The Children Who Stop Talking

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REBEKAH RICKS

The Children Who Stop Talking
Trafficking identification, permanent records, and the limits of a child’s consent
under OMB No. 0970-0509
A white paper by Rebekah Ricks, September 2026
Submitted with the author’s individual comment on OMB No. 0970-0509, 91 Fed. Reg. 46,935 (July 27, 2026)

Executive Summary
The Office of Refugee Resettlement (ORR) proposes to share health information from its mental
health forms with the Department of Homeland Security (DHS) when a child with healthcare needs is
identified for repatriation. Before sharing mental health information, the notice says, ORR “will
request consent from the child.”1 This paper examines the proposal from two directions the notice
does not address: what it will do to the conversations ORR depends on to find trafficked and abused
children, and what happens to a child’s information after it leaves ORR.
The children who stop talking. Congress made protecting unaccompanied children from traffickers
part of the federal government’s job, and one month before this notice ORR itself said that duty
justified new burdens on its own process. Abuse and trafficking usually come to light only when a
child decides it is safe to talk. Research on adolescents shows that confidentiality assurances change
what young people are willing to disclose. A child who learns that what she tells a counselor can
travel to DHS has a reason to say less, and the children with the most to tell have the most reason to
stay quiet.
A record the child cannot call back. The notice does not say which part of DHS receives the
information, which system of records it enters, how long it is kept, or how it may be used. If it enters
the A-File, DHS’s official immigration record, the governing notice lists medical information among
its contents, provides for transfer to the National Archives 100 years after the person’s date of birth,
and authorizes disclosures that include foreign governments coordinating removal. A child who
changes her mind has no practical way to retrieve what was sent.
A consent no one could give. Informed consent requires disclosure of what is being authorized. The
notice does not disclose it. Even a capable adult could not give informed consent on the terms
published. A child certainly cannot, and no child, at any age, should be the only one asked.
My recommendation: before any mental health information about a child goes to DHS, require
an adult’s consent every time; name the receiving system and its retention and use rules; send
clinical information to the child’s next caregiver rather than into an immigration record; and

1

Admin. for Children & Families, Proposed Information Collection Activity; Mental Health Assessment Form and Onsite Health
Intervention Form, OMB No. 0970-0509, 91 Fed. Reg. 46,935 (July 27, 2026), FR Doc. 2026-15087,
https://www.federalregister.gov/documents/2026/07/27/2026-15087/proposed-information-collection-activity-mental-healthassessment-form-and-onsite-health. The quoted sentence appears at 46,936.
Rebekah Ricks, The Children Who Stop Talking, Page 1 of 10

study the effect on children’s disclosures before changing what they are told in the counselor’s
office.

1. What the Notice Says, and What It Leaves Out
The notice expands the purposes of the Mental Health Assessment Form to include “sharing relevant
health data captured on the MHAF with DHS when a child in ORR custody has healthcare needs and
is identified by DHS for repatriation.”2 It lists the categories to be shared: identifying information,
active diagnoses or concerns that require management, allergies, current medications and dosages,
isolation or quarantine requirements, health-related accommodations, and health-related travel
restrictions.3 It adds: “Prior to sharing mental health information with DHS, ORR will request
consent from the child.”4
Read closely, the notice is precise about what leaves ORR and silent about where it goes. It refers
only to “the Department of Homeland Security (DHS).”5 It names no DHS component, such as
Immigration and Customs Enforcement, Customs and Border Protection, or Citizenship and
Immigration Services. It names no DHS system of records. It sets no retention period, no limit on
DHS’s use of the information, and no rule against onward disclosure. It says nothing about what
happens if a child refuses, and elsewhere it says that relevant treatment plan information “must be
shared with DHS.”6
It is also worth being precise about what the notice does not propose. It does not say DHS will
receive complete therapy files. My argument does not depend on that. It depends on the fact that a
child is being asked to authorize a disclosure whose destination and consequences the notice does not
disclose.

2. Congress Made Finding Trafficked Children Part of the Job
The statute governing these children is titled “Enhancing efforts to combat the trafficking of
children.”7 It directs the Secretaries of Health and Human Services and Homeland Security, the
Attorney General, and the Secretary of State to “establish policies and programs to ensure that
unaccompanied alien children in the United States are protected from traffickers and other persons
seeking to victimize or otherwise engage such children in criminal, harmful, or exploitative
activity.”8 It requires policies to ensure that children are “safely repatriated.”9 And it makes ORR’s
Director responsible for “ensuring that the interests of the child are considered in decisions and
actions relating to the care and custody of an unaccompanied alien child.”10

2

91 Fed. Reg. at 46,936.

3

Id.

