Five Laredo and San 

Antonio Area CBP 

Facilities Generally 

Complied with the 

National Standards on 

Transport, Escort, 

Detention, and Search 

September 1, 2020 

OIG-20-67 
6HSWHPEHU
 
 

 

 

 

DHS OIG HIGHLIGHTS 

Five Laredo and San Antonio Area CBP Facilities 

Generally Complied with the National Standards on

Transport, Escort, Detention, and Search 

September 1, 2020 

Why We 

Did This 

Inspection 

As part of OIG’s annual, 

congressionally mandated 

oversight of CBP holding 

facilities, we conducted 

unannounced inspections of 

five facilities in the Laredo 

and San Antonio areas of 

Texas to evaluate CBP’s 

compliance with applicable 

detention standards. 

What We 

Recommend 

We made no 

recommendations as a 

result of these inspections. 

For Further Information: 

Contact our Office of Public Affairs at 

(202) 981-6000, or email us at 

DHS-OIG.OfficePublicAffairs@oig.dhs.gov 

What We Found 

During our unannounced inspections of five U.S. Customs 

and Border Protection (CBP) facilities in the Laredo and 

San Antonio areas of Texas in February 2020, the three 

CBP Border Patrol stations and two CBP Office of Field 

Operations (OFO) ports of entry we visited appeared to be 

operating in compliance with the National Standards on 

Transport, Escort, Detention, and Search (TEDS) standards. 

We verified accessibility to water, food, toilets, sinks, basic 

hygiene supplies, and bedding. We observed clean 

facilities and verified that temperatures and ventilation in 

the holding rooms were appropriate. Of the five facilities, 

only one could provide on-site showers to detainees, but 

during our visits, no detainees were approaching the 

detention time threshold when a shower would be 

required. Because Border Patrol leadership directed all 

Border Patrol stations to implement Phase 2 of enhanced 

medical screening ahead of the prescribed schedule 

outlined in CBP Directive 2210-004, the Border Patrol 

stations we visited were conducting alien intake health 

assessments using CBP Form 2500. Ports of entry had 

implemented Phase 1, but were not yet required to 

conduct Phase 2 assessments at the time of our 

inspection. 

CBP Response 

CBP management elected to forego a formal written 

response as we made no recommendations in the report. 

www.oig.dhs.gov OIG-20-67 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



Introduction 

With holding facilities in many of the 328 ports of entry and 135 Border Patrol 

stations, U.S. Customs and Border Protection’s (CBP) ability to meet the 2015 

National Standards on Transport, Escort, Detention, and Search (TEDS)1 and 

provide reasonable care for detainees from apprehension to transfer or 

repatriation can vary greatly. In 2019, our unannounced inspections of CBP 

holding facilities identified significant issues, such as dangerous overcrowding 

and prolonged detention, at several locations along the Southwest Border. In 

fiscal year 2020, Congress mandated that we continue our unannounced 

inspections of CBP holding facilities, with a particular focus on evaluating 

CBP’s capacity to identify and adequately address the health needs of 

detainees. Accordingly, in addition to assessing CBP’s compliance with the 

detention standards we typically evaluate, such as access to food, drink, 

personal hygiene supplies, and medical care, our FY 2020 inspections also 

focus on enhanced medical intake procedures implemented by CBP. This 

report describes the results of the first of a series of unannounced inspections 

we will conduct in FY 2020. This first round of inspections covered five Laredo 

and San Antonio area CBP facilities (see figure 1). 

Figure 1: Locations of CBP Facilities Visited in February 2020 

Source: Office of Inspector General (OIG) 

 1 The TEDS standards govern CBP’s interaction with detained individuals. U.S. Customs and 

Border Protection, National Standards on Transport, Escort, Detention, and Search, October 

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2015 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



Background 

CBP’s Office of Field Operations (OFO) manages U.S. ports of entry where 

officers perform immigration and customs functions, admitting people who 

have valid documents for legal entry, such as visas or legal permanent resident 

cards, and goods permitted under customs and other laws. Between ports of 

entry, CBP’s Border Patrol detects and interdicts individuals suspected of 

illegally entering the United States. OFO and Border Patrol are responsible for 

short-term detention of persons arriving in the United States without valid 

travel documents or crossing the border illegally. 

