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 Department of Health and Human Services
 
OFFICE OF 

 
INSPECTOR GENERAL 

 
 
 
 
 
 
 
 
 
 
D U
IVISION OF  NACCOMPANIED 

 
C    S : 

HILDREN S  ERVICES
 
E T S C  
FFORT  S  O  ERVE  HILDREN 

 
 
 
 
 
Daniel R. Levinson 
  
Inspector General 

 
March 2008 
 
OEI-07-06-00290 
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Office of Inspector General

http://oig.hhs.gov  
 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452,  
as amended, is to  protect the integrity of  the Department of Health and Human Services 
(HHS)  programs, as well as the health and welfare of beneficiaries  served by those 
programs.  This statutory mission  is  carried  out through  a nationwide network  of  audits, 
investigations, and inspections conducted by the  following operating components:  
Office of Audit Services 
The Office of Audit Services (OAS) provides all auditing services  for HHS, either by  
conducting audits with its  own audit resources or by overseeing audit work done by others.   
Audits examine the performance of HHS programs and/or its grantees and  contractors  
in carrying out  their respective responsibilities and are intended  to provide independent  
assessments of  HHS programs and operations.  These assessments help reduce waste, 
abuse, and mismanagement  and  promote economy and  efficiency throughout HHS. 
Office of Evaluation and Inspections  
The Office  of  Evaluation and Inspections (OEI)  conducts national evaluations to  provide 
HHS, Congress, and the public with timely, useful, and reliable information on 
significant issues.  Specifically, these evaluations focus on preventing fraud,  waste,  or  
abuse and promoting  economy, efficiency, and effectiveness  in departmental programs.  
To promote impact, the reports also present practical recommendations for improving 
program operations.  
Office of Investigations 
The Office of Investigations (OI) conducts criminal, civil, and administrative  
investigations  of  allegations of wrongdoing  in HHS  programs or to HHS  beneficiaries  
and of unjust enrichment by  providers.  The investigative  efforts  of OI lead to  criminal  
convictions, administrative sanctions,  or  civil monetary penalties.  
Office of Counsel to the Inspector General 
The  Office of Counsel to the Inspector General (OCIG)  provides  general legal services  to  
OIG, rendering  advice and opinions on HHS programs and operations and  providing all  
legal support in OIG's internal operations.   OCIG imposes program exclusions and civil 
monetary penalties  on health care providers and litigates  those actions  within HHS.   
OCIG also  represents OIG in the global settlement of  cases  arising under the Civil False 
Claims Act, develops and monitors corporate integrity agreements, develops compliance 
program guidances, renders advisory opinions on OIG sanctions to  the health care  
community,  and issues fraud alerts  and other industry  guidance.  
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I N T R O D U C T I O N  
  E X E C U T I V E   S U M M A R Y
OBJECTIVE 
 
To assess the Division of Unaccompanied Childrens Services (DUCS) 
placement, care, and release of unaccompanied alien children. 
BACKGROUND 
For fiscal year (FY) 2008, the Presidents budget request for the 
Department of Health and Human Services (HHS) estimates that the 
Federal Government will apprehend 10,350 unaccompanied alien 
children who will be placed into HHS custody.  The term 
unaccompanied alien child is defined in 6 U.S.C.  279(g)(2) as a child 
who has no lawful immigration status in the United States, who has not  
attained 18 years of age, and who has no parent or legal guardian in the 
United States available to provide care and physical custody. 
The Homeland Security Act of 2002 transferred care and custody of 
unaccompanied alien children to DUCS within the Administration for 
Children and Families (ACF).  The Homeland Security Act  also created 
the Department of Homeland Security (DHS), which is responsible for 
immigration benefits and enforcement. 
In 1985, a class action lawsuit challenged Federal detention policies and 
procedures for children in Federal custody.  The litigants reached a 
settlement, commonly known as the Flores Agreement, that included  
minimum standards for placement, care, and release to sponsors of 
alien children in Federal custody. Although HHS did not have 
responsibility for unaccompanied alien children at the time the 
settlement was reached, section 1512(a) of the Homeland Security Act 
specifies that such agreements continue in effect according to their 
terms.   Therefore, HHS is bound by the terms of the Flores Agreement.   
FINDINGS 
Most children appeared to be placed and released in accordance with the 
Flores Agreement.   The Flores Agreement requires that children be  
admitted to facilities within 3 to 5 days, in most cases; be placed in the 
least restrictive setting appropriate; and be released without 
unnecessary delay.  Eighty-four percent of children were admitted to 
facilities within 3 days of apprehension and less than 4 percent of 
children were placed in staff-secure or secure facilities.  Most children 
were released quickly, and most reviewed case files of released children 
contained evidence of reunification packets. 
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Case Files Lacked Documentation of Care Received.  We could not 
determine whether lack of documentation in case files was a result of poor 
record keeping or failure to provide services. Fifty-six percent of case files 
lacked one or more of the required assessments used to gather information 
about childrens needs, and all case files lacked at least one required 
document that would indicate whether children received medical and 
mental health services or participated in educational and recreational 
activities. 
The Division of Unaccompanied Childrens Services provides limited  
oversight of facilities.  Interviews with DUCS central office officials 
indicate that little oversight of facilities occurs. Federal field specialist 
and field coordinator visits to facilities do not include routine meetings 
with children. Additionally, DUCS does not have a method to track 
children after they are released to sponsors and therefore is unable to 
determine whether the processes facilities use to  screen sponsors are 
effective and whether sponsors continue to provide for childrens physical, 
mental, and financial well-being. 
No explicit agreement exists between Federal Departments regarding  
information  exchange and postrelease activities.   When responsibilities were 
divided between  HHS and DHS, no formal memorandum of understanding 
(MOU) was established to clarify each Departments specific roles.  
Although the two Departments established a Statement of Principles in  
2004, it states that [t]his document  does not resolve all outstanding 
issues. . . .  As such, the Departments lack a specific agreement on  
exchanging information when children are transferred from  DHS to HHS  
custody. Additionally, it is not clear which Department is responsible for 
ensuring the safety of children once they are released to sponsors and  
which Department is responsible for ensuring sponsors continued 
compliance with sponsor agreements. 
RECOMMENDATIONS 
Although DUCS appears to be placing and releasing children in 
accordance with the Flores Agreement, all case files lacked at least one 
of the DUCS-required documents to  assess care needs or document care 
provided. Therefore, we could not definitively conclude that all children 
were receiving all needed services.  DUCS officials acknowledged a lack  
of program oversight, and no method exists to ensure that children 
remain with sponsors and that sponsors comply with sponsor 
agreements. Finally, no  explicit agreement exists between HHS and  
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E X E C U T I V E   S U M M A R Y   
DHS with regard to each Departments specific roles and 
responsibilities and their shared responsibilities with respect to 
exchanging information and monitoring children once they are released  
to sponsors.  
Therefore, we recommend that DUCS: 
Enforce documentation requirements to ensure that needs are assessed 
and care provided.  DUCS should conduct regular, periodic onsite visits to 
all facilities, using a standard protocol to ensure adherence to policies and 
procedures and completeness of case file documentation.  
Enhance and define field staff role in ongoing oversight.  The roles and 
responsibilities of Federal field specialists and field coordinators should 
include oversight responsibilities and require regular, individual meetings 
with children.  
Establish a memorandum of understanding.  Building on the Statement of 
Principles, HHS officials should  develop a formal MOU with DHS to 
clearly delineate the roles and responsibilities of each Department.  At a 
minimum, the MOU should address the following:   
 	 each entitys specific responsibilities for gathering and exchanging 
information when a child comes into Federal custody and is placed  
into a DUCS facility, and 
 	 each entitys specific responsibilities for gathering and exchanging 
information about children who have been released to sponsors to 
ensure that the process is working as intended and that sponsors 
are adhering to agreements. 
AGENCY COMMENTS 
In its written comments on the draft report, ACF did not indicate  
whether it concurred with our recommendations.  ACF did indicate  
that it agrees that more monitoring of facility documentation and 
practices is needed; that the Office of Refugee Resettlement (ORR)  
will include random interviews with children and case file reviews as 
part of the routine responsibilities for Federal field specialists; and 
that ORR is drafting a Joint Operations Manual with DHS, with the 
ultimate goal of drafting an MOU.   
 
