U.S. Department of Health and Human Services 
 Office of Inspector General 
 
May 2021, OEI-09-21-00220 
 
 
 
Toolkit: Insights From OIGs Work on the Office of Refugee 
Resettlements Efforts To Care for Unaccompanied Children 
This toolkit compiles insights from the Office of Inspector Generals (OIGs) oversight of the 
Unaccompanied Children Program.  The insights provided are largely drawn from the findings, 
recommendations, and conclusions in OIGs body of work conducted since 2008, including reports that 
were issued following site visits at 45 facilities during the 2018 surge of children entering the 
Unaccompanied Children Program. 
The insights provided in this toolkit focus on three priority areas: (1) ensuring that the Department of 
Health and Human Services (HHS) is prepared to take unaccompanied children into custody as they are 
transferred from immigration officials; (2) protecting children in HHS custody from harm; and 
(3) addressing childrens medical and mental health needs.  A complete list of OIGs public reports on 
the Unaccompanied Children Program is included on pages 8 and 9 of this toolkit.  Details about OIGs 
ongoing oversight are available in our Work Plan. 
The number of unaccompanied children apprehended at the U.S. border has surged during the first 
months of 2021, as it has many times over the last decade.  In order to respond to the 2021 surge, HHS 
has added capacity at State-licensed facilities and has opened new influx care facilities and emergency 
intake sitestwo types of facilities that are not required to be State-licensed.  Because these new 
facilities are established quickly and may have staff with limited training, they can benefit from 
additional focus and oversight.  This toolkit outlines consequential actions that HHS program officials 
and facility administrators can take to ensure the health and safety of children in care, especially 
children at these new facilities.  This toolkit contains information that may be relevant for other 
policymakers as well. 
OIG has identified numerous aspects of the Unaccompanied Children Program that require attention, 
but a few key items warrant highlighting.  Given the increase in the number of children in HHS custody, 
immediate actions that the Office of Refugee Resettlement (ORR)the office within HHSs 
Administration for Children and Families that administers the programcan take to ensure childrens 
health and safety include: 
  Coordinating with local and Federal law enforcement agencies when opening new facilities 
that are not State-licensed in order to identify the entities that will provide emergency 
response services. 
  Maintaining the significant incident reporting system and ensuring that facility staff have clear 
training on how to effectively report safety incidents. 
  Ensuring that facilities meet requirements for pre-employment background screenings, 
including conducting timely background checks for new employees. 
  Taking all reasonable steps to minimize the time that children remain in ORR custody 
by efficiently and effectively vetting potential sponsors. 
Toolkit: Insights from OIGs Work on ORRs Efforts To Care for Unaccompanied Children  
OEI-09-21-00220  Toolkit | 1  Background 
Surges of unaccompanied children at the U.S. 
About Unaccompanied Children 
bordersuch as the current surgepresent 
several urgent challenges that ORR must address,  Unaccompanied children are children under the 
including adding additional bed capacity and  age of 18 who have no lawful immigration 
hiring new facility staff while ensuring the health  status in the United States and who have no 
and safety of unaccompanied children in HHS  parent or legal guardian in this country available 
custody.   to assume physical custody and provide care for 
them.  Most unaccompanied children come into 
In fiscal year (FY) 2019, HHS received the highest 
HHS custody because they are apprehended by 
recorded number of unaccompanied children 
border patrol officers with DHS.  DHS must refer 
from the Department of Homeland Security 
unaccompanied children to HHS within 72 hours 
(DHS)a total of 69,488 for the year.  In FY 2020, 
unless there are exceptional circumstances.   
this number of referrals fell to 15,381; the low 
number followed a U.S. policyimplemented in  The Unaccompanied Children Program, a 
March 2020to close the border to prevent entry  program office within ORR, funds a network of 
by certain noncitizens during the COVID-19  facilities that provide care to unaccompanied 
pandemic.  Following a court injunction and a  children, generally until suitable sponsors in the 
change in policy, referrals of unaccompanied  United States can assume custody.  
children to HHS began to increase.  In April 2021, 
DHS referred 19,154 children to HHS, an increase from 1,530 referrals in October 2020, the first month 
of FY 2021.  The cumulative total of referrals in FY 2021 (as of May 13, 2021) was 56,459 children, as 
shown in Exhibit 1. 
Exhibit 1: The number of unaccompanied children referred to HHS in FY 2021 reached 
56,459 on May 13, 2021, and has already exceeded referrals from 6 of the last 9 fiscal years. 
Referrals in FY 2020 were the lowest since FY 2012 because of the border action during the 
COVID-19 pandemic.
 