CBP’s holding facilities are required to comply with TEDS, which specify how 

detainees should be treated in CBP custody. According to TEDS, every effort 

must be made to promptly transfer, transport, process, release, or repatriate 

detainees as appropriate and as operationally feasible, within 72 hours after 

being taken into custody.2 CBP has an obligation to provide detainees in its 

custody with drinking water, meals and snacks, access to toilets and sinks, 

basic hygiene supplies, bedding, and under certain circumstances, showers.3 

CBP must also ensure that holding facilities are kept clean, temperaturecontrolled, and adequately ventilated.4 

TEDS standards also outline general requirements related to detainee access to 

medical care in emergencies. In late December 2019, CBP enhanced these 

requirements by adopting CBP Directive 2210-004,5 which requires 

“deployment of enhanced medical support efforts to mitigate risk to, and 

sustain enhanced medical efforts for persons in CBP custody along the 

Southwest Border.” The directive outlines a three-phased approach for 

enhancing medical screening of persons in CBP custody. In the first phase 

(Phase 1), CBP personnel are expected to observe all persons in custody upon 

initial encounter and identify potential medical issues. Persons identified with 

 2 TEDS standards generally limit detention in CBP facilities to 72 hours, with the expectation 

that CBP will transfer Unaccompanied Alien Children (UAC) to the Department of Health and 

Human Services, Office of Refugee Resettlement, and families and single adults to U.S. 

Immigration and Customs Enforcement long-term detention facilities. 

3 TEDS 4.14 Secure Detention Standards: Drinking Water; TEDS 4.13 Secure Detention 

Standards: Food and Beverage, Meal Timeframe and Snack Timeframe; TEDS 5.6 Detention: 

Meals and Snacks – Juveniles, Pregnant, and Nursing Detainees; TEDS 4.15 Secure Detention 

Standards: Restroom Facilities; TEDS 5.6 Detention: Hold Rooms – UAC; TEDS 4.11 Secure 

Detention Standards: Hygiene; TEDS 4.12 Secure Detention Standards: Bedding. Under TEDS 

standards, reasonable effort will be made to provide showers to juveniles approaching 48 

hours, and adults approaching 72 hours, in CBP custody. TEDS 4.11 Secure Detention 

Standards: Hygiene: Basic Hygiene Items; and 5.6 Detention: Showers – Juveniles 4 TEDS 4.7 Hold Room Standards: Temperature Controls; and TEDS 5.6 Detention: Hold Rooms 

– UAC 

5 CBP Directive No. 2210-004, Enhanced Medical Support Efforts, December 30, 2019 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



medical issues of concern will then receive health interviews or medical 

assessments, or be referred to the local health system for evaluation. 

In addition to the initial observation required in the first medical screening 

phase, the second phase (Phase 2) requires CBP personnel to complete an Alien 

Initial Health Interview Questionnaire (CBP Form 2500) for any individual in 

custody under the age of 18. Subject to availability of resources and 

operational requirements, the third phase (Phase 3) adds the requirement that 

CBP personnel conduct a medical assessment6 of all children ages 12 and 

under in custody,7 any person who has a positive response to a specific set of 

questions on the CBP Form 2500,8 and any other person in custody with a 

known or reported medical concern. The directive notes that implementation of 

these phases “is contingent upon available funding and necessary resources for 

contracted medical support and for dedicated internal CBP medical direction, 

coordination, and oversight.”9 

The medical screening directive gave Border Patrol and OFO 90 days to submit 

plans to the Commissioner detailing how they would implement the new 

requirements. At the time of our February 2020 inspections, Border Patrol had 

submitted its plan and had already implemented the Phase 2 requirements 

ahead of the 90-day deadline. OFO had not yet submitted its plan, but was on 

track to meet the directive’s deadline for submission. 