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E X E C U T I V E   S U M M A R Y   
ACF questioned our findings about case file documentation, stating 
that many facilities keep multiple files and that [i]n general, the case 
files reviewed by ORR contain the required documentation . . . . 
With respect to postrelease activities, ACF stated that ORRs 
statutory mandate to ensure the well-being of an unaccompanied  
alien child ends at the time the child is released from ORRs care. 
OFFICE OF INSPECTOR GENERAL RESPONSE 
Although some facilities did maintain separate files for such things as 
medical care, education,  and counseling as stated in ACFs comments,  
those facilities consolidated the files for our review.  When asked, 
facility staff confirmed that case files we reviewed should have 
contained all required documentation.  We have revised the report 
methodology to clarify that facilities reported that they provided to us 
the complete case files for our sampled children.  
In its 2005 report, DHS OIG reported DHSs concerns with ACFs 
release of children to sponsorsconcerns that imply DHS believes that 
it is ACFs responsibility to ensure proper and safe release of children.  
ACF stated that its statutory mandate to ensure the well-being of 
unaccompanied alien children ends at the time children are released 
from ORRs care.  An MOU will help address which agency has 
responsibility for postrelease monitoring. 
Finally, ACFs descriptions of current activities do not specifically 
address our recommendations and therefore it is unclear whether and  
how ACF intends to implement our recommendations.  We ask that, in 
its final management decision, ACF indicate whether it concurs with 
our recommendations and what steps, if any, it will take to implement  
them. 
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  T A B L E   O F   C O N T E N T S  
 
EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i
  
 
 
   
I N T RO DUC T IO N  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  1 
  
 
 
   
F I N D IN G S  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  11 
  
 
Children appeared to be placed and released as required. . . . . . .  11 
  
 
Case files lacked care documentation. . . . . . . . . . . . . . . . . . . . . . .  13 
  
 
Division of Unaccompanied Childrens Services oversight is       
limited. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .     15 
  
 
Departments lack an explicit agreement. . . . . . . . . . . . . . . . . . . .  17 
  
 
 
 
 
  R E C O MMEN D A T ION S  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  19 

  Agency Comments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  20 
  
 
  Office of Inspector General Response. . . . . . . . . . . . . . . . . . . . . . .  21 
  
 
 
 
 
  APPENDIXES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  22 
  
  A: 	Movement of Unaccompanied Alien Children Through 
               
  Federal Custody . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  22 
  
    B:	  Confidence Intervals for Key Estimates. . . . . . . . . . . . . . . . . .  23 
  
    C: 	Status of Unaccompanied Alien Children at Time  
                          
        of Sample Selection. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  24 
  
 
  D:	  Agency Comments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  25 
  
 
 
 
 
A C K NO WL E D G M E N T S  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  29 
  
 
 
 
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  I N T R O D U C T I O N
OBJECTIVE 
To assess the Division of Unaccompanied Childrens Services (DUCS) 
placement, care, and release of unaccompanied alien children. 
BACKGROUND 
For fiscal year (FY) 2008, the Presidents budget for the Department of 
Health and Human Services (HHS) estimates that the Federal 
Government will apprehend 10,350 unaccompanied alien children who 
will be placed into HHS custody.  The term unaccompanied alien child 
is defined in 6 U.S.C.  279(g)(2) as a child who has no lawful 
immigration status in the United States, who has not attained 18 years 
of age, and who has no  parent or legal guardian in the United States to  
provide care and physical custody. 
The 10,350 estimate represents a 15-percent increase from the number 
of children apprehended and placed in HHS custody during FY 2007.1   
HHS requested $135 million for FY 2008, an increase over the 
$77 million appropriated in FY 2007, to fund DUCS, a component 
within the Administration for Children and Families (ACF) Office of 
Refugee Resettlement (ORR). 
The Homeland Security Act of 2002, P.L. No. 107-296 
(6 U.S.C.  279(a)), transferred responsibility for the custody and care of  
unaccompanied alien children from the Commissioner of the former  
Immigration and Naturalization Service (INS),  U.S. Department of 
Justice, to the Director of ORR.  The Homeland Security Act also 
abolished INS and created the Department of Homeland Security 
(DHS). DHS is responsible for immigration benefits and enforcement, 
which includes apprehension, processing, and immigration actions.  (For  
simplicity, we will refer to the various agencies to which DHS has 
assigned its juvenile-related responsibilities collectively as DHS.)  The 
Director of ORR is responsible for the placement, care, and,  as 
appropriate, release to sponsors of these childrenresponsibilities 
delegated to the Director of DUCS (hereinafter  referred to as DUCS).  
Officials from DHS and HHS attempted to draft a memorandum of 
understanding (MOU) to delineate their respective roles and  
 
