Navigating ICE Raids: How FQHCs Can Protect Patients and Staff

In this critical episode, Jill Steeley sits down with Steve Weinman, owner of FQHC Associates and veteran of 40 years in community health, to discuss one of the most pressing challenges facing health centers today: ICE raids and immigration enforcement. They explore the legal protections available to health centers, practical strategies for maintaining patient access, and how to balance mission with safety during uncertain times.

Guest: Steve Weinman, FQHC Associates

Key Topics Discussed

The Current Reality

• ICE arrests have increased by 1200% in some jurisdictions in 2025
• Over 460,000 arrests nationwide in 2024, with numbers rising significantly
• Fear spreading beyond raid locations—even communities that have never experienced ICE activity
• Patients no-showing appointments due to stay-home alerts on social media networks
• Impact on preventative care access, leading to more expensive emergency situations

Legal Protections and Rights

• HIPAA privacy rules remain unchanged—health centers cannot share patient information without judicial warrants
• Difference between administrative warrants (executive branch documents) and judicial warrants
• Constitutional rights against unlawful search and seizure still apply
• Health centers still have the charge to serve everyone, regardless of documentation status
• Public charge rules have not changed health centers' mission to serve all patients

Staff Protection and Training

• Importance of written policies kept at front desk workstations
• Role-playing and training for all staff, especially front desk personnel
• Clear liaison designation—front desk staff should immediately call management
• Defining public vs. non-public areas (waiting rooms vs. exam rooms)
• Locking back areas and requiring buzz-through access
• Documentation and surveillance cameras in public areas

Facility and Operational Considerations

• Minimizing "target rich environments"—avoiding lines of patients outside
• Strategic use of building entrances and parking areas
• Signage indicating restricted access (with legal guidance)
• Understanding and leveraging state and local protective laws
• Balancing federal funding requirements with patient protection

Key Timestamps

• [00:02:00] - Introduction to Steve Weinman and his background
• [00:03:00] - Steve's experience in Immokalee, Florida with farm worker population
• [00:05:00] - Current statistics on ICE arrests and their impact
• [00:07:00] - Public health implications of healthcare avoidance
• [00:10:00] - Misconceptions about serving undocumented patients
• [00:12:00] - HIPAA protections and warrant requirements
• [00:13:00] - Creating written policies and staff training protocols
• [00:16:00] - Data collection best practices during this time
• [00:19:00] - Community partnerships and legal organization connections
• [00:22:00] - Navigating political polarization within staff
• [00:24:00] - Expanding telehealth and remote services
• [00:27:00] - Mobile and outreach services strategies
• [00:28:00] - Hurricane Wilma story—building community trust
• [00:30:00] - Off-hours and weekend access expansion
• [00:35:00] - Balancing federal requirements with patient protection
• [00:38:00] - Messaging do's and don'ts for health centers
• [00:40:00] - Three action steps for CEOs this week
• [00:42:00] - Historical perspective and resilience of health center movement

Practical Action Steps for Health Centers

Immediate Actions (This Week)

1. Review and update policies for ICE encounters and enforcement response
2. Train all staff, including new hires, on protocols and their roles
3. Establish open communication with patients about their rights and safety

Policy Development

• Create written protocols for front desk encounters
• Designate management liaison for enforcement situations
• Define public vs. non-public areas clearly
• Implement locked access to exam/private areas
• Establish surveillance camera systems in public spaces
• Develop after-action report procedures

Expanding Access

• Telehealth services for medical, dental, and behavioral health
• Mobile and outreach units with recognizable, trusted branding
• Extended hours and weekend access to avoid daytime visibility
• Walk-in options for patients who can't commit to scheduled appointments
• Remote prescription refills and routine care management

Community Partnerships

• Connect with local legal services organizations (contract if possible)
• Partner with State Primary Care Association for training
• Collaborate with food banks and human service organizations
• Establish clear referral pathways between organizations
• Create joint strategies for remote/delivered services

Data and Privacy Protection

• Collect only HRSA-required data—nothing additional
• Minimize immigration status data collection
• Document all enforcement encounters thoroughly
• Review and strengthen HIPAA compliance procedures

Patient Communication

• Post "Know Your Rights" materials in clinics
• Mail postcards (not bill-like materials) explaining patient rights
• Use social media and community networks to share safety information
• Provide materials in multiple languages
• Emphasize health center's commitment to serving all patients

Messaging Do's and Don'ts

DON'T Say:

• "We oppose ICE or federal immigration policy"
• "We refuse to cooperate with federal law enforcement"
• Anything that takes a strong political position

DO Say:

• "We want to ensure all residents can safely access care regardless of their background"
• "We will follow the laws on privacy and access for all of our patients"
• "Our mission is to provide healthcare to everyone who needs it"
• Focus on health outcomes and community wellbeing

Key Takeaways

✓ Health centers must balance federal funding requirements with mission to serve all patients

✓ HIPAA protections remain in effect—know the difference between administrative and judicial warrants

✓ Front-line staff need clear protocols, training, and immediate management support

✓ Telehealth and mobile services are critical tools for maintaining access during this crisis

✓ Microbes don't discriminate—untreated illness in any population affects entire community

✓ The health center movement has survived many challenges and grown stronger

✓ Community partnerships with legal organizations are essential right now

✓ Avoid political messaging; focus on mission of providing healthcare

✓ Consider how your facility appears to enforcement—reduce visible congregation of patients

✓ New staff onboarding must include ICE policy training, not just annual training

Memorable Quotes

Steve Weinman:

"Microbes don't discriminate against people based on whether they're here legally or what they look like. They spread equally to everyone, and so it's a public health issue."

"The time to think about this is not when somebody shows up at your front door, potentially wearing a mask and putting a piece of paper in front of you."

"It's a big difference from 'we won't help you' and 'we can't help you.'"

"We have survived many attacks on the health center program and have not only survived, but we've gotten stronger."

Jill Steeley:

"It's not just in the communities where the raids are occurring—this fear factor spreads into communities where ICE raids have never really been a thing."

Resources Mentioned

Guest Resources:

• FQHC Associates: fqhcassociates.org
• CEO Connect Bootcamp (Jill Steeley & Steve Weinman partnership)

Legal and Support Resources:

• State Primary Care Associations (PCAs)
• National Immigration Legal Services Directory
• United We Dreams Deportation Defense Hotline www.unitedwedream.org. 
• Florida Rural Legal Services (example of local legal partnership)
• Montana Legal Services Association (example of contracted services)

Recommended Actions:

• Contact your state PCA for ICE encounter trainings
• Consult with immigration attorneys before enforcement encounters
• Review HRSA Section 330 requirements
• Check state and local laws regarding ICE cooperation

About the Guest