Results of Inspection 

During our unannounced inspections of five CBP facilities in the Laredo and 

San Antonio areas of Texas in February 2020, the three Border Patrol stations 

and two OFO ports of entry we visited appeared to be operating in compliance 

with the TEDS standards. We verified accessibility to water, food, toilets, 

sinks, basic hygiene supplies, and bedding. We observed clean facilities and 

verified that temperatures and ventilation in the holding rooms were 

appropriate. Of the five facilities we visited, only one could provide on-site 

showers to detainees, but during our visits, no detainees were approaching the 

detention time threshold where a shower would be required. Because Border 

 6 The directive defines a “medical assessment” as an evaluation of an individual conducted by a 

health care provider to assess medical status. CBP Directive 2210-004, Enhanced Medical 

Support Efforts (5.4), December 30, 2019 

7 The directive specifically identifies that only children 12 and under along the Southwest 

border will receive a medical assessment. There is no such requirement along the Northern 

border. 

8 There are seven questions on the CBP Form 2500 that, if the detainee has a positive 

response, would automatically prompt a medical assessment. These questions are used to 

determine if the detainee has injury, any symptoms of illness, known contagious diseases, or 

thoughts of harming self or others. 

9 CBP Directive 2210-004, Enhanced Medical Support Efforts (8.1), December 30, 2019 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



Patrol leadership directed all Border Patrol stations to implement Phase 2 of 

enhanced medical screening ahead of the prescribed schedule outlined in CBP 

Directive 2210-004, the Border Patrol stations we visited were conducting alien 

intake health assessments using CBP Form 2500. Ports of entry had 

implemented Phase 1, but were not yet required to conduct Phase 2 

assessments at the time of our inspection. 

Facilities Generally Complied with Standards, but Did Not Have 

Showers Readily Available for Detainees 

Among other requirements under TEDS standards, functioning drinking 

fountains or clean drinking water must always be available to detainees;10 

snacks and meals have to be provided at regularly scheduled intervals;11 

detainees must have access to toilets and sinks, basic hygiene supplies, and 

bedding;12 and temperatures and ventilation in hold rooms must be 

reasonable.13 During our inspection of Laredo and San Antonio area facilities, 

we found that all five of the facilities we visited complied with these TEDS 

standards. In addition, under TEDS standards, reasonable effort will be made 

to provide showers to detainees after a certain amount of time in CBP 

custody.14 At the time of our visit, only one out of five facilities visited had the 

capability to provide showers on site. However, because none of the facilities at 

the time were holding detainees long enough to meet the shower-access 

thresholds, we did not observe noncompliance with these standards. 

Drinking Water, Meals, and Snacks Were Available 

In all five facilities we visited, each detainee had access to potable water. The 

facilities had either jugs filled with water and clean drinking cups, or bottled 

water, available. At all five facilities, juveniles and adults had access to food, 

drinks such as juice and milk, and snacks. The facilities also had clean baby 

bottles and a variety of age appropriate foods such as formula, baby food, and 

snack items. 

 10 TEDS 4.14 Secure Detention Standards: Drinking Water 11 TEDS 4.13 Secure Detention Standards: Food and Beverage, Meal Timeframe and Snack 

Timeframe; TEDS 5.6 Detention: Meals and Snacks – Juveniles, Pregnant, and Nursing 