1 HHS Budget in Brief document reflecting the fiscal year (FY) 2008 Presidents budget 
for the Department of Health and Human Services (HHS)  Available online at 
http://www.hhs.gov/budget/08budget/2008BudgetInBrief.pdf. Accessed October 17, 2007. 
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I N T R O D U C T I O N   
responsibilities for unaccompanied alien children. Because of 
difficulties in agreeing to terms for an MOU, the agencies instead 
crafted a Statement of Principles in April 2004.  The statement defines 
broad operational responsibilities but . . . does not resolve all 
outstanding issues. . . .2  
Prior to enactment of the Homeland Security Act, INS was responsible 
for all of the functions related to unaccompanied alien children that now 
belong to DHS and DUCS. In 2001, the Department of Justices Office 
of the Inspector General (OIG) issued a report that noted numerous 
concerns about INSs handling of unaccompanied alien children.  
The report contained 28 recommendations, including a recommendation  
that INS implement procedures that require the monitoring and regular 
reporting of noncompliance with the 3-to-5-day placement requirement 
to ensure that juveniles are promptly placed into appropriate facilities 
and a recommendation that INS include and enforce standards that 
require the segregation of nondelinquent juveniles from delinquent 
juveniles in all contracts with secure detention facilities.3 In 2004 and 
2005, after the dissolution of INS and the creation of DHS, DHS OIG 
issued two reports following up on the recommendations from the  
Department of Justice OIG report.4   HHS OIG has not previously 
evaluated DUCS or its efforts to place, care for, and release 
unaccompanied alien children. 
The Flores Agreement  
In 1985, a class action lawsuit challenged INS detention policies and 
procedures for children in its custody.5 The litigants reached a 
settlement, commonly known as the Flores Agreement, which included  
minimum standards for areas such as placement, care, and release of  
children in INS custody.6  Although HHS was not a party to the Flores  
 
2 A Review of  DHS Responsibilities For Juvenile Aliens, the Department of Homeland
  
Security (DHS), Office of the Inspector General (OIG), OIG 05-45, September 2005, p. 24.  A 

copy of the Statement of Principles can be found in Appendix E of the report. 

3 Unaccompanied Juveniles in INS Custody, Department of Justice, OIG, I-2001-009, 

September 28, 2001. 

4 Open Inspector General Recommendations Concerning the Former Immigration and 

Naturalization Service from Unaccompanied Juveniles in INS Custody, a Report by the 

Department of Justice Inspector General, DHS, OIG, OIG-04-18, March 2004; and A 

Review of  DHS Responsibilities For Juvenile Aliens, DHS, OIG, OIG 05-45,        
  
September 2005. 

5 Reno v. Flores, 507 U.S. 292 (1993). 

6 Ibid., Case No. CV 85-4544-RJK (C.D. Cal. 1996). 

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I N T R O D U C T I O N   
Agreement, section 1512(a) of the Homeland Security Act specifies that 
agreements continue in effect according to their terms.7  Therefore, 
HHS is bound by the terms of the Flores Agreement.   
A basic tenet of the Flores Agreement is that unaccompanied alien 
children in Federal custody should be treated with dignity, respect, and 
special concern for their particular vulnerabilities as children.  The 
Flores Agreement also mandates that children be placed in the least 
restrictive setting; that placement occur within  3 to 5 days of 
apprehension, except in specific situations; and that children be 
released to  available sponsors without unnecessary delay.8  
To address the Flores Agreement, DUCS focuses its efforts in three 
main areas:  placement,  care, and release.  (See Appendix A for an 
overview flowchart of DUCS interactions with unaccompanied alien 
children.) 
Placement 
When DHS apprehends an individual and determines that he or she is 
an unaccompanied alien child, a juvenile coordinator within 
DHS contacts the ORR Intake Operations Team (hereinafter  referred to  
as the intake team). The intake team requests information about the 
child, including gender, age, country of origin, date and location of  
apprehension, medical and mental condition, and criminal history. The  
intake team records this information in the Tracking Management 
System (TMS).9  The intake team then contacts a DUCS-funded facility, 
typically close to where DHS apprehended the child, to arrange 
placement. 
At the time of our review in 2006, DUCS funded 36 facilities and 
programs to place and care for children in its custody.  Facilities, 
ranging from lowest to highest restriction levels, are shelter,  
 
7 6 U.S.C.  552(a). 

8 Ibid., Case No. CV 85-4544-RJK (C.D. Cal. 1996). 

9 The Tracking  Management System is an electronic database containing records for all 

children in the Division of  Unaccompanied Childrens Services (DUCS)  custody.  It includes 

information such as dates of apprehension, placement, and  release; type of placement; and 
 
discharge reason (e.g., released to a sponsor, voluntary departure, or ordered removed). 

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staff secure,10 or secure.  Facilities vary in terms of whom they serve 
(e.g., age, gender, and/or nationality of children),  duration of placement,  
type of accommodation (e.g., house in neighborhood versus 
multiple-building campus), and size of the program (e.g., single program  
versus a part of a large nonprofit conglomerate). Facilities are located 
throughout the United  States but are concentrated along the southwest 
border. Some facilities had contracted previously with INS, while 
others have worked only with DUCS. DUCS also funds foster care  
programs, which typically involve placements with families.  Foster care 
is typically reserved for initial placements of younger children or for 
children who have resided at a facility for several months without being 
released to  a sponsor. For simplicity, we will refer to all DUCS-funded 
placement options, whether shelters, staff-secure or secure facilities, or 
foster care programs, as facilities. 
In accordance with the Flores Agreement, DUCS must place a child in 
the least restrictive facility setting possible unless information collected 
about the child indicates that he or she requires  a specific placement.  
The Flores Agreement specifies circumstances under which children 
may be placed in staff-secure or secure facilities, such as when DUCS 
determines that a child has been charged, is chargeable, or has been 
convicted of a crime; has committed, or has made credible threats to 
commit, violent or malicious acts while in custody; has engaged in 
disruptive behavior; is a flight risk; or must be kept in a secure facility 
for his or her safety.  Most commonly, children are placed in shelters. 
The intake team provides information about the child collected from 
DHS to the facility and then contacts DHS to arrange transportation of 
the child to the facility.  
Care 
Facilities have the lead responsibility for determining childrens care 
needs and ensuring that these needs are met. Care includes physical 
care, suitable living accommodations, food, appropriate clothing, 
personal hygiene, medical care, dental care, educational services, 
 
10 Staff-secure  facilities use staff supervision rather than architectural barriers, such as the  
barred  windows or locked doors used in secure facilities. A staff-secure placement might be 
used for a child  who is a flight risk, for example. A child who is a flight  risk might be too 
difficult for a shelter to handle, but such behavior does not warrant being placed in a secure 
facility. A staff-secure facility would provide the heightened level of supervision needed to 
prevent a child  from running away. 
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mental health services,  recreation and leisure activities, acculturation, 
and adaptation services.   
Federal field specialists and field coordinators also have a role in 
ensuring that children receive appropriate care.   Federal field 
specialists are employees of DUCS tasked with ensuring that children 
receive needed services, as well as ensuring that facilities and field 
coordinators are interpreting and following DUCS policies and 
procedures correctly.11  Field coordinators are employees of voluntary 
agencies that contract with DUCS.12 These individuals advocate on  
behalf of unaccompanied alien children and work with facilities to 
ensure that children receive needed  services.  Both Federal field  
specialists and field coordinators are located throughout the country, 
each working with facilities within a specific geographic region.  
DUCS policies and procedures require that each childs case file include 
assessments and records of care provided for medical, mental health, 
education, training, and recreation needs.  DUCS policies and 
procedures require that facilities identify care needs by completing 
DUCS-required formsthe Initial Intake Form, the Admissions 
Assessment, and the Psycho-Social Summary and Individual Service 
Plan. 
Initial Intake Form. A staff person at the facility must complete the Initial 
Intake Form within 24 hours of a childs placement at the facility.  The 
form is used to determine the childs  basic and immediate care needs.  
The assessment also helps establish whether the child has a family 
member in the United States who might serve as a sponsor.  
Admissions Assessment. A masters-level social worker (or equivalent) 
must complete the Admissions Assessment within 3 to 7 days of 
placement, after reviewing the Initial Intake Form.  This assessment 
builds on the Initial Intake Form and more completely collects 
biographic, family, legal/migration, medical, and/or any substance abuse 
or mental health histories. 
 
