UNITED STATES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

JENNY LISETTE FLORES, et al, Plaintiffs 

v. 

JANET RENO, Attorney General of the United States, et al., Defendants 

Case No. CV 85-4544-RJK(Px) 

STIPULATED SETTLEMENT AGREEMENT 

WHEREAS, Plaintiffs have filed this action against Defendants, challenging, inter alia, the constitutionality 

of Defendants' policies, practices and regulations regarding the detention and release of unaccompanied 

minors taken into the custody of the Immigration and Naturalization Service (INS) in the Western Region; 

and 

WHEREAS, the district court has certified this case as a class action on behalf of all minors apprehended 

by the INS in the Western Region of the United States; and 

WHEREAS, this litigation has been pending for nine (9) years, all parties have conducted extensive 

discovery, and the United States Supreme Court has upheld the constitutionality of the challenged INS 

regulations on their face and has remanded for further proceedings consistent with its opinion; and 

WHEREAS, on November 30, 1987, the parties reached a settlement agreement requiring that minors in 

INS custody in the Western Region be housed in facilities meeting certain standards, including state 

standards for the housing and care of dependent children, and Plaintiffs' motion to enforce compliance 

with that settlement is currently pending before the court; and 

WHEREAS, a trial in this case would be complex, lengthy and costly to all parties concerned, and the 

decision of the district court would be subject to appeal by the losing parties with the final outcome 

uncertain; and 

WHEREAS, the parties believe that settlement of this action is in their best interests and best serves the 

interests of justice by avoiding a complex, lengthy and costly trial, and subsequent appeals which could 

last several more years; 

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NOW, THEREFORE, Plaintiffs and Defendants enter into this Stipulated Settlement Agreement (the 

Agreement), stipulate that it constitutes a full and complete resolution of the issues raised in this action, 

and agree to the following: 

I DEFINITIONS 

As used throughout this Agreement the following definitions shall apply: 

1. The term "party" or "parties" shall apply to Defendants and Plaintiffs. As the term applies to 

Defendants, it shall include their agents, employees, contractors and/or successors in office. As the term 

applies to Plaintiffs, it shall include all class members. 

2. The term "Plaintiff" or "Plaintiffs" shall apply to the named plaintiffs and all class members. 

3. The term "class member" or "class members" shall apply to the persons defined in Paragraph 10 

below. 

4. The term "minor" shall apply to any person under the age of eighteen (18) years who is detained in the 

legal custody of the INS. This Agreement shall cease to apply to any person who has reached the age of 

eighteen years. The term "minor" shall not include an emancipated minor or an individual who has been 

incarcerated due to a conviction for a criminal offense as an adult. The INS shall treat all persons who are 

under the age of eighteen but not included within the definition of "minor" as adults for all purposes, 

including release on bond or recognizance. 

5. The term "emancipated minor" shall refer to any minor who has been determined to be emancipated in 

an appropriate state judicial proceeding. 

6. The term "licensed program" shall refer to any program, agency or organization that is licensed by an 

appropriate State agency to provide residential, group, or foster care services for dependent children, 

including a program operating group homes, foster homes, or facilities for special needs minors. A 

licensed program must also meet those standards for licensed programs set forth in Exhibit 1 attached 

hereto. All homes and facilities operated by licensed programs, including facilities for special needs 

minors, shall be non-secure as required under state law; provided, however, that a facility for special 

needs minors may maintain that level of security permitted under state law which is necessary for the 

protection of a minor or others in appropriate circumstances, e.g., cases in which a minor has drug or 

alcohol problems or is mentally ill. The INS shall make reasonable efforts to provide licensed placements 

in those geographical areas where the majority of minors are apprehended, such as southern California, 

southeast Texas, southern Florida and the northeast corridor. 

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7. The term "special needs minor" shall refer to a minor whose mental and/or physical condition requires 

special services and treatment by staff. A minor may have special needs due to drug or alcohol abuse, 

serious emotional disturbance, mental illness or retardation, or a physical condition or chronic illness that 

requires special services or treatment. A minor who has suffered serious neglect or abuse may be 

considered a minor with special needs if the minor requires special services or treatment as a result of the 

neglect or abuse. The INS shall assess minors to determine if they have special needs and, if so, shall 

place such minors, whenever possible, in licensed programs in which the INS places children without 

special needs, but which provide services and treatment for such special needs. 

