NonSub Change - Form P-5 July 2024

To: Kelsi Feltz

Office of Information and Regulatory Affairs (OIRA)

Office of Management and Budget (OMB)

From: Kristie Ross

Office of Refugee Resettlement (ORR)

Administration for Children and Families (ACF)

Date: July 29, 2024

Subject: Non-Substantive Change Request – Placement and Transfer of Unaccompanied Children into ORR Care Provider Facilities (OMB #0970-0554)

This memo requests approval of non-substantive changes to the approved information collection, Placement and Transfer of Unaccompanied Children into ORR Care Provider Facilities (OMB #0970-0554).

Background

The “Placement and Transfer of Unaccompanied Children into ORR Care Provider Facilities” information collection contains 20 instruments that allow ORR to place unaccompanied children referred to ORR by federal agencies into care provider facilities and to transfer children within the ORR care provider network as required by the Homeland Security Act (6 U.S.C. 279) and the Trafficking Victims Protection Reauthorization Act of 2008 (8 U.S.C. 1232). The collection was last approved by OMB on June 12, 2023, and expires on June 30, 2026.  

ORR is proposing revisions to one form in this collection, the Foster Care Placement Memo (Form P-5).

Care providers use the Foster Care Placement Memo (Form P-5) to ensure placement in a foster home that meets the child’s needs and continuity of services.  See UC Policy Guide Section 1.2.6 ORR Long Term Foster Care for related policies.

ORR has not yet been able to start using the currently approved version of Form P-5 due to an implementation delay of related foster care policy. The form contains elements related to the foster care policy revisions that are currently deliberative. ORR considered issuing a separate set of instructions to ignore elements of the form that cannot yet be implemented, but ultimately determined that this would be confusing for users. Instead, ORR is proposing revisions to Form P-5 that will remove elements specifically related to the as-of-yet unpublished policy guidance. ORR is also proposing additional revisions, unrelated to the unpublished policy guidance, that will improve the instrument’s clarity and effectiveness to better serve its purpose within the agency.

Once the new policy is ready for publication, ORR will submit a non-substantive request to reverse the currently requested revisions that are related to the policy. This process will ensure that the necessary adjustments are made in a timely manner to align with the updated policy guidance.

pROPOSED REVISIONS

Revisions related to the unpublished foster care policy:

• Update the form to remove all references to transitional foster care and community-based care placement types throughout document as this form will only be used for long-term foster care placements at this time.

• Remove reference to Section 8 of the policy as the policy guidance is not currently published.

Other revisions:

• Update the form to remove all references to initial placements, as ORR does not make initial placements into long-term foster care directly from the United States/Mexico border.

• Technical revisions include replacing the "Title" description box with the "Care Provider Program" description box in the Certification section of the form.