Source: OIG analysis of HHS data on referrals from DHS, 2021.   
Note: Data for FY 2021 is from October 1, 2020, through May 13, 2021.  FY 2021 will end on September 30, 2021. 
 
Toolkit: Insights from OIGs Work on ORRs Efforts To Care for Unaccompanied Children  
OEI-09-21-00220  Toolkit | 2  In response to the increasing number of referrals, ORR had added (as of April 7, 2021) 15 emergency 
intake sites and 2 influx care facilities.  Emergency intake sites and influx care facilities open temporarily 
to provide emergency shelter and services for unaccompanied children.  Unlike permanent facilities, 
emergency intake sites and influx care facilities are temporary and are therefore not required to be 
State-licensed.  Emergency intake sites provide only basic services (e.g., food and clothing) to children 
before they are transferred to a permanent shelter facility or released to sponsors.  Influx care facilities 
generally provide the same services as permanent ORR-funded shelter facilities.  On April 8, 2021, 
46 percent of the children in HHS custody resided in emergency intake sites and 6.5 percent in influx 
care facilities.    
Toolkit: Insights from OIGs Work on ORRs Efforts To Care for Unaccompanied Children  
OEI-09-21-00220  Toolkit | 3   
INSIGHTS 
 
Preparing to take unaccompanied children into HHS custody 
Coordinating transfers and interagency communication 
  To ensure the timely, seamless transfer of children from DHS to HHS, formal interagency 
agreements between HHS and DHS must provide clarity on each departments roles and 
responsibilities.  The agreements should include requirements for the transport, transfer, 
custody, and care of unaccompanied children, as well as structures for resolving issues and 
sharing information.  (OEI-09-16-00260, OEI-07-06-00290) 
  Effective HHS agreements with DHS and the Department of Justice can help to ensure that 
ORR receives all necessary information pertinent to its ability to provide care for 
unaccompanied children.  (OEI-BL-18-00510) 
Planning for sufficient bed capacity 
  Comprehensive and coordinated planning to maintain sufficient bed capacity can prepare ORR 
for surges in referrals of children from DHS and is critical to ensure that children can be 
transferred to ORR facilities within the 72-hour legal limit.  (OEI-BL-18-00510)  
  Maintaining adequate bed capacity in specialized facilitiessuch as facilities that provide 
higher levels of security or mental health carecan help prevent safety issues from occurring 
in nonspecialized shelter facilities by ensuring that children who need a higher level of care 
can be transferred to specialized facilities.  (OEI-09-18-00431) 
  Effective oversight of the Unaccompanied Children Program should include planning for 
population shifts that result from seasonal and policy changes.  (OEI-BL-18-00510,  
A-12-20-20001) 
Managing influx care facilities and emergency intake facilities 
  Better projections of bed capacity based on historical referral data and information from other 
Federal departments can help ORR do the following: respond to surges; ensure that influx care 
facilities have beds and staff in place; and maintain sufficient capacity.  (A-12-20-20001,  
OEI-BL-18-00510) 
  When ORR opens new facilities that are not State-licensed, two actions that it can take to help 
avoid placing children at risk are (1) ensuring that facilities receive background check results 
for staff prior to hiring them and (2) limiting the extent to which waivers are allowed for the 
background check requirements.  (A-12-19-20001, A-12-19-20000) 
  Working with local and other law enforcement to address jurisdiction issues prior to opening 
facilities that are not State-licensed can help clarify which law enforcement agency responds 
to child safety incidents.  (OIG law enforcement experts)  
Toolkit: Insights from OIGs Work on ORRs Efforts To Care for Unaccompanied Children  
OEI-09-21-00220  Toolkit | 4  Protecting children from harm 
Hiring, screening, and retaining facility employees 
  Two actions that can help protect children are (1) ORRs ensuring that pre-employment 
background screenings meet minimum requirements for background checksincluding FBI 
fingerprint checks and child abuse and neglect checksand (2) facilities noting proper 
documentation in employee personnel files.  (A-12-19-20000, A-12-19-20001) 
  Conducting timely background checks and ensuring that facility employees do not have direct 
access to children while checks are pending can help to ensure child safety.  (A-12-19-20001) 
  Maintaining a sufficient number of facility staffparticularly youth care workers and mental 
