A summary of the list of recommendations on the implementation of the OBBBA in Colorado regarding public benefits systems and work requirements.
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CCLP condemns slate of new directives from Trump administration agencies

Reversal of decades-old federal policy will deprive Coloradans of access to basic health care, nutrition, education, and more
DENVER, CO — July 11, 2025 — Yesterday, the U.S. Departments of Health and Human Services, Agriculture, Education, and Labor released a slate of coordinated policy changes purporting to immediately reverse decades of consistent policy and practice by clinics, schools, municipalities, and other entities that receive federal funding. These new policies are inhumane. They also violate principles of due process and fundamental fairness, both in substance and in the manner in which they were introduced.
For the one-quarter of Colorado farmworkers who lack documentation yet help put food on every American’s table, there would be nowhere to go for treatment for an injury, nowhere to vaccinate a child during a measles outbreak, and no access to a food bank or school meals. For families who have lived peacefully in Colorado for years, working and paying taxes alongside everyone else, there would be no access to Head Start, no behavioral health services, and no support for the well-being of their children.
Neither the President nor agency secretaries have the authority to unilaterally reverse the well-established interpretation of a 1996 federal law without Congressional or judicial action. Nor have any of these agencies even attempted to comply with the Administrative Procedure Act’s notice-and-comment requirements.
It has been clearly established in the courts that administrative agencies do not have the power to issue edicts in defiance of the law. As the Supreme Court held in Goldberg v. Kelly, the termination of essential benefits without due process violates the constitutional rights of those affected. Denying people access to life-sustaining services without notice, a fair hearing, or an opportunity to be heard is unlawful as well as unjust, particularly when done in a manner designed to evade public accountability.
Moreover, under the Supreme Court’s recent decision in Loper Bright Enterprises v. Raimondo, courts are no longer required to defer to agency interpretations of ambiguous laws. This means that the administration’s unilateral reinterpretation of federal statutes to strip long-established rights and benefits is not only cruel but lacks a lawful foundation, particularly when these agencies fail to provide any meaningful justification or valid legal basis for such sweeping reversals.
Policies that target immigrants and low-income communities are a hallmark of authoritarian rule. The same may be said of directives that ignore existing laws and constraints on power. If due process and the rule of law can be abandoned at the whim of those in power, they no longer serve as the foundation of our democracy. The erosion of rights harms all of us. And if we stand by while our neighbors are deliberately and systematically deprived of access to basic needs, there is little hope for stopping a descent into tyranny.
We urge Coloradans to stand together, rejecting these policies, and to demand the protection of due process, the rule of law, and our shared humanity.
(PDF version available here..)
About Colorado Center on Law and Policy
Founded in 1998, Colorado Center on Law and Policy is an antipoverty organization advancing the rights of every Coloradan through research, legal advocacy, legislative advocacy, and coalition building. Driven by our core values of equity, integrity, strategic advocacy, collaboration, and community engagement, CCLP envisions a Colorado where everyone has what they need to succeed. Learn more at copolicy.org.