4

Id.

5

Id. at 46,935.

6

Id. at 46,935-36.

7

8 U.S.C. § 1232.

8

8 U.S.C. § 1232(c)(1).

9

8 U.S.C. § 1232(a)(1).

10

6 U.S.C. § 279(b)(1)(B).
Rebekah Ricks, The Children Who Stop Talking, Page 2 of 10

ORR has recently said the same thing in its own words. In a proposed rule published June 26, 2026,
one month before this notice, ORR reported that “HHS’s own internal investigations have revealed
documented cases of criminal prosecutions related to the use of fraudulent foreign documents in
sponsor applications in which former UAC became victims of crimes by their sponsors, including
incidents of trafficking and sexual assault.”11 It concluded that its proposed requirements were
“necessary to effectuate its statutory duties to protect UAC from trafficking and exploitation, even if
these proposed additional requirements would result in additional time needed to approve the release
of UAC to sponsors.”12
The oversight record shows why that concern is warranted. HHS’s Inspector General found in 2024
that “[i]n 16 percent of children’s case files, one or more required sponsor safety checks lacked any
documentation indicating that the checks were conducted,” and that “[i]n 22 percent of cases, ORR
did not conduct timely Safety and Well-Being Follow Up Calls.”13 DHS’s Inspector General found in
2025 that “the addresses ICE had for 31,322 of the 448,820 UACs were either blank, undeliverable,
or missing apartment numbers.”14 These are findings about gaps in screening and monitoring. They
are not counts of missing or trafficked children, and I do not present them that way. What they show
is that once a child leaves ORR’s care, the government’s ability to learn what is happening to her is
limited. What a child says while she is still in ORR’s care matters all the more.
The consequence for this notice is simple. A policy that makes children less willing to talk to ORR’s
clinicians works against the duty Congress assigned and ORR has just reaffirmed.

3. Disclosure Is a Process, and Confidentiality Makes It Possible
Children rarely disclose abuse all at once, and they rarely disclose it first to authorities. In a study of
4,339 Swedish high school seniors, most of those who had experienced sexual abuse had told
someone, but “[g]irls and boys disclosed most often to a friend of their own age. Few had disclosed
to professionals. Even fewer said that the incident had been reported to the authorities.” 15 The authors
concluded that “[m]uch is hidden from the adult society, especially from professionals and the legal
system.”16
Confidentiality changes what young people are willing to say. In a randomized trial of 562
adolescents, a physician’s assurance of confidentiality “increased the number of adolescents willing
to disclose sensitive information about sexuality, substance use, and mental health from 39%
(68/175) to 46.5% (178/383),” and increased the number willing to seek future health care “from
53% (93/175) to 67% (259/386).”17
11

Unaccompanied Children Program Foundational Rule; Sponsor Assessment Update To Include Proof of Identity, Background
Check, Placement, and Income Verification Standards, 91 Fed. Reg. 38,582, 38,584-85 (proposed June 26, 2026).
12

Id. at 38,589.

13

HHS Office of Inspector General, Gaps in Sponsor Screening and Followup Raise Safety Concerns for Unaccompanied
Children, OEI-07-21-00250 (Feb. 2024), https://oig.hhs.gov/reports/all/2024/gaps-in-sponsor-screening-and-followup-raisesafety-concerns-for-unaccompanied-children/.
14

DHS Office of Inspector General, ICE Cannot Effectively Monitor the Location and Status of All Unaccompanied Alien
Children After Federal Custody, OIG-25-21, at 5 (Mar. 25, 2025),
https://www.oig.dhs.gov/sites/default/files/assets/2025-03/OIG-25-21-Mar25.pdf.
15

Gisela Priebe & Carl Göran Svedin, Child Sexual Abuse Is Largely Hidden from the Adult Society: An Epidemiological Study
of Adolescents’ Disclosures, 32 Child Abuse & Neglect 1095 (2008) (abstract), https://pubmed.ncbi.nlm.nih.gov/19038448/.
16

