ローレンス・バーナリア氏、医療現場における移民法施行への配慮を強調

Foley & Lardner LLP partner Lawrence Vernaglia highlighted immigration enforcement considerations in health care settings in the Healthcare Risk Management article, “Immigration Enforcement Worries Healthcare Leaders.”

Vernaglia commented that health care facilities adhering to proper employment practices will not likely have employees targeted by U.S. Immigration and Customs Enforcement (ICE), though he noted that contractors, along with patients and visitors, may encounter enforcement actions.

He said that compliance with certain orders can come down to how a health care facility designates areas as either public or private space.

“For example, do you have a policy that lets any member of the public into your ER waiting room? Or is the policy such that only people who have a legitimate medical need to be there, either because they are seeking care or they’re accompanying someone who is?” he continued.

“Do the Girl Scouts get to sell Girl Scout cookies in there? Does the Salvation Army get to come in and ring the bell? Those are benign examples, but you wouldn’t want to have to be interpreting policies on the fly when law enforcement’s at the door,” Vernaglia added.