Co-Opting Compliance

The views expressed are those of the author and do not necessarily reflect the views of ASPA as an organization.

By Parisa Vinzant
March 6, 2026

At a California state health agency, employees and human resources are at odds over new compliance requirements that could reshape public servants’ ties to their jobs and communities.

The California Department of Public Health (CDPH) recently requested that 4,000 employees re-verify employment eligibility through the E-Verify+ platform. CDPH human resources said this step was needed to maintain California’s access to the National Death Index, a key health database. Without it, access to major health studies and cancer and chronic disease surveillance would be at risk. Yet this new requirement reveals how federal compliance mandates can conflict with agency equity commitments and organizational trust.

At its core, this is a governance and administrative challenge with far-reaching implications, including preserving staff diversity and public trust as well as the credibility of public institutions themselves. It calls for leaders to reflect and then act: will they pursue equity, trust and mission effectiveness even when compliance tools threaten to sabotage these priorities?

E-Verify+ is an updated system that requires workers to create an online account with U.S. Citizenship and Immigration Services and upload documents for federal checks through Department of Homeland Security (DHS) databases. Unions and CDPH employees have identified specific concerns. These include privacy risks, possible data security issues and the need to re-verify workers who are already cleared to work. These concerns are worsened by public unease about increasing U.S. Immigration and Customs Enforcement (ICE) actions.

This conflict must be seen in context. According to 2024 data from the Public Policy Institute of California (PPIC), over 10 million immigrants live in the state. Of these, 28 percent are foreign-born. Among them, 54 percent are naturalized citizens. Additionally, 44 percent of California children have at least one immigrant parent.

CDPH’s workforce demographics are not publicly available. However, as state-employed public health workers, they likely follow 2024 sector trends. These include underrepresented Hispanics, overrepresented whites, overrepresented Asians (with exceptions when data is disaggregated) and more than 30 percent immigrant representation.

This data suggests that CDPH has a relatively diverse workforce, including immigrants. For many employees, such as green card holders, DACA recipients and those from mixed-status families, there are real and perceived risks to creating an employment account with a DHS agency. It connects their livelihoods to the wider immigration surveillance apparatus. When agencies require links to DHS for employment, fear can spread in the workplace, hurting relationships with the community and undermining both mission and trust.

Imagine the dilemma faced by a public health nurse from a mixed-status family who may think twice about taking or keeping a job if it requires a profile in DHS systems, even if they have full work authorization.

Susan Gooden’s 2014 book, Race and Social Equity: A Nervous Area of Government, provides a valuable lens to make sense of this complex situation. Gooden argues that race and inequity are a “nervous area” where administrators use neutral language instead of tackling policy-driven structural injustice. Gooden advises identifying injustices, diagnosing causes and taking concrete action. By applying this framework to the CDPH conflict, what can be revealed?

First, naming calls for clarity. Broad re-verification puts extra burdens on noncitizen and racialized staff. It ties their jobs directly to federal immigration databases, a connection not previously required for a job they already hold. This can chill the retention and recruitment of diverse public health workers, which is an issue California is already struggling with. It also undermines organizational effectiveness and mission alignment.

Second, a systemic diagnosis is needed. Federal rules place employment checks in DHS systems and tie funding to compliance, limiting local choices. Organizational leaders, however, do have discretion. They decide whether to require universal participation or use a narrower approach. They also choose whether to support vulnerable employees or leave them to navigate federal systems on their own.

Third, advancing equity means turning commitments into action. Even under federal mandates, agencies can clarify requirements, limit re-verification to what is strictly necessary and advocate for privacy protections and assistance for impacted employees. Leaders must assess how compliance tools affect diversity and organizational trust, linking equity principles to operational decisions.

Agencies need to connect internal decisions to their core missions. Equity commitments strengthen that trust, especially with immigrant and disadvantaged communities. If staff or communities see public service as associated with immigration enforcement, trust and effectiveness decline. Operational choices, after all, shape institutional legitimacy.

Workforce policy is being changed through the back door via conditions set on grants and data contracts, not through open debate or transparent rulemaking. Today, access to data sets is the pressure point. Tomorrow, they may be tied to other essential resources as federal expectations evolve. This shifting landscape calls for vigilance, resourcefulness and strategic action, along with aligned coalition-building.

A realistic way forward will require action beyond the limits of any single organization. Securing coalition support and visible backing from multi-agency working groups, union-management committees or state leadership is important. It helps strengthen agency leverage in talks with federal partners and in supporting the dignity and civil rights of their employees.

Within this backdrop of expanding coercive funding conditions and data requests, public servants will likely face similar federal demands. How agency leaders show up for their employees, and by extension their communities, at this consequential time matters.

Passive implementation of compliance measures that undermine equity and trust is still a choice. We must choose to actively champion justice and preserve the core missions of both the agency and public service itself.

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 Author: Parisa Vinzant, MPA, works as a private and public sector strategist. She served as a technology and innovation commissioner in Long Beach, CA. Parisa applies an intersectional equity lens in her writing on topics such as technology, ethics and democracy. Connect with her by email at [email protected] or on Bluesky @pvinzant.bsky.social. Signal contact by request.

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