Id.
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ORR’s own regulations make confidentiality the first thing a child hears. Before the assessment and
counseling begin, care providers must give the child “a written notice of the limits of confidentiality”
and explain it orally in her language “in a way they can effectively understand.”18 If this proposal is
adopted, that notice will have to tell children that what they say may be shared with DHS. Honesty
requires it. The question is what a child who has been trafficked, abused, or threatened will choose to
say after hearing it.
The population makes the question urgent. When UNHCR interviewed 404 unaccompanied or
separated children from El Salvador, Guatemala, Honduras, and Mexico, it found that “no less than
58% of the 404 children interviewed were forcibly displaced because they suffered or faced harms
that indicated a potential or actual need for international protection.” 19 That is not a trafficking
statistic, and I do not use it as one. It shows that a large share of these children carry histories that
matter to their safety and that come to light only when the child tells someone.
No study has measured how much less ORR’s children would disclose if their mental health
information could go to DHS, and I do not claim a number. That absence is the point. Before
changing what children are told at the start of every counseling relationship, ACF should find out
what the change will cost, because the practical utility of a mental health assessment depends on
what the child is willing to say.

4. The Protection Gap Before a Child Speaks
Existing law shields some victims’ information from immigration authorities, but only after the
victim has come forward. The main statute bars officials of DHS, the Department of Justice, and the
Department of State from permitting use or disclosure of information relating to a person “who is the
beneficiary of an application for relief” as a trafficking victim, a crime victim, or a battered spouse or
child.20 It does not bind HHS. It attaches to an application. And the protection “ends when the
application for relief is denied and all opportunities for appeal of the denial have been exhausted.” 21
HHS’s Office on Trafficking in Persons issues Eligibility and Interim Assistance Letters through
which foreign national minors, including unaccompanied children, who have experienced a severe
form of trafficking become eligible for federal benefits and services.22 That help, too, begins with
someone learning what happened.
The child this proposal most endangers is the one before any of these protections exist: the child who
has not yet told anyone she was trafficked, who has no application pending and no letter issued, and
whose first disclosure would happen in a counselor’s office. Downstream confidentiality protections
cannot help a child who never speaks.
17

Carol A. Ford et al., Influence of Physician Confidentiality Assurances on Adolescents’ Willingness to Disclose Information
and Seek Future Health Care: A Randomized Controlled Trial, 278 JAMA 1029 (1997) (abstract),
https://pubmed.ncbi.nlm.nih.gov/9307357/. The comparison is between adolescents who heard no mention of confidentiality and
those who heard either a conditional or an unconditional assurance.
18

45 C.F.R. § 410.1306(c)(1).

19

UNHCR, Children on the Run: Unaccompanied Children Leaving Central America and Mexico and the Need for International
Protection (2014), https://www.unhcr.org/us/children-run.
20

8 U.S.C. § 1367(a)(2).

21

8 U.S.C. § 1367(a).

22

HHS Office on Trafficking in Persons, Child Eligibility Letters, https://www.acf.hhs.gov/otip/victim-assistance/childeligibility-letters.
Rebekah Ricks, The Children Who Stop Talking, Page 4 of 10

5. Where the Record Goes
Because the notice does not name the receiving system, I cannot say where a child’s information
would be kept, and I do not assume. But DHS’s own published records notices show what is at stake,
and they are what a child would need to understand before her consent could be called informed.
The A-File is DHS’s central immigration record. Its governing notice describes it as “the official
record of an individual’s immigration history,” used “in immigration proceedings before U.S.
Department of Justice (DOJ) immigration judges and the Board of Immigration Appeals (BIA),” and
as “the official record used in Federal court litigation.”23 Its categories of records include “Medical
information.”24 Its retention rule reads: “DHS/USCIS transfers A-Files to the custody of NARA 100
years after the individual’s date of birth.”25 Its index records “are permanently retained.”26
The A-File’s routine uses reach well beyond a child’s trip home. Routine Use HH permits disclosure
“[t]o foreign governments for the purpose of coordinating and conducting the removal of individuals
to other nations under the INA; and to international, foreign, and intergovernmental agencies,
authorities, and organizations in accordance with law and formal or informal international
arrangements.”27 A routine use is a permission, not proof that any particular record will be sent
anywhere. But a child asked to consent would need to know that the permission exists.
DHS already knows how to write a narrower rule. In the same notice, Routine Use FF allows
disclosure to arrange “continuing medical care,” but “only such information that is relevant and
necessary” for that purpose. Routine Use GG limits disclosures about a person who, “due to a
condition such as mental illness, may pose a health or safety risk” to information “relevant to the
health or safety risk” and the means to mitigate it, such as “the individual’s need to remain on certain
medication for a serious mental health condition.”28 That is the right model for this proposal: the
information needed to keep a child’s treatment going, and nothing more.