health cliniciansto meet ORR-mandated staff-to-child ratios can help to ensure the health 
and safety of children in facilities.  Additionally, ORR should work with facilities to maintain a 
sufficient number of youth care workers because they are key to preventing, detecting, and 
reporting safety incidents.  (OEI-09-16-00260, A-12-19-20000, A-12-19-20001,  
OEI-09-18-00430) 
  Technical assistance from ORR to facilities that addresses the topics of recruiting and retaining 
qualified staff; stress management; and other staffing issues can help ensure that facility staff 
can respond to childrens health and safety needs.  (OEI-09-16-00260, OEI-09-18-00431) 
Ensuring facility safety and security  
  Proactive safety and security planning at facilities can help prevent potential child safety 
incidents, especially at temporary facilities.  (OEI-05-19-00210) 
  Facilities benefit from clear and specific guidance from ORR regarding safety checklists and 
physical security requirements.  This helps the facilities to understand, meet, and properly 
document security and safety requirements.  (OEI-05-19-00210, A-02-16-02007,  
A-06-17-07005)  
  Periodic reviews of a facilitys physical security checklist by ORR help to protect children from 
potential harm and enable ORR to provide guidance on facility-level safety.   
(OEI-05-19-00210) 
  Facility compliance with State licensing-agency requirements (e.g., requirements regarding fire 
safety, facility cleanliness, securing hazardous materials, maintaining first-aid supplies, etc.) is 
critical to ensuring a safe living environment for children.  (A-06-17-07005, A-02-16-02007,  
A-02-16-02013, A-06-17-07007) 
Reporting and tracking significant incidents 
  Maintaining a significant incident reporting system that captures necessary informationsuch 
as a facilitys response to a safety incidentin an easy-to-analyze manner enables ORR to 
provide efficient and effective oversight and proactively spot trends in incident reports, in 
order to identify opportunities to better safeguard minors.  (OEI-09-18-00430)  
Toolkit: Insights from OIGs Work on ORRs Efforts To Care for Unaccompanied Children  
OEI-09-21-00220  Toolkit | 5    When facility employees have clear training and specific guidance on reporting safety 
incidents, and when they effectively report safety incidents through a robust reporting system, 
ORR can ensure that it has insights into specific safety incidents happening at facilities and can 
ensure appropriate followup action to protect children.  (OEI-09-18-00430) 
Coordinating with law enforcement 
  When ORR opens a new facility that is not State-licensed, early coordination with local and 
Federal law enforcement agencies can help to prevent safety and security issues at the facility 
and ensure adequate emergency response and necessary investigative support.   
(OIG law enforcement experts) 
  Followup calls from ORR and its grantees to a childs family after the childs release to a 
sponsor allow ORR to identify and report serious safety concerns to law enforcement and child 
protective services, where appropriate.  (OEI-09-16-00260) 
  Alerting the public and prospective sponsors to fraud schemes involving unaccompanied 
children can help to protect vulnerable families from bad actors.  (OIG Fraud Alert: Scheme 
Targeting Families of Unaccompanied Children) 
Screening potential sponsors and supporting family reunification 
  Efficiently identifying and vetting potential sponsors shortens the time that children remain in 
ORR custody and can help to prevent unnecessarily long stays that may worsen mental health 
issues for children in care.  (OEI-09-18-00431) 
  ORRs maintenance of centralized data systems that contain accurate, reliable, and consistent 
data about whether unaccompanied children were separated from family members, and 
information about those family members, helps with reunification efforts.  (OEI-BL-18-00510) 
  Reconciling and verifying data between facility and ORR data systems can support 
reunification efforts.  (A-06-17-07005, A-06-17-07007) 
  Communicating ORR operational guidance and policy changes quickly and accurately, in a 
searchable location with clear issuance and effective dates, ensures that facility staff can easily 
find current guidance on practices for sponsor screening and other policies.   
(OEI-BL-18-00510) 
  Contacting unaccompanied children after they have been released to sponsors can help 
connect children and their sponsors to post-release services such as locating legal 
representation, enrolling children in school, and obtaining health care.  (OEI-09-16-00260) 
   
