Why Emergency Leaders Must Prepare for ICE Presence in Shelters and Medical Facilities

As the new federal administration doubles down on immigration enforcement, emergency managers and healthcare leaders face a critical - and largely overlooked - gap in preparedness planning: how to handle the presence of U.S. Immigration and Customs Enforcement (ICE) in emergency shelters and medical facilities. This is no longer a hypothetical issue. Across the country, ICE operations are becoming more aggressive, including detentions in and around public spaces. Hospitals, clinics, and shelters - especially those activated during disasters - are increasingly vulnerable to enforcement activity. And regardless of how you feel about immigration enforcement, this will disrupt your response. It will slow operations, break trust, and create public health risks. If you're responsible for continuity of care, safety, and community coordination during an emergency, you need to be ready.

4/9/20255 min read

Why This Matters Now

Disasters don’t discriminate by immigration status. When wildfires tear through neighborhoods or hurricanes force evacuations, entire communities are displaced. Emergency shelters become essential infrastructure. Hospitals and clinics are the frontline for trauma care, chronic disease management, and life-saving interventions.

But when people fear that walking into a shelter or clinic might lead to detention or deportation, they stay away. That fear - fueled by both experience and policy changes - leads to avoidable deaths, worsening public health outcomes, and disrupted disaster response.

These disruptions don’t just affect individuals with uncertain immigration status. They slow down response times for everyone, clog emergency departments with preventable complications, and introduce chaos into systems that depend on precision and coordination. When trust in the safety of essential services collapses, the entire public health apparatus suffers.

This issue also speaks to broader challenges around equitable access. If response leaders fail to account for the legal and social dynamics affecting immigrant populations, they risk leaving behind entire segments of the community during a crisis. That is not just unethical - it’s operationally reckless.

Legal Protections Are Not Enough

ICE’s own guidance identifies certain “sensitive locations” where enforcement actions are supposed to be avoided - places like hospitals, schools, and churches. But this guidance is just that: a non-binding policy, not a legal protection. It can be suspended, rewritten, or ignored, and it has been under past administrations.

Additionally, many community members are unaware of the nuances in ICE policy. To them, a visible ICE presence anywhere near a shelter or clinic is reason enough to stay away. Even rumors or social media misinformation about a potential raid can deter hundreds of people from accessing help during an emergency.

Facilities often assume that existing policies will offer protection, only to find themselves reacting to rapidly evolving enforcement tactics without a clear plan. Without pre-established protocols and legal guidance, institutions are left exposed - both legally and ethically.

What Happens If We Don’t Plan for This?

It’s a mistake to think immigration enforcement inside medical facilities or shelters only affects immigrant communities. In a crisis, the consequences ripple far and wide:

1. Delayed or Avoided Care = Bigger Public Health Risks

People avoiding medical care out of fear isn’t just a humanitarian issue - it’s a public health risk. Contagious illnesses go untreated. Chronic conditions worsen. That doesn’t stay isolated in one community. It spreads and becomes a broader health threat.

These delays also affect continuity of care. Patients with existing care plans may abandon treatment mid-stream. Children may miss vaccinations. Pregnant individuals may avoid prenatal care. Over time, this degrades population health and increases the burden on the healthcare system.

2. Slower Response, Broken Systems

ICE presence on-site means staff get pulled into legal questions they’re not trained to handle. Leaders scramble to call legal teams. Evacuees panic. Facilities may even pause services. During a wildfire, flood, or power outage, those lost minutes matter.

Operational chaos quickly becomes systemic failure. If you’re diverting staff to manage ICE interactions or manage community panic, you’re not directing resources where they’re needed. Those distractions can cost lives.

3. Erosion of Trust in Institutions

When clinics or shelters become seen as traps, trust vanishes - not just among immigrants but within entire neighborhoods. People stop engaging with public health. They avoid testing, vaccination, and emergency alerts. Misinformation spreads faster than your press release can catch up.