6. A Consent That Cannot Be Taken Back
Even under HIPAA, revoking an authorization does not undo what has already happened. A person
“may revoke an authorization provided under this section at any time, provided that the revocation is
in writing, except to the extent that: (i) The covered entity has taken action in reliance thereon.” 29
Once information has been sent, revocation stops future disclosures. It does not retrieve the copy.
Other routes to correction are closed to most of these children. The Privacy Act defines an
“individual” as “a citizen of the United States or an alien lawfully admitted for permanent
residence.”30 And for the A-File, DHS “has exempted this system from the notification, access, and
23

DHS/USCIS/ICE/CBP-001, Alien File, Index, and National File Tracking System of Records, 82 Fed. Reg. 43,556 (Sept. 18,
2017), as modified by 90 Fed. Reg. 61,409 (Dec. 31, 2025), at 43,557.
24

Id. at 43,560.

25

Id. at 43,564.

26

Id.

27

Id. at 43,563.

28

Id. at 43,563.

29

45 C.F.R. § 164.508(b)(5).

30

5 U.S.C. § 552a(a)(2).
Rebekah Ricks, The Children Who Stop Talking, Page 5 of 10

amendment procedures of the Privacy Act, and those of the Judicial Redress Act (JRA) if applicable,
because it is a law enforcement system.”31
A decision that cannot practically be reversed, about a record that may be kept for a century, is
exactly the kind of decision the law ordinarily reserves for adults.

7. Why a Childhood Record Can Matter Later
This argument is easy to overstate, so I will be careful. A mental health diagnosis does not by itself
make a person inadmissible to the United States. The statute requires a disorder “and behavior
associated with the disorder that may pose, or has posed, a threat to the property, safety, or welfare of
the alien or others.”32 CDC’s instructions to immigration medical examiners state that “neither
harmful behavior nor the physical or mental disorder or non-CSA substance use disorder alone
makes an applicant medically inadmissible.”33
The same instructions show why history matters. Harmful behavior includes “[s]erious psychological
or physical injury to the applicant or to others (e.g., a suicide attempt or child abuse).”34 The
examining physician should ask about “[t]he applicant’s history of diagnosed mental or physical
disorders” and should “[r]eview other relevant records (if available), such as police, military, school,
and employment, and any historical medical records, that might provide a history of harmful
behavior or substance use.”35 In fiscal year 2024, the State Department reported 624 immigrant visa
ineligibility findings and 260 nonimmigrant findings on this ground, a category that combines
physical and mental disorders; 387 and 21, respectively, were overcome.36
Mental health evidence can also matter in immigration court. The Attorney General has held that
“[i]mmigration adjudicators may consider a respondent’s mental health in determining whether an
individual, ‘having been convicted by a final judgment of a particularly serious crime, constitutes a
danger to the community of the United States.’”37 It can protect a person too: the Board of
Immigration Appeals has held that when an asylum applicant “has competency issues that affect the
reliability of his testimony,” the judge “should, as a safeguard, generally accept his fear of harm as
subjectively genuine.”38 And when a child in federal custody turns 18 and is transferred to DHS, the
statute directs DHS to take into account “the alien’s danger to self, danger to the community, and risk
of flight” in deciding placement.39
None of this means a childhood diagnosis will be used against a child. It means that a record created
for a child’s trip home can be relevant to decisions made about her years later, by people she will
never meet, and that she cannot evaluate that possibility on a form.
31

82 Fed. Reg. at 43,564.

32

8 U.S.C. § 1182(a)(1)(A)(iii)(I).

33

CDC, Technical Instructions for Panel Physicians: Mental Health (updated Aug. 4, 2025), https://www.cdc.gov/immigrantrefugee-health/hcp/panel-physicians/mental-health.html.
34

Id.

35

Id.

36

U.S. Dep’t of State, Report of the Visa Office 2024, Table XIX,
https://travel.state.gov/content/dam/visas/Statistics/AnnualReports/FY2024AnnualReport/Table%20XIX.pdf.
37

Matter of B-Z-R-, 28 I&N Dec. 563, 563 (A.G. 2022).

38

Matter of J-R-R-A-, 26 I&N Dec. 609, 609 (BIA 2015).