8. The term "medium security facility" shall refer to a facility that is operated by a program, agency or 

organization licensed by an appropriate State agency and that meets those standards set forth in Exhibit 

1 attached hereto. A medium security facility is designed for minors who require close supervision but do 

not need placement in juvenile correctional facilities. It provides 24-hour awake supervision, custody, 

care, and treatment. It maintains stricter security measures, such as intensive staff supervision, than a 

facility operated by a licensed program in order to control problem behavior and to prevent escape. Such 

a facility may have a secure perimeter but shall not be equipped internally with major restraining 

construction or procedures typically associated with correctional facilities. 

II SCOPE OF SETTLEMENT, EFFECTIVE DATE, AND PUBLICATION 

9. This Agreement sets out nationwide policy for the detention, release, and treatment of minors in the 

custody of the INS and shall supersede all previous INS policies that are inconsistent with the terms of 

this Agreement. This Agreement shall become effective upon final court approval, except that those terms 

of this Agreement regarding placement pursuant to Paragraph 19 shall not become effective until all 

contracts under the Program Announcement referenced in Paragraph 20 below are negotiated and 

implemented. The INS shall make its best efforts to execute these contracts within 120 days after the 

court's final approval of this Agreement. However, the INS will make reasonable efforts to comply with 

Paragraph 19 prior to full implementation of all such contracts. Once all contracts under the Program 

Announcement referenced in Paragraph 20 have been implemented, this Agreement shall supersede the 

agreement entitled Memorandum of Understanding Re Compromise of Class Action: Conditions of 

Detention (hereinafter "MOU"), entered into by and between the Plaintiffs and Defendants and filed with 

the United States District Court for the Central District of California on November 30, 1987, and the MOU 

shall thereafter be null and void. However, Plaintiffs shall not institute any legal action for enforcement of 

the MOU for a six (6) month period commencing with the final district court approval of this Agreement, 

except that Plaintiffs may institute enforcement proceedings if the Defendants have engaged in serious 

violations of the MOU that have caused irreparable harm to a class member for which injunctive relief 

would be appropriate. Within 120 days of the final district court approval of this Agreement, the INS shall 

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initiate action to publish the relevant and substantive terms of this Agreement as a Service regulation. 

The final regulations shall not be inconsistent with the terms of this Agreement. Within 30 days of final 

court approval of this Agreement, the INS shall distribute to all INS field offices and sub-offices 

instructions regarding the processing, treatment, and placement of juveniles. Those instructions shall 

include, but may not be limited to, the provisions summarizing the terms of the Agreement attached 

hereto as Exhibit 2. 

III CLASS DEFINITION 

10. The certified class in this action shall be defined as follows: "All minors who are detained in the legal 

custody of the INS." 

IV STATEMENTS OF GENERAL APPLICABILITY 

11. The INS treats, and shall continue to treat, all minors in its custody with dignity, respect and special 

concern for their particular vulnerability as minors. The INS shall place each detained minor in the least 

restrictive setting appropriate to the minor's age and special needs, provided that such setting is 

consistent with its interests to ensure the minor's timely appearance before the INS and the immigration 

courts and to protect the minor's well-being and that of others. Nothing herein shall require the INS to 

release a minor to any person or agency whom the INS has reason to believe may harm or neglect the 

minor or fail to present him or her before the INS or the immigration courts when requested to do so. 