11 Federal field specialists assist facilities with identifying  community resources and  give  
final approval to release recommendations.  The position of Federal field specialist is 
relatively new,  and at the time of our review, some individuals had been in their jobs for 
less than a year.  
12 DUCS administers its program,  in part, by contracting with two  faith-based voluntary 
service agencies:  the United States Conference of Catholic Bishops and the Lutheran  
Immigration  and Refugee Services. 
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Psycho-Social Summary and Individual Service Plan. A masters-level  
social worker (or equivalent) must complete the Psycho-Social Summary 
and Individual Service Plan within 7 to 10 days of placement. The 
Psycho-Social Summary uses information gathered from the Initial 
Intake Form and Admissions Assessment and summarizes the childs 
strengths, stressors, and presenting  problems. The Individual Service 
Plan addresses the childs identified needs. Additionally, items from the  
Admissions Assessment are transferred to the Individual Service Plan, 
and action steps with completion dates are identified to address those 
needs. The Individual Service Plan should be reviewed and updated  
periodically. 
Unless specifically noted, we will hereinafter refer to the Initial Intake 
Form, Admissions Assessment, and the Psycho-Social Summary and  
Individual Service Plan collectively as assessments. 
Release 
Releases to  sponsors are often termed family reunifications. Children 
may provide the name  of a potential sponsor when apprehended, during 
intake, and/or when completing the assessments. The facility has the 
lead responsibility for initially assessing these potential sponsors. In 
accordance  with the Flores Agreement, the following order of preference  
is used when seeking a sponsor: a parent, a legal guardian, an adult 
relative, an  individual or entity designated by the parent or legal 
guardian, a licensed program willing to accept legal custody, or an adult 
individual or entity not previously mentioned seeking custody. 
Once a potential sponsor is identified, the facility sends that person a 
family reunification packet. The packet requires that the potential 
sponsor provide information such as relationship to the child, age, 
gender, address, household composition, employment status, and  
immigration status. The potential sponsor also undergoes a fingerprint 
background check against the Federal Bureau of Investigations 
National Crime Information Center database, the Central Index 
System, and the Deportable Alien Control System. 
Once all information is collected and reviewed and the facility deems 
the potential sponsor appropriate, the facility makes a recommendation 
for release and the family reunification packet is forwarded to the field 
coordinator. In cases in  which a child may be a potential victim of 
trafficking or for other specific reasons, facility staff and/or field 
coordinators may recommend that the sponsor receive a Suitability 
Assessment, which is a more detailed assessment of a potential sponsor 
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including a home visit by a staff member.13  If no Suitability Assessment 
is recommended, the field coordinator reviews all information that the 
facility submitted and either requests additional information or makes a 
recommendation to the Federal field specialist for release.  The Federal  
field specialist makes the final determination as to whether to release 
the child to  a sponsor.   Once the sponsor is approved, DUCS releases 
the child to  the sponsor, thus ending DUCS custody of that child and its 
responsibilities for care.14  Even though a child is released to a sponsor,  
immigration proceedings continue and the child remains in the United 
States with no lawful immigration status.  
DUCS requires a sponsor to sign a Sponsors Agreement to Conditions of 
Release form (sponsor agreement) indicating that he or she will assume 
responsibility for the childs physical, mental, and financial well-being; 
for the child appearing at all immigration proceedings; and for the child 
reporting for removal from the United States if so ordered.  Other 
sponsor agreement requirements include reporting changes  of residence  
to DHS within 5 days; receiving written permission from DHS to 
transfer custody of the child to another person; and notifying DHS as 
soon as possible but within 72 hours  if the child has disappeared, has 
been threatened, or has been contacted in any way by an individual(s) 
believed to represent an alien-smuggling syndicate or organized crime.   
In signing the sponsor agreement, the sponsor agrees to the following:  
I further understand that [DHS] may refer the minor to ORR, and ORR 
may resume custody if I do not comply with the conditions of the release 
agreed to in this form. 
Policies and Procedures 
Prior to June 2006, DUCS had a draft policies and procedures manual 
that was periodically updated with transmittals from the DUCS central 
office.  On June 1, 2006, DUCS issued a single manual that consolidated 
all the policy- and procedure-related materials.  The  manual (as did the  
former manual and transmittals) addresses such topics as what 
 