39

8 U.S.C. § 1232(c)(2)(B).
Rebekah Ricks, The Children Who Stop Talking, Page 6 of 10

8. No One Can Consent to Consequences No One Has Disclosed
American law built informed consent around adults. The foundational statement is that “[e]very
human being of adult years and sound mind has a right to determine what shall be done with his own
body.”40 Consent is meaningful only when it is informed: “[t]rue consent to what happens to one’s
self is the informed exercise of a choice.”41 The Belmont Report describes the consent process as
having “three elements: information, comprehension and voluntariness.”42 The American Medical
Association directs physicians to “[a]ssess the patient’s ability to understand relevant medical
information and the implications of treatment alternatives and to make an independent, voluntary
decision.”43
Measured against those elements, the notice fails before capacity even enters the picture.
Information: a child cannot be told which DHS office receives her records, which system holds
them, how long they are kept, who else may see them, or whether refusing changes anything, because
the notice does not say. Comprehension: the Belmont Report recognizes that a person’s “ability to
understand is a function of intelligence, rationality, maturity and language,”44 and these are children,
many of them carrying trauma and many of them speaking languages other than English.
Voluntariness: the request comes from the agency that controls the child’s placement and release,
for the benefit of the agency carrying out her return. The Belmont Report warns that unjustifiable
pressures arise when “persons in positions of authority or commanding influence” urge a course of
action, especially where sanctions are possible.45
Capacity makes it harder still. In a study of subjects aged 9, 14, 18, and 21, 9-year-olds “appeared
less competent than adults with respect to their ability to reason about and understand the treatment
information provided,” though 14-year-olds, overall, did not differ from adults.46 In a study of 927
adolescents and 466 young adults, “[y]ouths aged 15 and younger performed more poorly than young
adults.”47 Older adolescents can reason well in calm settings. That is why I believe an older child’s
agreement should be required. It is not a reason to make her the only one asked, in custody, about a
record she cannot take back.
My position: no child, at any age, should be the only person asked. An adult must consent every
time: a parent or legal guardian where one can be reached, and an independent adult charged
with the child’s best interests where one cannot. An older child’s agreement should be required
in addition, and her objection honored.

40

Schloendorff v. Society of New York Hospital, 211 N.Y. 125, 129 (1914).

41

Canterbury v. Spence, 464 F.2d 772, 780 (D.C. Cir. 1972).

42

Nat’l Comm’n for the Protection of Human Subjects of Biomedical & Behavioral Research, The Belmont Report pt. C.1
(1979), https://www.hhs.gov/ohrp/regulations-and-policy/belmont-report/read-the-belmont-report/index.html.
43

AMA Code of Medical Ethics Op. 2.1.1, https://code-medical-ethics.ama-assn.org/ethics-opinions/informed-consent.

44

Belmont Report, supra, pt. C.1.

45

Id.

46

Lois A. Weithorn & Susan B. Campbell, The Competency of Children and Adolescents to Make Informed Treatment
Decisions, 53 Child Dev. 1589 (1982) (abstract), https://pubmed.ncbi.nlm.nih.gov/7172783/.
47

Thomas Grisso et al., Juveniles’ Competence to Stand Trial, 27 Law & Hum. Behav. 333 (2003) (abstract),
https://pubmed.ncbi.nlm.nih.gov/12916225/.
Rebekah Ricks, The Children Who Stop Talking, Page 7 of 10

9. Eight Minutes
The notice estimates that each Mental Health Assessment Form response takes a mental health
professional 0.13 hours, based on 250 professionals completing 12.3 responses each, for 399.8 hours
a year.48 That is less than eight minutes per form. The same revision adds a healthcare provider
acknowledgement and signature section authorizing record sharing with ORR.49
An honest consent conversation with a child about sharing her mental health information with DHS
cannot fit inside that estimate. It would require explaining the new limits of confidentiality at the
outset, through an interpreter where needed; explaining what would be shared, with whom, for how
long, and with what consequences; confirming that the child understood; and, under my
recommendation, reaching a parent or an independent adult. Either the estimate does not include this
work, in which case it is inaccurate, or the work will not be done, in which case the consent will not
be real. I ask ACF to revise the estimate under the Paperwork Reduction Act’s accuracy criterion. 50

10. A Better Design
Continuity of care does not require an immigration record. Federal hospital rules show the ordinary
model: at discharge, a hospital sends “all necessary medical information pertaining to the patient’s
current course of illness and treatment” to “the appropriate post-acute care service providers and
suppliers.”51 Clinical information follows the patient to the people who will treat her next.
Applied here, that model separates three things. Travel safety: DHS receives what its officers need
to move a child safely, such as medications to be given during travel, allergies, equipment,
quarantine status, and travel restrictions. Clinical continuity: the fuller treatment summary goes
from the treating clinician directly to the receiving caregiver, child welfare authority, or health
provider. Immigration records: diagnosis labels, therapy content, and history stay out of
immigration and enforcement systems unless a statute specifically requires them. That design serves
the purpose the notice states without risking that a child’s mental health history ends up in a record
kept for a century.