Once lost, trust takes years to rebuild. It doesn’t just affect emergency response - it affects every community health initiative that follows. That’s a price most public health systems can’t afford.

4. Overburdened Health Systems

When people wait until the last second to get care - or avoid it altogether - conditions get worse. That leads to emergency room surges, longer stays, and higher costs. In a disaster, it also means other patients wait longer or go without care.

Resource constraints become even tighter. If people avoid shelters, they may attempt to ride out storms in unsafe housing, leading to greater injury or death. These hidden emergencies complicate triage and strain already limited capacity.

5. Moral Injury and Legal Exposure for Staff

Frontline staff are not immigration officers. Being forced to act like they are - or to watch patients flee in fear - undermines morale and fuels burnout. Worse, sharing patient data without consent can violate HIPAA, putting the entire institution at legal risk.

Staff placed in these situations may feel powerless or complicit, leading to long-term moral injury. This compounds the workforce retention challenges already facing the healthcare and emergency management sectors.

Even if you support stronger border enforcement, doing it in the middle of disaster response is the wrong place, wrong time. The collateral damage is too high.

What Needs to Happen

Hospitals, clinics, and emergency management agencies must act now to develop and implement protocols that protect operations and uphold public health responsibilities:

Define Institutional Policy on ICE Interactions
Every facility should have a clear, written policy outlining when and how ICE agents are allowed to enter, who handles communication, and what staff should do if approached. Without this, confusion and mistakes are inevitable.
Train Your People
Emergency volunteers, nurses, shelter intake staff - everyone needs to know the policy. Not in theory, but in practice. Run simulations. Provide talking points. Have legal support ready. If staff aren't trained, the policy will fail.
Clarify Legal Boundaries
Consult legal counsel now. Most facilities can legally require ICE to present a signed judicial warrant before entering non-public areas. Staff need to understand the difference between administrative and judicial warrants - and how to respond to each.
Coordinate with Local Law Enforcement
If local police or sheriff’s departments are cooperating informally with ICE, it could undermine your response. Address these dynamics now, not during a disaster. Establish written agreements where possible and clarify jurisdictional boundaries.
Engage Community Partners
Immigrant-serving organizations understand community fears and can help design realistic, culturally competent response strategies. Bring them to the table early. These groups can also support communication efforts that restore trust and relay accurate information.
Include Legal and Language Access in Response Plans
Shelters and clinics should be equipped with legal aid referrals, translation services, and “know your rights” materials. These are not extra services - they are core to equitable emergency care. They also reduce liability and ensure compliance with language access laws.
Practice the Plan
Just like fire drills, exercises around ICE encounters should be part of your emergency preparedness routine. Include community partners, legal observers, and front-line staff in the planning process to identify real-world challenges and refine procedures.

Where to Find Resources

Several national and local organizations offer templates, trainings, and legal guidance:

National Immigration Law Center (NILC) - nilc.org
Sample policies and legal guidance for institutions.
Immigrant Legal Resource Center (ILRC) - ilrc.org
Trainings and templates for emergency response planning.
ACLU (State Chapters) - aclu.org
Constitutional rights guidance and legal assistance.
State and Regional Immigrant Justice Networks
Examples include California Immigrant Policy Center, NY Immigration Coalition, and Texas Civil Rights Project.
Medical-Legal Partnerships (MLPs)
Collaborations between healthcare providers and legal professionals that may support preparedness planning.
Local Sanctuary Policy Advocacy Groups
These groups often have toolkits and legal contacts who can help institutions build protocols and staff training curricula.

The Bottom Line

This is not about politics - it’s about protecting the ability to respond when lives are on the line.

Failing to plan for ICE presence in shelters and medical facilities will disrupt care, reduce access, burden your staff, and shake public trust. You don’t need to wait for your facility to become a test case. The time to act is now.

Emergency managers, hospital administrators, and public health leaders: write the policy, train your people, build partnerships, and prepare. Because when the next disaster hits, your job is to protect lives - not manage legal fallout in the middle of a crisis.