13 A Suitability Assessment is coordinated through the DUCS central office with one of the 
voluntary agencies.  A staff person from the voluntary agencys field office performs the 
Suitability Assessment, visiting  the potential sponsors home, observing the condition of the 
home, determining  where specifically the child would live, and interviewing other  
individuals living in the home.  The staff person summarizes his or her observations and  
the interview responses to support his or her conclusion as to whether placement with the 
potential sponsor would serve the best interests of the child.  
14 If no sponsor is available, the child remains in DUCS custody until a final immigration 
determination is reached or the child attains age 18. 
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information facilities should maintain in their case files, what 
assessments facilities should complete and how quickly those 
assessments should be completed once children are placed, how facilities 
should use information  obtained from the assessments to provide care  
for children, and how facilities should screen potential sponsors. 
METHODOLOGY 
This study used four primary methods: (1) analyses of placement and 
release and timeframes for children placed in DUCS-funded facilities 
during specific periods; (2) a review of case files for 100 randomly 
selected children physically placed at DUCS-funded facilities from 
April 1 through September 30, 2006; (3) structured interviews with 
directors and other key staff of the 22 facilities where at least 1 of the 
100 randomly sampled children had been placed; and (4) structured 
interviews with Federal field specialists, field coordinators,  key officials 
in the DUCS central office, and  officials from the voluntary  agencies  
central offices. 
Analyses of Placements and Releases 
At the time we received the complete TMS database, it contained 
26,030 records of placements. We used the admission dates to identify 
the 4,235 children who were physically placed (admitted) in  
DUCS-funded facilities from April 1  through September 30, 2006. This 
period reflected the most recent, complete 6-month period at the time  
we received the TMS data and allowed us to review the most current  
practices of DUCS and facilities (e.g., completion of assessments, 
provision of  care) at the time we conducted our review. We determined  
the placement types (e.g., shelter, secure, foster care) and average time 
from apprehension to admission for the children admitted to 
DUCS-funded facilities during this 6-month period. 
Separately, we used the admission dates listed in TMS to identify the 
3,937 children who were admitted into facilities from October 1, 2005, 
through March 31, 2006. We used this period because DUCS officials 
informed us that most children are, on average, in DUCS-funded  
facilities for 45 days. All of the children admitted during this 6-month 
period would have been admitted to a facility at least 6 months prior to  
our receiving the TMS data, meaning that a significant majority of them 
should have been released from their respective facilities. We 
determined the durations of stays in DUCS-funded facilities for the 
children admitted during this 6-month period. 
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I N T R O D U C T I O N   
Case File Reviews 
From the population of 4,235 children who were admitted into 
DUCS-funded facilities from April 1 through September 30, 2006, we 
randomly selected 100 children. We conducted site visits at all 
22 facilities that provided direct care for at least 1 of the 100 sampled 
children.  Of the 22 facilities, 16 were shelters, 2 were staff-secure 
facilities, 1 was a secure facility, and 3 were foster care programs.  
Although we observed children during onsite visits at some facilities, we 
did not speak with children about their care and treatment while in 
DUCS custody. Prior to  reviewing the sampled case files, we  confirmed 
with facility staff that they had provided to us the complete  case files for 
all sampled children and that these case files contained all 
documentation that DUCS policies and procedures required.  We  
reviewed case files for assessments  and other documents related to  
health, mental health, education, recreation, and family reunification, 
as well as for cover sheets, progress notes, and case notes indicating 
that children received services. 
We excluded from our analyses four case files for children who had been  
determined to not meet the definition of unaccompanied alien children 
or were in a DUCS-funded facility for fewer than 10 days (the amount of  
time DUCS policies and procedures allow facilities to complete the last 
of the required assessments) and whose case files lacked all required 
assessments.  When we analyzed all 96 remaining case files, we 
projected the results to the universe of children admitted to facilities 
from April 1 through September 30,  2006.  Confidence intervals for 
these projections can be  found in Appendix B.   When we analyzed  
subgroups from the sample, such as the 46 children released to sponsors 
at the time  we drew our sample, we  did not project our results to the 
universe.  
Facility Staff Interviews  
At the 22 facilities that had at least 1 of the 100 sampled children, we  
conducted structured interviews with the facility directors.  At some 
facilities, we also interviewed case managers, counselors, clinicians, 
and/or medical coordinators (or similar individuals).  Topics that we  
discussed included the following: 
 	  the number of children the facility served and scope of services at 
  the facility; 
 	  the facilitys primary goals in working with unaccompanied alien 
children; 
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 	  the way in which the facility learned about pending placements; 
 	  the way in which the facility identified needs and provided care; 
 	  the processes the facility used for release, sponsor background 
  checks, and suitability assessments; and 
 	  recommendations the facilities had for improvement. 
Although we may have interviewed multiple staff members at each 
facility, we catalogued the responses as one per facility for the purposes 
of our analysis. Therefore, each of the 22 facilities is represented once 
regardless of how many  people we interviewed. 
Federal Field Specialist, Field Coordinator, and Central Office Interviews  
We interviewed all Federal field specialists and field coordinators who 
had responsibility for the facilities in our sample, resulting in  
interviews with 9 Federal field specialists and 10 field coordinators. We  
asked about their experiences in working with unaccompanied alien 
children and facilities; their interactions with each other; and their roles 
and responsibilities related to placement, care, and release of 
unaccompanied alien children. We used these interviews to supplement 
the information gathered from case file reviews and facility staff 
interviews. 
We interviewed key officials in the DUCS central office and the 
voluntary agencies. We used these interviews to support or contrast 
information obtained through case file reviews and facility staff, Federal 
field specialist, and field  coordinator interviews.    
Standards 
This study was conducted in accordance with the Quality Standards for 
Inspections issued by the Presidents Council on Integrity and 
Efficiency and the Executive Council on Integrity and Efficiency. 
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  F I N D I N G S  
Most chi ldren appeared to be placed  Absolute adherence to the Flores  
and released in accordance with the  Agreement is difficult to 
determine because the Agreement 
Flores Agreement 
established some criteria specific 
to INS.  Additionally, the Agreement at times uses terminology for 
placement and release that is nonspecific and subject to interpretation.  
Still, DUCS appears to be placing and releasing children in accordance 
with the Flores Agreement.  
Eighty-four percent of children were admitted to facilities within 3 days of  
apprehension and less than 4 percent of children were placed in staff-secure 
or secure facilities 
The Flores Agreement specifically requires that a child be placed in a 
facility within 3 days if the child is apprehended in an INS district in 
which a licensed program is located and has space available and within 
5 days in all other cases, except for specific situations, such as during an 
emergency or influx of minors, in which case children should be placed 
at facilities as expeditiously as possible.  However, a single agency no 
longer has responsibility for both the apprehension and placement of 
children.  DHS must transfer children to DUCS to make the placement 
decisions rather than determining placements itself.  Despite the 
transfer of children from DHS to DUCS, TMS data indicate that 
84 percent of children admitted into facilities from April 1 through 
September 30, 2006, were admitted within 3 days of apprehension, and 
94 percent were admitted within 5 days of apprehension.  TMS data did  
not enable us to determine whether  the 10 percent of placements that 
occurred after 3 days but within 5 days of apprehension fell within the 
all other cases criteria that the Flores Agreement established or  
whether the remaining 6 percent of placements that occurred after 
5 days of apprehension fell within the established exceptions. 
The Flores Agreement also specifies that children should not be placed  
in a staff-secure or secure facility if less-restrictive alternatives are 
available and appropriate.  For children initially admitted to facilities 
from April 1 through September 30,  2006, TMS data indicate that 
3.7 percent  of children were placed in staff-secure or secure facilities.  
Of these children, 89 percent had  information in their TMS records 
supporting these placements.  Common reasons for staff-secure and 
secure facility placements included  children being flight risks, having 
been convicted of crimes, having criminal charges pending against 
them, or exhibiting violent or disruptive behavior. 
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F I N D I N G S  
During the review period for the 2001 Department of Justice OIG 
report, INS contracted with 57 secure facilities.  INS lacked sufficient 
shelter placement options to avoid placing children in secure facilities 
during periods of influx.  Delinquent and nondelinquent children were 
often commingled at these secure facilities.15  DUCS has reduced the  
number of secure facilities (to two during our review period), meaning 
that DUCS is unlikely to place children at secure facilities during 
periods of influx. 
Most children were released quickly,  and reviewed case files often 
contained evidence of reunification packets 
Section VI  of the Flores Agreement is entitled General Policy Favoring  
Release, and states that children should be released from Federal 
custody without unnecessary delay. TMS data that we received in 
mid-October 2006 indicate that for children admitted to facilities from 
October 1, 2005, through March 31, 2006,16 61 percent were released to 
sponsors, on average, within 30 days.  Of these children, 42 percent  
were released to a parent and an additional 51 percent were released to 
another relative (e.g., aunt or uncle, brother or sister).  TMS data also 
indicate that 99 percent  of all children had been discharged from  
the facility at the time we received the data for various reasons 
(e.g., released to a sponsor, ordered removed, voluntarily departed, or  
aged out), on average, within 39 days.  The remaining 1 percent of 
children remained in DUCS custody. 
At the time  we selected  our sample, 46 of the 100 sampled children had  
been reunified with sponsors, while an additional 34 were no longer at 
the original facilities for various reasons, such as being ordered removed 
as a result of immigration proceedings or voluntarily choosing to depart  
the United  States.  (See Appendix C for the status of sampled children 
at the time we received TMS data to draw our sample.)  Case files for  
43 of the 46 children reunified with sponsors contained  evidence of 
facilities assessments of potential sponsors through the use of 
reunification packets. 
 