11. The Agency’s Strongest Arguments, and My Answers
“This is narrow continuity-of-care sharing, not an enforcement pipeline.”
The notice’s purpose is narrow. Its safeguards are not written down. A narrow purpose with no
named recipient, no retention limit, and no use limit is not a narrow program. If the sharing is truly
limited to care, ACF can say so in binding terms and name the system.

“Asking for the child’s consent solves the privacy problem.”
Asking is not the same as obtaining informed, voluntary consent, and the notice defines neither. It
does not say whether refusal is honored, whether it carries consequences, whether consent can be
48

91 Fed. Reg. at 46,936 (Estimated Response Time for Respondents).

49

See 91 Fed. Reg. 46,935 (description of proposed changes).

50

44 U.S.C. § 3506(c)(2)(A)(ii); see 91 Fed. Reg. 46,935 (requesting comment on “the accuracy of the agency’s estimate of the
burden of the proposed collection of information”).
51

42 C.F.R. § 482.43(b).
Rebekah Ricks, The Children Who Stop Talking, Page 8 of 10

limited to some items, or whether a lawyer or advocate may be present. A child cannot consent to
terms that have not been disclosed.

“Existing confidentiality laws already prevent misuse.”
They protect some victims after they come forward. They do not protect the child who has not yet
spoken, and the main statute does not bind HHS at all. Access controls limit who can open a file.
They do not limit what the file can be used for.

“A diagnosis alone has no immigration consequence.”
That is correct as to inadmissibility, and I have said so. But records can matter in medical
examinations, dangerousness determinations, and custody decisions at 18. The question is not
whether harm is certain. It is why an immigration record should hold a child’s mental health history
at all when her treatment can continue through a clinical handoff.

12. Recommendations
1. An adult consents every time. No child, at any age, should be the only person asked. Require
the written consent of a parent or legal guardian where one can be reached, and otherwise of an
independent adult charged with the child’s best interests who has no role in her custody,
placement, or immigration case. Require an older child’s agreement in addition, and honor her
objection.
2. Name the recipient. Identify the DHS component, the system of records, the governing
records notice, and the retention schedule that would apply to any information shared.
3. Keep it out of immigration files. Provide that mental health information shared for continuity
of care will not be placed in the A-File or any enforcement system, will be deleted when the
child’s return is complete, and will not be disclosed onward.
4. Limit the use. Provide in writing that DHS may use the information only for the child’s care
during return, and never in removal proceedings, custody or detention decisions, or
enforcement against the child, a sponsor, or family members.
5. Send clinical information to clinicians. Route treatment summaries directly to the receiving
caregiver or provider, and give DHS only what is needed for safe travel.
6. Study the effect first. Before changing what children are told about confidentiality, assess how
the change will affect disclosures of trafficking, abuse, and exploitation, and publish the
assessment.
7. Publish the consent instrument and revise the burden estimate. Publish the consent form,
staff script, and instructions with the 30-day notice, and revise the time estimate to reflect a real
consent process.

13. Scope and Limits
I rely on primary sources throughout, and I say so where a source is research or reporting rather than
law. I have not assumed that ORR’s information will enter any particular DHS system, because the
notice does not say; naming it is one of my requests. I do not claim that a diagnosis makes a child
Rebekah Ricks, The Children Who Stop Talking, Page 9 of 10

inadmissible, or that the Inspector General findings count missing or trafficked children. No study
has measured how this proposal would change what ORR’s children disclose, and I do not offer a
number. The research and ethics standards I cite do not govern ORR directly. I cite them for how the
federal government ordinarily protects people whose consent is sought while they are in its custody.

About the Author
Rebekah Ricks is a mother, a former classroom teacher, and a legislative strategist who has worked
on parental rights and child protection policy, including anti-trafficking legislation, for more than
twenty years. She lives in Winter Haven, Florida.

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