Nonsub Change Memo_0970-0278_10.20.26

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To:	Kelsi Feltz
	Office of Information and Regulatory Affairs (OIRA)
	Office of Management and Budget (OMB)

From:	Shannon Herboldsheimer
	Office of Refugee Resettlement (ORR)
	Administration for Children and Families (ACF)

Date:	October 19, 2026

Subject:	Non-Substantive Change Request – Unaccompanied Alien Children Sponsor Application Packet (OMB #0970-0278) 


This memo requests approval of a non-substantive change to the approved information collection, Unaccompanied Alien Children (UAC) Sponsor Application Packet (OMB #0970-0278). 

Background
The UAC Sponsor Application Packet information collection contains seven instruments that allow ORR to collect information necessary to determine the suitability of potential sponsors for UAC 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 February 27, 2026, and expires on February 28, 2029.  

ORR is proposing revisions to the following forms:
    • Authorization for Release of Information (Form SAP-2)
    • Sponsor Application (Form SAP-3)
ORR requests approval of these revisions as nonsubstantive changes to improve the clarity, organization, and consistency of the Sponsor Application Packet. The revisions align section headings and question order with the digital sponsor application, clarify instructions and terminology, provide conditional response fields from the existing approved forms, and remove unnecessary fields. These changes help sponsors provide complete and consistent responses for ORR’s existing sponsorship and placement process.
Several revisions organize information already requested through broader questions or supporting-document instructions. For example, the existing Financial Information section requests all income sources and amounts, including financial support from others. The revised fields provide specific prompts for sponsors to explain that support. Similarly, the incident follow-up fields organize details already requested in the Legal Records instructions, including the person involved, location, date, explanation, and disposition. 
The request also adds a current sponsor photo (selfie) to support the existing identity-verification process. The photo provides a current image of the applicant to assist ORR in verifying the applicant’s identity in connection with the identification documents already required. Including this request in the paper forms provides consistent instructions across application formats. 
The revisions are intended to improve the completeness and organization of information used for evaluation of potential sponsors and safe placement decisions. ORR does not believe that these updates will change the approved burden estimate.
This memo requests approval of a non-substantive change to the approved information collection, Unaccompanied Alien Children (UAC) Sponsor Application Packet (OMB #0970-0278).

Overview of Requested Changes
ORR will update the approved information collection forms to the forms listed above, including:
1. All Instruments
    • Reordered questions, where possible, to align with the information groupings in the digital sponsor application.
    • Updated “State” to “State/Province” and “ZIP Code” to “Postal Code” to accommodate addresses outside the United States.
2. Authorization for Release of Information (Form SAP-2)
Background
    • Updated “Information Required for a Background Check” to “Background” to align with the digital application.
    • About the Children: Added a column for “Child’s Country of Origin.”
    • Removed “County of Birth” and “State of Birth,” which are not needed for the sponsorship process.
    • Updated “TIN” to “ITIN” to align with the digital application.
Address Information
    • Updated instructions to direct sponsors who cannot recall a street address to enter “Unable to Recall Address” while still providing the city, state, or country and applicable dates.
    • Added a designated “Your Current Address” field and a Yes/No question asking whether the sponsor had a fixed home or physical address during the period covered by the address entry.
    • Added a conditional text box for sponsors to explain living arrangements when they did not have a fixed home or physical address, such as moving between homes or having no place to stay. These responses clarify address history and support safe placement decisions.
ARI File Uploads
    • Added a selfie verification photo request to the paper forms to reflect the corresponding identity-verification upload in the digital ARI.
3. Sponsor Application (Form SAP-3)
Sponsor Information
    • Updated “About You—the Sponsor—and the Child(ren)” to “Sponsor Information” to align with the digital application.
    • Updated “Country of Birth” to “Country of Origin” to clarify the question about where the sponsor was born.
    • Moved “Language(s) You Speak” to align with the digital application’s question order.
    • Updated “Phone Numbers” to “Sponsor’s Contact Information,” changed “Primary Phone” to “Mobile Phone,” and added an email field within the contact information section.
Sponsor’s Income and Employment Information
    • Moved “Financial Information,” formerly Item 13, into Sponsor Information and renamed it “Sponsor’s Income and Employment Information.”
    • Added questions about court-ordered child support paid, child support received, employment status, and ability to meet expenses.
    • Added a follow-up question asking how sponsors earn money if they are not employed.
    • Added conditional “My Job” fields for employment type and position/job title; average weekly and annual income; employer name, street address, city, state, country, ZIP code, and telephone number; employment start month and year and length of employment; average weekly hours; days worked, using weekday checkboxes; and comments.
    • Added a question about financial support from household members, a partner, an alternative caregiver, or a spouse, with conditional “My Supporter’s Job” fields requesting the same employment information. These prompts organize information about support from others previously requested in the Financial Information section.
    • Added fields for other income sources; monthly food, rent, clothing, and school expenses; total monthly expenses; total monthly income; and total annual income.
Prior Sponsorship Information
    • Added a dedicated section to align with the digital application.
    • Added a question about previous sponsorship attempts, with conditional fields for the sponsorship date; the child’s UAC Portal ID, A-number, first and last name, date of birth, and sex; and the sponsor’s relationship to the child.
    • Added questions about the child’s school attendance, immigration court attendance and court date, post-release services and case manager contact, and whether the child still lives with the sponsor.
    • Added questions about previous ORR home studies; withdrawn or discontinued sponsorship applications and the reasons; previous sponsorship denials and the reasons; relatives currently in ORR care; and whether a child was previously removed from the sponsor’s custody, with an explanation.
Household Information
    • Added a section heading to align with the digital application.
    • Updated “Household Member Name” to “Household Member First and Last Name.”
    • Added a prompt asking sponsors to explain when the proposed residence differs from their current address.
Health Information
    • Moved the existing Health Information section after Household Information without changing the questions.
Criminal History
    • Moved the section after Health Information and expanded the existing questions to cover both the sponsor and household members.
    • Added conditional follow-up fields for affirmative responses to the criminal-charge/conviction and abuse/neglect/abandonment questions. These fields require the person involved, incident location and date, explanation, and disposition, such as charges dropped, a fine, imprisonment, or probation. The existing Legal Records instructions already request these incident details.
Adult Who Will Care for the Child(ren) If You Cannot
    • Added email and country fields for the alternative caregiver.
    • Updated Item 12(f) to clarify how the alternative caregiver will care for the child if the sponsor becomes unable to do so.
Supporting Documents and Uploads
    • Updated the heading to “Proof of Identity: Sponsor, Adult Household Members, and Alternative Caregiver.” 
Organized the identity instructions into “Identification Documents” and “Sponsor Photo (Selfie)” subsections. Retained the accepted formats for government-issued identification documents—legible, full-color photocopies, digital scans, high-resolution digital photos, or original documents—and the requirement for at least one listed document for the sponsor and each adult household member. Retained the instruction that expired documents will not be accepted.

TIME SENSITIVITIES 

ORR requests expedited approval to support prompt compliance with the court’s directive in Angelica S. v. HHS to use the OMB-approved information collection or obtain approval for a materially different collection. These revisions align the Sponsor Application (Form SAP-3) and Authorization for Release of Information (Form SAP-2) with the digital application already in use. Prompt approval is critical to resolving discrepancies across application formats and providing consistent instructions and document requirements that support the safe and timely placement of children.