ADVOCACY & POLICY UPDATE - July 15, 2025

DOL Issues Guidance on Work Authorization Requirements

Washington Update

Rescissions Package

On Friday, July 11, the Senate began consideration of the White House’s $9.4 billion rescissions request, which seeks to cancel previously approved funding for public media and foreign aid. The measure has already passed the House in a narrow vote (214 to 212) and must be finalized by Friday, July 18, to meet the 45-day statutory deadline that temporarily freezes the targeted funds and faces notable resistance within the Senate Republican conference. Several GOP senators — including Susan Collins (ME), Lisa Murkowski (AK), Dan Sullivan (AK), Mike Rounds (SD), and Jerry Moran (KS) — have raised concerns and are seeking amendments to the proposal. A key issue for some lawmakers is the nearly $1.1 billion in cuts to the Corporation for Public Broadcasting, raising bipartisan concerns about its potential impact on over 1,500 local public radio and television stations, including services to rural and tribal communities. Despite ongoing inquiries, the White House has not provided clear assurances that funding for public broadcasting will be preserved. Senator Rounds has been in talks with the Office of Management and Budget (OMB) to secure protections for public media. He has indicated he will not support moving the package forward unless these concerns are resolved.

On Tuesday, July 8, Senate Democratic Leader Chuck Schumer (NY) cautioned in a “Dear Colleague" letter to fellow Democrats that the Republican-led effort to rescind funding for public broadcasting and foreign aid could undermine bipartisan cooperation on annual appropriations. He warned that advancing a partisan rescissions package after negotiating bipartisan spending bills that need 60 votes in the Senate would damage trust and disrupt the regular budget process and indicated that such an approach could jeopardize future negotiations on the 12 annual spending bills.

The rescissions process, which bypasses the Senate filibuster and requires only a simple majority, has rarely been used. If the Senate advances the measure, it will trigger extended debate and a series of amendment votes. The outcome remains uncertain, especially if senators modify the bill, which would require another House vote. President Trump has publicly urged GOP Senators to support the package, signaling potential political consequences for those who oppose it. Some Democrats view the effort as an attempt to undermine bipartisan spending agreements and weaken the role of the legislative branch in budget decisions. The administration has described this proposal as a potential model for future rescissions if Congress approves the current package.

Click here to access Schumer’s Dear Colleague letter.

Guidance on Work Participation Requirements

On Thursday, July 10, the U.S. Departments of Labor (DOL), Education, and Health and Human Services (HHS) issued coordinated guidance restricting access to a range of federally funded workforce, education, and health programs for undocumented immigrants. The new rules reinterpret longstanding policies to align with the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA), classifying many participant-level services as federal public benefits that require proof of legal work authorization.

The DOL Employment and Training Administration (ETA) issued the Training and Employment Guidance Letter (TEGL), Work Authorization Verification in Grant Programs Administered by the Employment and Training Administration, that reverses earlier guidance and mandates that all recipients of ETA funding verify participants' legal work status before delivering services. Programs affected include WIOA Adult, Youth, and Dislocated Worker programs, Wagner-Peyser, YouthBuild, Reentry Employment Opportunities, and the Senior Community Service Employment Program.

Similarly, the Department of Education rescinded Clinton-era guidance, now restricting access to federally funded postsecondary, career, and adult education programs, including those funded under the Perkins Act and the Adult Education and Family Literacy Act. The Department reaffirmed that Pell Grants and federal student loans remain unavailable to undocumented immigrants. HHS also announced parallel restrictions on programs such as Head Start, the Title IV-E Educational and Training Voucher Program, and the Title X Family Planning Program.

The administration says the changes are a move to protect taxpayer resources and ensure compliance with federal law. Advocacy organizations warned of negative impacts on vulnerable populations and questioned the legal basis and broader implications of the policy shift.

Click here to read a DOL press release and link to the full TEGL.

Click here to access the Department of Education full press release.

Click here to access the Department of Education full interpretive rule.

Click here to access the HHS press release and notice.

Head Start for Our Future Act

On Friday, July 11, Senators Kirsten Gillibrand (NY) and Susan Collins (ME) reintroduced the bipartisan legislation Head Start for Our Future Act, which would classify child development and early education roles as eligible community service positions under the Federal Work-Study program. The legislation aims to provide college students with hands-on experience in early childhood education while addressing workforce shortages in the field. Companion legislation has been introduced in the U.S. House of Representatives by Representatives Joaquin Castro (TX) and Juan Ciscomani (AZ).

Click here to read the full press release and access the full text of the legislation.

Job Corps

On Friday, July 11, the Trump administration asked a federal judge in Manhattan to significantly narrow an injunction that prevents the Department of Labor (DOL) from suspending operations at privately operated Job Corps centers. The administration argued that the current order violates a recent Supreme Court decision restricting the use of broad, nationwide injunctions. In late June, the judge blocked the DOL’s plan to indefinitely close all privately run Job Corps centers, though the ruling did not affect those managed by the U.S. Forest Service. Afterward, the judge requested additional legal briefs to determine whether his order should be modified in light of the Supreme Court’s ruling in Trump v. Casa. Administration attorneys asserted that the injunction should be limited to the approximately 30 centers associated with the plaintiffs in the case, rather than covering all 99 centers targeted by the policy. The plaintiffs maintain that the Supreme Court’s decision does not apply in this instance and that the broader injunction should remain in effect.

Federal Workforce

Last week, the Trump administration moved forward with a broad restructuring of the federal workforce with the President extending a federal civilian hiring freeze for another three-months and a Supreme Court ruling allowing planned job reductions to proceed. 

On Monday, July 7, President Trump extended the hiring freeze, first implemented on January 20, through the beginning of FY26. It halts hiring for new and vacated positions across federal agencies, with exemptions for roles tied to immigration enforcement, national security, public safety, and critical functions such as Social Security, Medicare, and veterans’ services. Political appointees and certain non-career senior executives remain exempt as well. Unlike prior iterations, the latest order does not reference the Internal Revenue Service, despite an earlier indefinite freeze on the agency. The Department of Defense continues to operate under a separate partial hiring freeze. The order also maintains a ban on outsourcing to circumvent the freeze and calls for alignment with the administration’s merit-based hiring framework. The Office of Personnel Management has advised agencies to scale back one controversial requirement – mandating applicants to describe how they would support administration priorities.

On Tuesday, July 8, the Supreme Court lifted lower court injunctions that had temporarily blocked related efforts to reduce the federal workforce. In an unsigned opinion, the justices allowed the administration to move forward with an executive order and directive instructing agencies to undertake job cuts, though no specific positions were under review. Justice Ketanji Brown Jackson was the only dissenting vote.

The hiring freeze extension and Supreme Court decision reinforce the administration’s broader goal of reshaping the federal government. 

Senior Community Service Employment Program (SCSEP)

On Thursday, July 10, Vermont’s congressional delegation sent a letter to U.S. Secretary of Labor (DOL) Lori Chavez-DeRemer that urged her to reinstate $300 million in funding for the Senior Community Service Employment Program, which supports job training for low-income older adults. In the letter, the lawmakers cited the impact in Vermont, where more than 50 seniors have been furloughed due to the funding pause, resulting in lost wages and disrupted training. DOL is reviewing the letter but has not issued a response.

Click here to access the full letter.