15  The 2001 Department of Justice OIG report, Unaccompanied Juveniles in INS 
Custody, I-2001-009, discussed the placement of juveniles in secure facilities during 
periods of influx and contained recommendations addressing the segregation of  
nondelinquent juveniles from  delinquent  juveniles and the placement of children in secure 
facilities. 
16 The 6-month period of October 1, 2005, through March 31, 2006, was used for the release 
analysis to allow time for children to be released from DUCS-funded facilities.  
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F I N D I N G S  

 
Case file  s lacked documentation of  We could not determine whether  
assessments completed and   the lack of documentation in case 
files was a result of poor record 
care received  
keeping or failure to provide 
services.  During interviews, facility staff indicated that they completed 
required assessments, that children received services to address 
identified care needs, and that documentation of these activities would  
be found in case files.  Additionally, staff from 14 facilities indicated 
that the assessments were useful and had realistic timeframes for 
completion.  Still, all case files lacked at least one of the DUCS-required 
documents  used to assess care needs or document care provided.   
Overall, 56 percent of case files lacked one or more of the required 
assessments used to gather information about childrens needs 
Although 4 percent of case files did not contain the Initial Intake Form, 
which is the assessment to be completed within 24 hours of a child being 
admitted to a facility, 36 percent of case files lacked the Admissions 
Assessment (to be completed within 3 to 7 days of admission), and 
44 percent lacked the Psycho-Social Summary (to be completed within 
7 to 10 days of admission). (See Table 1 below.)  The Individual Service 
Plan, which is based largely on the results of the other assessments and 
serves as a primary tool for documenting and tracking care provided, 
was missing from 46 percent of case files. 
 
Table 1:  Case Files Missing Documentation of Assessments 
60% 
s  50% 
e
Fil
e  40% 
s
a
C
of  30% 
e 
g
a
nt 20% 
e
c
r
e
P 10% 
0% 
Initial Intake Form  Admissions  Psycho-Social  Individual Service  Files missing at 
Assessment  Summary  Plan  least one 
assessment 
Types and Status of Assessments 
Source: OIG, 2007. 
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F I N D I N G S  
All case files lacked at least one required document that  would indicate that 
children received medical or mental health services or participated in 
educational or recreational activities 
Seventy percent of case files did not contain cover sheets with dates of 
services, 55 percent did not contain progress notes related to medical 
and mental health care, and 45 percent did not contain case notes that 
described activities and services associated with care.  (See Table 
2 below.) 
 
Table 2:   Case Files Lacking Documentation of  Service  Provision 
 
 
80% 
70%   
s
e
Fil 60%   
e 
s 50% 
a
C  
of  40% 
 ge  30%   
a
nt
e 20%   
c
r
e
P 10% 
 
0% 
Group    Cover sheets Recreational  Individual  Progress  Educational  Case 
counseling  activity log  counseling  notes   record  notes/log 
notes    notes 
  Required Docum ents 
 Source:  OIG,  2007. 
 
Although facility staff stressed that  most children experienced serious 
trauma during their journey to the United States or had mental health 
issues prior  to their arrival, case files often lacked information about 
mental health treatment.  Seventy-five percent of case files did not 
contain group counseling notes,  and 56 percent did not contain 
individual counseling notes. 
When conducting our scheduled site visits, we commonly saw 
classrooms and observed children participating in educational activities, 
yet 50 percent of case files did not contain educational records.  We also 
observed recreational areas and equipment, such as soccer fields, 
basketball hoops, and game tables, yet 58 percent of case files did not 
contain evidence of participation in recreational activities.   
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In contrast to the documentation of ongoing services, services that 
children received less frequently or only once were less likely to be 
missing required documentation. For example, only 7 percent of case  
files did not contain immunization records, 17 percent did not contain 
initial medical exams, and 20 percent did not contain educational 
assessments. 
 
Interviews with DUCS central 
The Division of Unaccompanied 
office officials indicate that little 
Ch ildrens Services provides limited 
oversight of facilities occurs.  
oversight of facilities 
They stated  that the lack of 
central office staff and 
standardized review protocols limited centralized oversight.  Federal 
field specialists and field coordinators indicated that they routinely visit 
facilities and therefore could assist in the oversight of facilities.  
However, only one Federal field specialist reported conducting any 
oversight activities. Federal field specialists and field coordinators do  
not routinely meet individually with  children to  ensure that facilities 
are addressing their care needs. Finally, DUCS does not have a method  
to determine whether the processes facilities use to screen sponsors are 
effective at ensuring safe reunifications. 
Federal field specialists  interactions with facilities typically do not include 
oversight of those facilities 
Federal field specialists are tasked  with ensuring that children receive 
needed services and that facilities are interpreting and following DUCS 
policies and  procedures correctly. However, only one Federal field  
specialist noted providing facility oversight through audits of case files. 
Another Federal field specialist explained that although she may 
interact with facilities regarding policy and oversight, she lacks 
authority during these interactions. DUCS officials confirmed that 
Federal field specialists are leaders without authority and that their 
current responsibilities focus on capacity building (e.g., identifying 
community resources and assisting facility staff and field coordinators 
with interpreting DUCS policies and procedures).  
Federal field specialists and field coordinators do not routinely meet with 
children to determine whether facilities are meeting their individual care 
needs 
Federal field specialists and field coordinators reported seeing children  
when they visit facilities; they do not routinely meet with children to 
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F I N D I N G S  
discuss the services or care they  receive.  Overall, 12 Federal field 
specialists and field coordinators reported meeting with children but 
indicated that those meetings were only on an as-needed basis (i.e., for  
nonroutine or special needs cases).  Six out of ten field coordinators 
and four out of nine Federal field specialists described their interactions 
with staff and children to be related to reunification, not to service 
provision or receipt of care.  Case files did not contain documentation 
indicating whether or when Federal field specialists and field 
coordinators met with children to ensure their well-being or worked 
with facility staff to ensure that children received needed services.17    
The 2001 Department of Justice OIG report found that INS staff were 
not meeting with children residing at facilities and recommended that 
weekly meetings with all children take place to  ensure childrens 
well-being. In its response to the report, INS indicated that it had a 
policy requiring that appropriate staff visit children on a weekly basis 
but noted that staffing and distances between facilities and INS offices 
presented  challenges to meeting this requirement.  INS stated that it 
would work to identify resources and opportunities to more fully comply 
with its requirement.  In the 2004 DHS OIG report following up on the 
Department of Justice OIG report recommendations, DHS OIG 
designated HHS as responsible for addressing this recommendation.  
However, the DUCS policies and procedures do not require Federal field  
specialists and/or field coordinators  to routinely meet with children 
individually. 
DUCS does not have methods to determine whether facilities sponsor 
screenings are effective and whether sponsors are providing for the 
childrens physical, mental, and financial well-being 
Although our case file review and interviews show that considerable 
time and effort are put into the reunification process, DUCS is unable to 
determine whether the processes facilities use to  screen sponsors are 
effective because DUCS rarely gathers information about children or 
sponsors after reunification.  Additionally, despite establishing the 
sponsor agreement, which would require some form of followup to 
ensure compliance, DUCS does not formally follow up with sponsors to  
ensure that sponsors are providing for childrens physical, mental, and 
 