Detainees 

12 TEDS 4.15 Secure Detention Standards: Restroom Facilities; TEDS 5.6 Detention: Hold Rooms 

– UAC; TEDS 4.11 Secure Detention Standards: Hygiene; TEDS 4.12 Secure Detention 

Standards: Bedding 

13 TEDS 4.7 Hold Room Standards: Temperature Controls; and TEDS 5.6 Detention: Hold Rooms 

– UAC 

14 TEDS 5.6 Detention: Showers – Juveniles; and TEDS 4.11 Secure Detention Standards: 

Hygiene: Showers 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



Figure 2. Baby food, drinks, and snacks available at CBP facilities, 

observed February 25–27, 2020 

Source: OIG 

Detainees Had Access to Toilets, Hygiene Items, and Bedding 

All five facilities had working toilets and sinks. Four of the five facilities had 

mats and Mylar blankets, and personal hygiene items such as toothbrushes, 

toothpaste, soap, and deodorant. They also had some clothing available. The 

remaining facility, a port of entry at an airport, did not hold detainees 

overnight. A CBP official at the airport said if an individual must be detained 

overnight, the detainee is transferred to an Immigration and Customs 

Enforcement facility. All facilities had basic hygiene supplies such as toilet 

paper, diapers, baby wipes, and feminine hygiene products. 

Figure 3. Clean holding cells with child sized mats and adult sleeping 

mats, observed February 25–27, 2020 

Source: OIG 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



CBP Facilities Were Well Below Maximum Capacity 

We observed that holding facilities were well below capacity during the time of 

our visit. The total maximum capacity for all five facilities was approximately 

400. As noted in table 1, during our visit, only 44 detainees were in custody at 

the 5 facilities. 

Table 1: Total Detainees Held at CBP Facilities Visited February 25–27, 

2020 

Facilities UAC Family Single 

Adult 

Grand 

Total 

Holding 

Capacity15 

Border Patrol Cotulla 2 0 0 2 119 

Border Patrol Freer 2 0 3 5 85 

Border Patrol Laredo South 5 14 10 29 156 

Port of Entry Juarez-Lincoln 0 3 5 8 40 

Port of Entry San Antonio Airport 0 0 0 0 4 

Grand Total 9 17 18 44 404 

Source: OIG analysis of CBP roll call information 

Most CBP Facilities Did Not Have Showers on Site 

Of the five facilities we visited, only the San Antonio Airport Port of Entry could 

provide on-site showers to detainees. According to local CBP officials, at least 

two of the four facilities without showers had requested portable showers from 

CBP headquarters, but had not received them. In the event of another 

Southwest border surge, these facilities may face challenges in complying with 

TEDS standards on access to showers. However, at the time of our February 

2020 visits, CBP was not holding detainees long enough to trigger the TEDS 

provisions regarding access to showers — i.e., 48 hours for juveniles and 72 

hours for adults. 

Border Patrol and OFO Facilities Were at Various Stages of 

Implementation of the New CBP Enhanced Medical Support 

Efforts 

At the time of our visit in February 2020, both Border Patrol and OFO had 

already implemented the Phase 1 procedures outlined in CBP Directive 2210-

004, Enhanced Medical Support Efforts. Operating ahead of the timeline 

prescribed in the directive, Border Patrol stations had implemented Phase 2 

and were using CBP Form 2500, Alien Initial Health Interview Questionnaire. 

 15 Holding capacities for ports of entry are approximate, as waiting areas can be used for less 

restrictive detention. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



OFO ports of entry had not implemented the Phase 2 procedures, but were still 

within the 90-day timeframe for developing an implementation plan. 

At all five locations we visited, CBP staff met the TEDS standard for identifying 

medical issues. Specifically, TEDS 4.3 General Detention Procedures: Medical 

Issues states: “Upon a detainee’s entry into any CBP hold room, 

officers/agents must ask detainees about, and visually inspect for any sign of 

injury, illness, or physical or mental health concerns and question the detainee 

about any prescription medications.” At the time of our site visits in February 

2020, all three Border Patrol stations met this requirement by implementing 

the Phase 2 procedures outlined in CBP Directive 2210-004.16 Specifically, the 

medical personnel, medical contractors, or Emergency Medical Technician 

(EMT)-certified Border Patrol agents working at the three stations we visited 

said they were completing the new CBP Form 2500, Alien Health Interview 

Questionnaire, to identify potential medical issues for all detainees under the 

age of 18. Further, at one Border Patrol station we visited, we learned staff had 