Toolkit: Insights from OIGs Work on ORRs Efforts To Care for Unaccompanied Children  
OEI-09-21-00220  Toolkit | 6  Addressing childrens medical and mental health  
Preventing infectious disease 
  Ensuring that facilities are able to quarantine children who test positive for COVID-19or any 
other communicable diseaseprotects the health and safety of children and facility 
employees.  (A-04-20-02031) 
  Establishing clear policies and procedures on addressing communicable diseases can 
help protect childrens health, especially during a pandemic.  (A-04-20-02031) 
  Expanding access to telehealth services allows children to receive care while mitigating the risk 
of potential infection.  (A-04-20-02031) 
Providing medical and mental health services 
  Conducting thorough intake assessments when children enter facilities is critical to help 
identify immediate medical or mental health concerns; current medications; and any concerns 
about the childs personal safety.  (A-03-16-00250) 
  Completing medical exams within the required time and maintaining case files with complete 
documentation are steps that facilities can take to help ensure that children receive necessary 
services.  (A-03-16-00250, A-06-17-07005, OEI-07-06-00290) 
  Promptly addressing childrens mental health needs is essentialnot only to stabilize each 
child in crisis, but also to minimize the risk that the child may negatively influence or harm 
others.  (OEI-09-18-00431) 
  Telehealth capability can help facilities fill gaps in providing medical and mental health care 
and help ensure that children receive timely assessments and services.  (OEI-09-18-00431, 
A-04-20-02031) 
  Ensuring that facilities have enough mental health clinicians to maintain the ORR-mandated 
ratio of mental health clinicians to children can enable staff to devote more attention to 
childrens needs.  (OEI-09-18-00431, A-12-19-20001) 
  Because the level of trauma that many unaccompanied children experience is greater than 
what many mental health clinicians would typically encounter in other settings, more training 
in facilities is an important supplement for mental health clinicians.  (OEI-09-18-00431) 
 
Toolkit: Insights from OIGs Work on ORRs Efforts To Care for Unaccompanied Children  
OEI-09-21-00220  Toolkit | 7  OIG Oversight of the Unaccompanied 
 
