County advisers warn proposed federal rescissions and HHS notice could cut services and chill enrollment

Emily Bauke Da Silva of federal affairs firm CJ Lake told the Alameda County Personnel Administration & Legislation Committee that Congress and the administration are moving in ways that could reduce federal funding and complicate FY2026 appropriations. "The Senate is preparing to take up President Trump's proposed $9,400,000,000 rescissions package," Da Silva said, describing it as a plan to "claw back unspent funds from a range of programs" including global health and public broadcasting.

Why it matters: The committee heard that, if the rescissions package or additional rescissions pass, smaller discretionary programs would face cuts that make it harder for counties to rely on federal dollars in coming years. Da Silva said that even if the immediate rescissions package is modest, "it really does spell trouble for FY26 appropriations and cooperation with Democrats, particularly in the Senate," because appropriations timelines and floor time are constrained.

Da Silva also flagged a separate and immediate administrative change from the U.S. Department of Health and Human Services. "HHS put out a notice reinterpreting the Personal Responsibility and Work Opportunity Reconciliation Act," she said, explaining the reinterpretation could reclassify several programs — including SAMHSA block grants, Head Start, Title X family planning, community services block grants and health centers — as federal public benefits, which typically require recipients to be U.S. citizens or qualified immigrants.

On timing and process: A committee member asked if the HHS notice had been published in the Federal Register. Da Silva replied, "It was published, I believe, on Friday," and confirmed the notice was effective immediately while the agency concurrently opened a 30-day comment period. She and county staff said that creates uncertainty: the rule's publication could immediately alter practice or create a "chilling effect" that discourages eligible residents from applying for benefits even before guidance or litigation resolves the change.

What local officials asked: Supervisors pressed for clarification about when changes would take effect and how a compressed federal schedule might affect county budgets. Da Silva cautioned the committee that work requirements and narrower definitions of federal public benefits could reduce enrollment and federal reimbursements to states and counties, making planning for FY2026 more difficult.

What the committee will do next: County staff said they are monitoring the federal proceedings and the HHS comment process and will provide further guidance as agencies supply more detailed implementation instructions. The committee was told to expect more targeted analyses when House and Senate subcommittee actions and committee reports are released.

Ending: The committee received the federal update and had no public speakers on the item; staff will return with more detailed impact analyses as federal markups and administrative guidance evolve.