expanded the Phase 2 procedures and were completing CBP Form 2500 on all 

detainees, regardless of age.17 

In contrast, OFO had not yet implemented the Phase 2 procedures at ports of 

entry at the time of our visit. The two OFO ports of entry we visited were not 

using CBP Form 2500 and had not received guidance from OFO headquarters 

regarding implementation of Phase 2 requirements. However, because OFO 

was still operating within the 90-day timeframe set in the directive, non-use of 

the form was acceptable. An OFO official from headquarters said the draft plan 

to enhance medical support efforts was in the final approval stages and, once it 

is signed, will be distributed to OFO locations with instructions to use CBP 

Form 2500. In the meantime, the two OFO facilities we visited met the TEDS 

requirement for identifying health concerns by engaging in verbal exchange 

with each detainee. Specifically, at the land port of entry, medical contractors 

conducted health interviews with detainees;18 at the airport port of entry, CBP 

officers elicited medical information from detainees. 

 16 On January 14, 2020, approximately 2 weeks after the directive was adopted, the Chief of 

Border Patrol sent out guidance to all Border Patrol stations stating the CBP Form 2500, Alien 

Health Interview Questionnaire, must be completed for all individuals under the age of 18. 

17 Although the Phase 2 procedures in CBP Directive 2210-004 call for completion of Form 

2500 only on detainees under the age of 18, Laredo Border Patrol officials at one station we 

visited said they used the CBP Form 2500 for all detainees. Our team corroborated this when 

it observed medical personnel using the CBP Form 2500 when questioning an adult detainee at 

one of the stations. 

18 These health interviews involved medical contractors asking detainees 13 questions the 

contractors had developed, the answers to which were logged in a system for recording health 

information in the detainee’s file. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



None of the CBP facilities we visited had implemented Phase 3, which is 

dependent on availability of resources and operational requirements. 

Finally, we observed that the facilities we visited had taken precautions to 

identify and limit the spread of infectious illnesses. For example, those with 

outdoor areas conducted health interviews before detainees entered the 

facilities. We observed a detainee who had been given, and was wearing, a 

mask. Masks, gloves, and hand sanitizers were available to CBP and contract 

staff. During our inspections, we observed some CBP personnel and contract 

staff wearing gloves, while some did not. Although the coronavirus was not yet 

prevalent in the United States at the time of our visit, we observed relevant 

posters displayed in the facilities, and medical staff asked detainees about 

travel routes to evaluate potential exposure risk. 

Recommendations 

We have no recommendations at this time. 

Management Comments and OIG Analysis 

We received technical comments from CBP and incorporated them in the report 

where appropriate. CBP management elected to forego a formal written 

response as no recommendations were made in the report. 

Objective, Scope, and Methodology 

The Department of Homeland Security Office of Inspector General was 

established by the Homeland Security Act of 2002 (Pub. L. No. 107ï296) by 

amendment to the Inspector General Act of 1978. 

Our objective was to determine whether CBP complied with the TEDS 

standards, and provided reasonable care to detainees from apprehension to 

holding, including CBP’s measures to implement the December 30, 2019 

Directive 2210-004, Enhanced Medical Support Efforts. 

Prior to our inspections, we met with our Office of Investigations and the DHS 

Office for Civil Rights and Civil Liberties to obtain information on detainee 

complaints relevant to our site selection. We also reviewed relevant 

background information, including DHS OIG hotline complaints, and 

information from congressional requests, non-governmental organizations, and 

media reports. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



Between February 25 and 27, 2020, we visited three Border Patrol stations 

(Cotulla, TX; Freer, TX (Freer Station and Freer Checkpoint); Laredo South, 

TX); and two ports of entry (Lincoln/Juarez International Bridge, Laredo, TX 

(Bridges 1 and 2); and San Antonio Airport, San Antonio, TX). 