Children Program 
 
 
OIG oversight of the Unaccompanied Children  Month of  Report number 
Program  Publication 
Preparing to take unaccompanied children into HHS custody 
The Office of Refugee Resettlement Did Not Award and  December 2020  A-12-20-20001 
Manage the Homestead Influx Care Facility Contracts in 
Accordance With Federal Requirements 
Communication and Management Challenges Impeded  March 2020  OEI-BL-18-00510 
HHS's Response to the Zero-Tolerance Policy   
Unaccompanied Alien Children Care Provider Facilities  September 2019  A-12-19-20001 
Generally Conducted Required Background Checks but Faced 
Challenges in Hiring, Screening, and Retaining Employees 
The Tornillo Influx Care Facility: Concerns About Staff  November 2018  A-12-19-20000 
Background Checks and Number of Clinicians on Staff   
HHS's Office of Refugee Resettlement Improved  July 2017  OEI-09-16-00260 
Coordination and Outreach To Promote the Safety and Well-  
Being of Unaccompanied Alien Children  
Division of Unaccompanied Children's Services: Efforts To  March 2008  OEI-07-06-00290 
Serve Children 
Protecting children from harm 
The Office of Refugee Resettlement's Incident Reporting  June 2020  OEI-09-18-00430 
System Is Not Effectively Capturing Data To Assist Its Efforts   
To Ensure the Safety of Minors in HHS Custody 
Unaccompanied Alien Children Program Care Provider  June 2020  OEI-05-19-00210 
Facilities Do Not Include All Required Security Measures in   
Their Checklists 
Southwest Key Programs Did Not Always Comply With Health  August 2019  A-06-17-07005 
and Safety Requirements For The Unaccompanied Alien   
Children Program  
The Children's Village, Inc., an Administration for Children  April 2019  A-02-16-02013 
and Families Grantee, Did Not Always Comply with   
Applicable Federal and State Policies and Requirements 
Lincoln Hall Boys' Haven, an Administration for Children and  February 2019  A-02-16-02007 
Families Grantee, Did Not Always Comply With Applicable   
Federal and State Policies and Requirements 
BCFS Health and Human Services Did Not Always Comply  December 2018  A-06-17-07007 
With Federal and State Requirements Related to the Health   
and Safety of Unaccompanied Alien Children   
Toolkit: Insights from OIGs Work on ORR's Efforts To Care for Unaccompanied Children 
OEI-09-21-0020  Toolkit | 8  OIG oversight of the Unaccompanied Children  Month of  Report number 
Program  Publication 
Addressing childrens medical and mental health 
Office of Refugee Resettlement Ensured That Selected Care  November 2020  A-04-20-02031 
Providers Were Prepared To Respond to the COVID-19   
Pandemic  
Youth For Tomorrow - New Life Center, Inc., an  September 2020  A-03-16-00250 
Administration for Children and Families Grantee, Did Not   
Comply With All Applicable Federal Policies and 
Requirements  
Care Provider Facilities Described Challenges Addressing  September 2019  OEI-09-18-00431 
Mental Health Needs of Children in HHS Custody   
Other reports 
Southwest Key Programs Failed To Protect Federal Funds  September 2020  A-06-17-07004 
Intended for the Care and Placement of Unaccompanied 
Alien Children  
Southwest Key Did Not Have Adequate Controls in Place To  August 2019  A-18-18-06001 
Secure Personally Identifiable Information Under the 
Unaccompanied Alien Children Program  
Separated Children Placed in Office of Refugee Resettlement  January 2019  OEI-BL-18-00511 
Care 
Florence Crittenton Services of Orange County, Inc., Did Not  October 2018  A-09-17-01002 
Always Claim Expenditures in Accordance With Federal 
Requirements  
Heartland Human Care Services, Inc., Generally Met Safety  September 2018  A-05-16-00038 
Standards, but Claimed Unallowable Rental Costs  
Florence Crittenton Services of Orange County, Inc., Did Not  June 2018  A-09-16-01005 
Always Meet Applicable Safety Standards Related to 
Unaccompanied Alien Children   
BCFS Health and Human Services Did Not Always Comply  February 2018  A-06-16-07007 
With Federal Requirements Related to Less-Than-Arm's-
Length Leases  
Office of Refugee Resettlement Unaccompanied Alien  December 2017  A-04-16-03566 
Children Grantee ReviewHis House  
 
   
Toolkit: Insights from OIGs Work on ORR's Efforts To Care for Unaccompanied Children 
OEI-09-21-0020  Toolkit | 9   
APPENDIX 
 
Standards 
OIG conducted the audits referenced in this toolkit in accordance with the Generally 
Accepted Government Auditing Standards issued by the U.S. Government 
Accountability Office and conducted the evaluations in accordance with the Quality 
Standards for Inspection and Evaluation issued by the Council of the Inspectors 
General on Integrity and Efficiency.   
Contact 
To obtain additional information concerning this report, contact the Office of Public 
Affairs at Public.Affairs@oig.hhs.gov.  OIG reports and other information can be found 
on the OIG website at oig.hhs.gov. 
Office of Inspector General 
U.S. Department of Health and Human Services 
330 Independence Avenue, SW 
Washington, DC 20201 
 
 
Toolkit: Insights from OIGs Work on ORR's Efforts To Care for Unaccompanied Children 
OEI-09-21-0020  Toolkit | 10