17 While  we were  conducting this  study, DUCS closed a facility due to allegations that a 
facility staffer was sexually abusing children.  The Federal field specialist and the field 
coordinator who covered this facility indicated that they interacted with the children while 
they were at the facility, but that meetings with  children were not routine. 
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financial well-being or meeting the other conditions of the sponsor 
agreement except in limited circumstances (e.g., when a Suitability 
Assessment is conducted). DUCS officials stressed that once a child is 
released, DUCS custody and therefore responsibility for that child ends. 
 
No explicit agreement exists between Federal  At the time of the Flores  
Departments regarding information exchange and  Agreement, children were in 
the care and oversight of just 
postrelease activities 
one Federal Department  
from the time of apprehension until the completion of immigration 
proceedings. When responsibilities were divided between DHS and 
HHS, no formal MOU was established to clarify each Departments  
specific roles. Although the two Departments established a Statement 
of Principles in 2004, it states that [t]his document does not resolve all 
outstanding issues. . . .  
The Departments lack a specific agreement for exchanging information 
when children are transferred for initial placement 
The intake team reported that the information it  receives from DHS 
during a standard initial placement is typically limited and therefore 
the information provided to facilities prior to a standard initial 
placement is often limited.18 Staff from 13 facilities indicated that they 
receive little or no information about a child prior to the childs arrival 
at the facility, or that the information they do receive is limited to basic 
demographic information (e.g., age,  gender, country of origin, location of  
apprehension). Facility staff commonly expressed a desire to receive 
more information, with a few citing specific information such as medical  
and mental health conditions or behavioral issues.   
Two examples of not receiving important information were provided by 
facilities. In one case, a facility received a child with a broken leg and in 
a wheelchair; in the other, a facility received a child who had been in a  
car accident prior to apprehension and needed follow-up medical 
attention. Although these circumstances would not have changed the 
placement at each respective facility, having the medical information 
 
18 The exception to the lack of information exchange during placement occurs when  
children are placed in staff-secure or secure facilities. Reportedly, these children often have  
been apprehended in the United States interior and turned over to Federal officials after 
having spent time in a local jail. Thus, DHS and DUCS have  more information about the  
child prior to initial placement. 
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would have allowed the facility to be prepared for meeting these 
childrens immediate needs. 
DUCS informed us of a pilot program underway to improve information 
exchange. According to the intake team, the DHS apprehending officer  
completes a detailed form about an apprehended child. This 
information is forwarded to a DHS juvenile coordinator, then to DUCS 
to assist in the placement of the child. The intake team said that it 
believes this approach will provide more complete information on the 
child, alleviate errors, and, if a breakdown of information exchange does  
occur, make it easier to hold individuals accountable for providing 
incomplete or inaccurate information. 
Responsibility for ensuring safe release and compliance with the sponsor 
agreement is undefined  
The 2005 DHS OIG report found fault with the DUCS reunification 
process.   The report included examples of releases that DHS believed  
were questionable. DHS believed these releases could be unsafe for 
children and/or lead to children failing to appear at immigration 
proceedings. The report recommended that the appropriate DHS 
agency request the appropriate HHS agency to  enter into an MOU to  
address respective responsibilities for unaccompanied alien children.  
The recommendation went on to state that the MOU should contain 
specific requirements for release, including mandatory record checks on 
potential juvenile sponsors.19  
DUCS began requiring sponsor fingerprint background screenings as of 
October 1, 2006, which addresses some of the DHS OIG report concerns. 
However, with respect to the DHS concerns that reunifications were at 
times unsafe or led to  children failing to appear at immigration 
proceedings, DUCS custody of children ends when family reunifications 
occur. The lack of a specific agreement leaves unclear which entity has 
responsibility for ensuring that children remain safe and that sponsors 
continue to  comply with sponsor agreements. 
 
