingly mindful of the risks involved in using certain resources. She explained to NPQ that they are working to be more deliberate in the guidance they provide—both internally and externally—so that people clearly understand the potential risks and can make informed decisions.

“We’re doing everything we can to make access to accurate information as safe as possible, whether that’s through newspapers, churches, radio, and bringing services to people where they are, including for example meeting people in community centers, so they don’t have to risk coming to us directly,” she said.

Public perception in the United States toward immigration enforcement policies is increasingly critical. The survey published by the Protecting Immigrant Families (PIF) coalition reveals a striking fact: 83 percent of people in the US support allowing “lawfully present immigrants” to access health and social service programs. The finding reflects a broad consensus in a country marked by political polarization. According to the study, support extends across party lines—Democrats (92 percent), independents (84 percent), and Republicans (74 percent)—showing that the idea of guaranteeing basic needs transcends partisan divisions.

The survey also shows a majority reject the use of Medicaid data by ICE for deportations, along with widespread disapproval of how the agency is carrying out its work. In addition, most respondents oppose immigration enforcement operations in schools, hospitals, clinics, and social organizations—places historically considered safe spaces.

Nonprofit organizations face multiple needs in this environment, yet they all agree that their work remains fundamental. As Gottschalk of HIAS said, while public attention often shifts to other crises, “the attacks on immigrants, the attacks on American values…are still going on.” To sustain the nonprofit’s mission, he stressed the urgent need for volunteers, funding, and community support, noting that the Trump administration is “throwing everything at us,” and nonprofits must mobilize more people to fight back.

Werman Connor underscored the additional need for a more compassionate legal framework that allows nonprofits to meet people’s basic needs.

“We need more humane laws that enable us to deliver the services people depend on. Our ultimate goals are to alleviate suffering and advance justice—but when we’re constantly bombarded with shifting policies and funding landscapes that run counter to those goals, it becomes extremely hard,” she said.

Cadena added that “state and local governments play a crucial role in rebuilding trust among immigrant families,” since they are often responsible for administering basic needs programs such as health, housing, and food assistance. She emphasized to NPQ that local officials should take a stronger stand against federal abuses of power and violations of law and highlighted that collaboration between local agencies and community organizations is essential to identify families’ most urgent needs and design effective responses.