Attachment A - Public Comments and ORR Responses

Placement and Transfer of

Unaccompanied Alien Children

into ORR Care Provider Facilities

OMB Information Collection Request

0970 - 0554

Attachment A - Summary of Public Comments and ORR Responses

December 2020

Submitted By:

Office of Refugee Resettlement

Administration for Children and Families

U.S. Department of Health and Human Services

Some of the below responses reference ORR’s new case management system, UAC Path. ORR is in the process of developing the UAC Path system, which will be launched mid-2021. All of the instruments in this collection will be incorporated into UAC Path. Updated UAC Path versions of the instruments will be submitted to the Office of Management and Budget (OMB) for review and approval with any substantive changes to include a period for public comment.

Long Term Foster Care Placement Memo

1. One commenter recommends that the form include an area to document dates and notes regarding the transfer timeline.

ORR Response: The purpose of this instrument is to ensure that the long term foster care placement identified will meet the needs of the UAC. Details regarding the transfer, such as transfer dates, are documented in ORR’s Transfer Request form.

Transfer Request

1. One commenter recommends that additional fields be added to the form that capture other factors taken into consideration when recommending a transfer, such as potential legal relief; existing good faith letters; educational, medical, mental health, and behavioral needs; the UAC’s wishes; and any other consideration unique to the UAC’s case.

ORR Response: The instrument already contains areas in which care provider case managers may document information on health, behavior, family reunification, and immigration court relevant to the transfer request. In addition, the instrument contains a comment field in which case managers may add any other information they believe is relevant to the transfer request. -

UAC Portal Capacity Report

1. One commenter notes that the report is broken down by gender, which does not reflect the reality that, for some care providers, beds assigned to specific genders may shift depending upon the types of referrals received from ORR. The commenter also notes that the report appears to be created from the group/shelter care perspective and is not easy to use for foster care programs.

ORR Response: ORR understands that the gender assigned to a specific bed may shift. Both the current UAC Portal system and the new UAC Path system allow care providers to change the gender assigned to a bed in real time. The ORR Intakes Team also communicates directly with care providers regarding the shifting bed gender assignments, as needed. ORR will consider any feedback provided by its long term foster care providers for improvements to the UAC Path system’s bed capacity tracking after initial launch of the new system.