19 A Review of  DHS Responsibilities For Juvenile Aliens, DHS,  OIG, OIG 05-45,  
September 2005. 
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  R E C O M M E N D A T I O N S  
Although DUCS appears to be placing and releasing children in 
accordance with the Flores Agreement, all case files lacked at least one 
of the DUCS-required documents to  assess care needs or document care 
provided.  As such, we  could not definitively conclude that all children 
were receiving all needed services.  DUCS officials acknowledged a lack  
of program oversight, and no method exists to ensure that children 
remain with sponsors and that sponsors comply with sponsor 
agreements.  Finally, no  explicit agreement exists between HHS and  
DHS with regard to each Departments specific roles and 
responsibilities and their shared responsibilities with respect to 
exchanging information and monitoring children once they are released  
to sponsors.  
Therefore, we recommend that DUCS: 
Enforce Documentation Requirements To Ensure That Needs Are Assessed 
and Care Provided 
DUCS should develop a standardized protocol and use it to  conduct 
regular, periodic onsite visits to all facilities to ensure adherence with 
policies and procedures and completeness of case file documentation.  
These efforts should focus on documents that assess care needs and 
demonstrate care provided. 
Define and Enhance Field Staff Roles in Ongoing Oversight 
The roles and responsibilities of Federal field specialists and field 
coordinators should be expanded to include not only release activities 
but oversight of childrens care.  One method for ensuring that children 
are receiving needed services would be for DUCS to require Federal 
field specialists and/or field coordinators to regularly meet with all 
children individually to ensure that each child is safe and is receiving 
needed care.  
Establish a Memorandum of Understanding 
Building on the Statement of Principles, HHS officials should develop 
a formal MOU with DHS to clearly delineate the roles and 
responsibilities of each Department.  At a minimum, the MOU should 
address the following: 
 	 Each entitys specific responsibilities for gathering and exchanging 
information when a child comes into Federal custody and is placed  
into a DUCS facility.  DUCS could use the results of the pilot  
project, which is intended to improve the completeness and accuracy 
of information that DHS collects and provides to DUCS, to  
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R E C O M M E N D A T I O N S  
determine how information is best exchanged to meet childrens 
needs. 
 	 Each entitys specific responsibilities for gathering and exchanging 
information about children who have been reunified with a sponsor 
to ensure that children are safe and that sponsors are adhering to 
agreements.  Officials should develop a process to sample and collect 
information regarding the outcomes  of family reunifications, such as 
whether children remain with sponsors and participate in 
immigration proceedings, and whether sponsors  remain in  
compliance with sponsor agreements.  Given that many children are 
released to  parents and the majority of children are released to 
relatives, officials may want to take these releases into 
consideration when determining with which sponsors to follow up 
and how often.  
AGENCY COMMENTS 
In its written comments on the draft report, ACF did not indicate  
whether it concurred with our recommendations.  ACF did indicate that 
it agrees that more monitoring of facility documentation and practices is 
needed; that ORR will include random interviews with children and 
case file reviews as part of the routine responsibilities for Federal field 
specialists; and that ORR is drafting a Joint Operations Manual with 
DHS, with the ultimate goal of drafting an MOU. 
ACF provided information that calls into question our finding regarding 
lack of case file documentation.  ACF stated, It is also important to 
note that many facilities keep documentation of group counseling notes 
and recreational activities separate from individual case files, and In 
general, the case files reviewed by ORR contain the required 
documentation, as per ACF policies and procedures.   
Also, in reference to our finding regarding responsibility for postrelease 
activities, ACF stated that ORRs statutory mandate to ensure the 
well-being of an unaccompanied alien child ends at the time the child is 
released from ORRs care.  ACF points out that ORR is working on 
developing a Joint Operations Manual with DHS as a first step toward 
drafting an MOU to address legal issues. 
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R E C O M M E N D A T I O N S  

OFFICE OF INSPECTOR GENERAL RESPONSE 
Prior to reviewing sampled case files  at each facility, we verified with 
facility staff that these case files were complete.  Although some 
facilities did maintain separate files for such things as medical care, 
education, and counseling, those facilities consolidated the files for our 
review. When asked, facility staff confirmed that case files we reviewed  
should have contained all required documentation.  We have revised the 
report methodology to clarify that facilities reported that they had 
provided  to us the complete case files for our sampled children. We 
continue to support our finding regarding missing case file 
documentation and our recommendation related to enforcing  
documentation requirements. 
In its 2005 report, DHS OIG reported DHSs concerns about ACFs 
release of children to sponsors.  These concerns imply that DHS believes  
that it is ACFs responsibility to ensure proper and safe release of 
children.  ACF stated that its statutory mandate to ensure the well-
being of unaccompanied alien children ends at the time children are 
released from ORRs care.  Neither agency appears to be monitoring or 
taking responsibility for monitoring children or sponsors postrelease, 
which is what prompted, in part, our recommendation that HHS enter 
into an MOU with DHS.  Although we support ACFs efforts to draft a 
Joint Operations Manual, we urge  development of a formal MOU with 
DHS to clearly delineate the roles and responsibilities of each 
Department. 
Finally, ACFs descriptions of current activities do not specifically 
address our recommendations and therefore it is unclear whether and  
how ACF intends to implement our recommendations.  We ask that, in 
its final management decision, ACF indicate whether it concurs with 
our recommendations and what steps, if any, it will take to implement  
them.  The full text of ACFs comments can be found in Appendix D. 
 
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  A P P E N D I X   ~   A
 
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   A P P E N D I X   ~   B
Confidence Intervals for Key Estimates 
Point   Confidence Interval 
Finding  Ratio 
Estimate  95 Percent 
Case  files that lacked one or more required assessments  56.2%  46.1%-66.4%  54/96 
Case  files that lacked an Initial Intake Form  4.2%  0.1%-8.2%  4/96 
Case  files that lacked an Admissions Assessment  36.4%  26.6%-46.3%  35/96 
Case  files that lacked a Psycho-Social Summary  43.8%  33.6%-53.8%  42/96 
Case  files that lacked an Individual Service Plan  45.8%  35.7%-56.0%  44/96 
Case  files that lacked cover  sheets  69.8%  60.4%-79.1%  67/96 
Cases files that did not contain progress notes  55.2%  45.1%-65.3%  53/96 
Case  files that did not contain case notes  44.8%  34.7%-54.9%  43/96 
Case  files that did not contain group counseling notes  75.0%  66.2%-83.8%  72/96 
Case  files that did not contain individual counseling notes  56.2%  46.1%-66.4%  54/96 
Case  files that did not contain education records  50.0%  39.8%-60.2%  48/96 
Case  files that did not contain evidence of recreational activities  58.3%  48.3%-68.4%  60/96 
Case  files that did not contain immunization records  7.3%  2.0%-12.6%  11/96 
Case  files that did not contain initial medical exams  16.7%  9.1%-24.2%  20/96 
Case  files that did not contain educational assessments  19.8%  11.7%-27.9%  23/96 
 
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 A P P E N D I X   ~   C
AAAA AAAAAAAAA PPPPPPPPPPPPP PPPPPPPPPPPPP EEEEEEEEEEEEE NNNNNNNNNNNNN DDDDDDDDDDDDD IIIIIIIIIIIII XXXXXXXXXXXXX               ~~~~~~~~~~~~~               BBBBBCBCCCCBB              
 A P P E N D I X   ~ B  
Status of Unaccompanied Alien Children 
      at Time of Sample Selection 
 
 
Status  Number 
 
Released to sponsor  46 
 
Not released (in facility at time sample drawn)  20 
 
Returned (ordered removed)  18 
 
Returned (voluntary departure)  5 
 
Adult status (age redetermined)  3 
 
Immigration status changed (accompanied)  3 
 
Transferred to a different facility  2 
 
Adult status (aged out)  2 
 
Immigration status changed (other)  1 
 
Source:  Office of Inspector General, 2007. 
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A P P E N D I X   ~   A  
 A P P E N D I X   ~   D  
Agenc y Comments 
 
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A P P E N D I X   ~   D  
 
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A P P E N D I X   ~   D  
 
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A P P E N D I X   ~   D  
 
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  A C K N O W L E D G M E N T S
This report was prepared under the direction of Brian T. Pattison, 
Regional Inspector General for Evaluation and Inspections in the 
Kansas City regional office, and Gina C. Maree, Deputy Regional 
Inspector General.  Other principal Office of Evaluation and Inspections 
staff from the Kansas City regional office who contributed to the report 
include Emily Meissen, Amber Meurs, and Dennis Tharp; central office 
staff who contributed include Kevin Farber, Alan Levine, Elise Stein,  
and Barbara Tedesco.  
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