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Here’s How Public Hospitals and Clinics Will Respond to ICE

An all-staff memo was issued by NYC Health + Hospitals the same week federal agencies announced new directives to prosecute city workers interfering with Trump’s immigration enforcement directives.

Arianna Friedman

Jan 24, 2025

SHUTTERSTOCK

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NYC Health + Hospitals, which operates the 11 public hospitals and 70 patient care locations in New York City, issued an all-staff memo to their more than 43,000 employees in light of President Trump’s new immigration enforcement directives. The memo instructs workers to document and escalate ICE officer requests to managers, but stops short of instructing them to interfere with the agents’ activities. 

The agency has nearly 19,000 migrants and asylum seekers under its care, according to a City Council report from December 2024. The directive outlines a general process for NYC Health + Hospitals  (H+H) staff to gather initial information, including a signed judicial warrant, and then escalate the matter to an Immigration Liaison from the agency. This involves taking the officer’s name, badge number, and business card, and asking the officer why they need access and what information they are after. If the officer has documents on hand related to the visit, staff must make a copy and pass on all information to the Immigration Liaison, who then may connect to H+H’s General Counsel’s office. 

Also read: Trump’s Executive Orders Create a Hostile Environment for Immigrant Communities

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Unlike more strongly worded directives circulated within the city’s internal agencies, which went as far as advising city employees to block access to any non-local law enforcement regardless of whether they have a judicial warrant, the H+H directive notes “if the officer wants to talk to your H+H Immigration Liaison directly, you should let the officer,” emphasizing to never engage in a physical or verbal altercation with any law enforcement officer. Bolded at the end, the document reminds staff, “it is illegal to intentionally protect a person who is in the United States unlawfully from detention.” If workers feel threatened by physical violence by ICE agents, H+H recommends its workers letting them inside the facility and documenting the interaction. 

On Tuesday, the U.S. Department of Homeland Security rolled back restrictions that limited U.S. Immigration and Customs Enforcement (ICE) agents’ ability to make arrests around houses of worship, schools, hospitals, locations offering disaster or emergency relief, and other “sensitive locations.” By Wednesday, the Justice Department said it will prosecute state and local officials that resist, obstruct, or otherwise fail to comply with Trump’s mission to detain and deport undocumented immigrants. 

H+H is the largest municipal health care delivery system in the U.S. As bound by the federal Health Insurance Portability and Accountability Act (HIPAA), there are already strict regulations on how healthcare providers and other covered entities can disclose patient data, which includes immigration status, without patient consent. Since the presidential election, Health + Hospitals’ Humanitarian Emergency Response and Relief Centers (HERRCs) for asylum seekers have implemented additional measures to encrypt personal information for the nearly 19,000 asylum seekers receiving shelter services under their care.

The new response protocol applies to in-person officer requests for information or access to non-public areas of the workplace to conduct immigration enforcement. According to the official procedure obtained by Documented, “in a clinical setting, ‘non-public areas’ would include exam rooms, patient floors, operating rooms and administrative offices; public areas would generally include the lobby.”

While there haven’t been any reports of ICE agents onsite in the NYC shelters as of time of publication, staff are moving forward with the assumption that it is a matter of when, not if. One employee predicts that action may turn out to be limited, with only a couple of officers asking to enter the premises. “In my past jobs we dealt with a lot of law enforcement, [knew] what they can and cannot do, [and] what we should and should not say. It’s pretty much the same when it comes to any law enforcement, including ICE. I don’t think [the ICE raids] will be nearly as big as the news makes it out to be,”  they said. All current employees who spoke to Documented requested anonymity as they weren’t authorized to speak to the press. 

Also read: What Does Trump’s National Emergency Mean for the US-Mexico Border?

In recent years, ICE activity in New York included reports of ICE agents using mobile fingerprint devices, holstering guns, and teams of agents claiming to be police to make arrests while wearing plain-clothes and vests labeled POLICE, not ICE. The Immigration Defense Project also reported an increase in collateral arrests, in which ICE agents did not find the individual they pre-identified for arrest but instead arrested multiple people who were present. 

This past Wednesday, Fox News was given exclusive access to ride along with a team of ICE officers wearing vests marked POLICE as they went door-to-door in East Boston neighborhoods known for their migrant communities. ICE agents later reported arresting alleged gang members and suspects of violent crimes on their “target sheet,” with at least one collateral arrest. The following day in Newark, New Jersey, officers raided a local establishment without a warrant and detained a U.S. military veteran. Experts warn these are not isolated events, and both advocates and citizens should anticipate the continuation of these practices as federal officers intensify operations in sanctuary cities nationwide.

In recent weeks, shelters have seen a surge in residents seeking help with job applications and resumes, with 5-10 people a day asking for support in some shelters. “People are seeing the reality of things, they want to get the help that they need,” a caseworker at a family shelter said. However, she notes she’s seeing that women are having more difficulty finding jobs because they struggle to find childcare. While New York City’s Human Resources Administration offers some childcare services accessible to asylum seekers, staff note that clients have varying experiences accessing services.

Staff also noticed an uptick in Reconnection requests, in which staff book tickets for individuals and their families at no cost to them to leave to other cities,  thus ending their shelter stay. This is a marked shift from a handful of requests every couple of weeks to a few everyday. “Even among guests with medical conditions, guests are leaving on their own,” said one supervisor. “They will say, ‘I’m leaving, what do I need to do?’” While some residents are being transferred to other locations as the shelter system consolidates, staff report that many asylum seekers, including those with medical conditions, are making significant efforts to find housing outside of the shelters. “It’s the new normal now.”

Between unexpected visits from ICE officers and upcoming shelter closures, both employees and residents are on edge and have braced themselves for outcomes that are beyond their control.  “We want to hope for the best but expect the worst. But we don’t have clear answers ourselves,” one employee mused. “Those that felt like they haven’t moved through the process enough accepted their fate. And those who already have their social security and everything don’t expect to leave — they have to get to work.”

Arianna Friedman

Arianna Friedman holds a dual master’s degree in International Affairs and Public Policy from Columbia University and the Hertie School of Governance. She managed operations at migrant shelters in New York City, leading efforts to improve service delivery and directly supporting thousands of asylum seekers. Previously, she worked on communications for organizations focused on the future of cities, including New York-based architecture and urban development firms and the United Nations Development Programme Istanbul Regional Hub. Passionate about bridging humanitarian and development gaps, Arianna works to address the root causes of forced migration and foster social integration by aligning immediate relief efforts and long-term development strategies.

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