Our inspections were unannounced; we did not inform CBP we were in the area 

before we arrived at the first facility. At each facility, we observed conditions 

and reviewed electronic records and paper logs as necessary. We also 

conducted a limited number of interviews of CBP personnel and, when 

possible, interviewed detainees with language assistance services to provide 

interpretation. We photographed examples of compliance with TEDS. For 

example, we took photographs to document the presence of food and supplies, 

and photographed the conditions of cells. 

With the number of detainees arriving and departing each day, conditions at 

facilities — including crowding and the presence of UACs and families — could 

vary by day. Our conclusions are therefore limited to what we observed and 

information obtained from detainees and CBP staff at the time of our site visit. 

Within the TEDS standards, we prioritized standards that protect children, 

derived from the Flores Agreement19 and the Trafficking Victims Protection 

Reauthorization Act of 2008.20 For example, the Flores Agreement generally 

permits detention of minors no longer than 72 hours, with a provision that, in 

an emergency or influx of minors, placement should be as expeditious as 

possible. In addition, the Trafficking Victims Protection Reauthorization Act of 

2008 requires DHS to transfer the custody of all unaccompanied alien children 

to the U.S. Department of Health and Human Services within 72 hours of 

determining that a child is a UAC, absent “exceptional circumstances.” The 

Flores Agreement and subsequent federal court decisions also require care for 

detained juveniles, including access to drinking water, meals and snacks, 

toilets and sinks, basic hygiene supplies and bedding, showers, and adequate 

temperatures and ventilation. 

We also focused on the TEDS standards regarding medical care, for example 

provisions to: 

x Ensure medical records and medications accompany detainees during 

transfer (TEDS 2.10). 

x Ask detainees about, and visually inspect for, any sign of injury, illness, 

or physical or mental health concerns (TEDS 4.3). 

x Take precautions to protect against contagious diseases (TEDS 4.3). 

 19 Flores Settlement Agreement of 1997 

20 Pub. L. No. 110-457, § 235(b)(3), 122 Stat. 5044, 5077 (2008); see also 8 United States Code 

(U.S.C.) § 1232(b)(3). 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



x Identify the need for prescription medicines (TEDS 4.3). 

x Have a process for medical emergencies (TEDS 4.10). 

x Take precautions for at-risk populations (TEDS 5.0). 

This review describes CBP’s process for providing access to medical care, but 

does not evaluate the quality of medical care provided to those in CBP custody. 

We conducted this review in February 2020 under the authority of the 

Inspector General Act of 1978, as amended, and according to the Quality 

Standards for Inspection and Evaluation issued by the Council of the Inspectors 

General on Integrity and Efficiency. 

www.oig.dhs.gov 10 OIG-20-67
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



Appendix A 

CBP Comments to the Draft Report 

CBP management elected to forego a formal written response as no 

recommendations were made in the report. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



Appendix B 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chiefs of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy, Strategy, and Plans 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Commissioner, U.S. Customs and Border Protection 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

www.oig.dhs.gov 12 OIG-20-67
Additional Information and Copies 

To view this and any of our other reports, please visit our website at: 

www.oig.dhs.gov. 

For further information or questions, please contact Office of Inspector General 

Public Affairs at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov. 

Follow us on Twitter at: @dhsoig. 

OIG Hotline 

To report fraud, waste, or abuse, visit our website at www.oig.dhs.gov and click 

on the red "Hotline" tab. If you cannot access our website, call our hotline at 

(800) 323-8603, fax our hotline at (202) 254-4297, or write to us at: 

Department of Homeland Security 

Office of Inspector General, Mail Stop 0305 

Attention: Hotline 

245 Murray Drive, SW 

Washington, DC 20528-0305