V PROCEDURES AND TEMPORARY PLACEMENT FOLLOWING ARREST 

12. Whenever the INS takes a minor into custody, it shall expeditiously process the minor and shall 

provide the minor with a notice of rights, including the right to a bond redetermination hearing if 

applicable. Following arrest, the INS shall hold minors in facilities that are safe and sanitary and that are 

consistent with the INS's concern for the particular vulnerability of minors. Facilities will provide access to 

toilets and sinks, drinking water and food as appropriate, medical assistance if the minor is in need of 

emergency services, adequate temperature control and ventilation, adequate supervision to protect 

minors from others, and contact with family members who were arrested with the minor. The INS will 

segregate unaccompanied minors from unrelated adults. Where such segregation is not immediately 

possible, an unaccompanied minor will not be detained with an unrelated adult for more than 24 hours. If 

there is no one to whom the INS may release the minor pursuant to Paragraph 14, and no appropriate 

licensed program is immediately available for placement pursuant to Paragraph 19, the minor may be 

placed in an INS detention facility, or other INS-contracted facility, having separate accommodations for 

minors, or a State or county juvenile detention facility. However, minors shall be separated from 

delinquent offenders. Every effort must be taken to ensure that the safety and well-being of the minors 

detained in these facilities are satisfactorily provided for by the staff. The INS will transfer a minor from a 

placement under this paragraph to a placement under Paragraph 19 (i) within three (3) days, if the minor 

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was apprehended in an INS district in which a licensed program is located and has space available; or (ii) 

within five (5) days in all other cases; except: 

1. as otherwise provided under Paragraph 13 or Paragraph 21; 

2. as otherwise required by any court decree or court-approved settlement; 

3. in the event of an emergency or influx of minors into the United States, in which case the INS 

shall place all minors pursuant to Paragraph 19 as expeditiously as possible; or 

4. where individuals must be transported from remote areas for processing or speak unusual 

languages such that the INS must locate interpreters in order to complete processing, in which 

case the INS shall place all such minors pursuant to Paragraph 19 within five (5) business days. 

B. For purposes of this Paragraph, the term "emergency" shall be defined as any act or event that 

prevents the placement of minors pursuant to Paragraph 19 within the time frame provided. Such 

emergencies include natural disasters (e.g., earthquakes, hurricanes, etc.), facility fires, civil disturbances, 

and medical emergencies (e.g., a chicken pox epidemic among a group of minors). The term "influx of 

minors into the United States" shall be defined as those circumstances where the INS has, at any given 

time, more than 130 minors eligible for placement in a licensed program under Paragraph 19, including 

those who have been so placed or are awaiting such placement. 

C. In preparation for an "emergency" or "influx," as described in Subparagraph B, the INS shall have a 

written plan that describes the reasonable efforts that it will take to place all minors as expeditiously as 

possible. This plan shall include the identification of 80 beds that are potentially available for INS 

placements and that are licensed by an appropriate State agency to provide residential, group, or foster 

care services for dependent children. The plan, without identification of the additional beds available, is 

attached as Exhibit 3. The INS shall not be obligated to fund these additional beds on an ongoing basis. 

The INS shall update this listing of additional beds on a quarterly basis and provide Plaintiffs' counsel with 

a copy of this listing. 

13. If a reasonable person would conclude that an alien detained by the INS is an adult despite his claims 

to be a minor, the INS shall treat the person as an adult for all purposes, including confinement and 

release on bond or recognizance. The INS may require the alien to submit to a medical or dental 

examination conducted by a medical professional or to submit to other appropriate procedures to verify 

his or her age. If the INS subsequently determines that such an individual is a minor, he or she will be 

treated as a minor in accordance with this Agreement for all purposes. 

VI GENERAL POLICY FAVORING RELEASE 

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14. Where the INS determines that the detention of the minor is not required either to secure his or her 

timely appearance before the INS or the immigration court, or to ensure the minor's safety or that of 

others, the INS shall release a minor from its custody without unnecessary delay, in the following order of 

preference, to: 

A. a parent; 

B. a legal guardian; 

C. an adult relative (brother, sister, aunt, uncle, or grandparent); 

D. an adult individual or entity designated by the parent or legal guardian as capable and 

willing to care for the minor's well-being in (i) a declaration signed under penalty of perjury 

before an immigration or consular officer or (ii) such other document(s) that establish(es) to 

the satisfaction of the INS, in its discretion, the affiant's paternity or guardianship; 

E. a licensed program willing to accept legal custody; or 

F. an adult individual or entity seeking custody, in the discretion of the INS, when it appears 

that there is no other likely alternative to long term detention and family reunification does not 

appear to be a reasonable possibility. 

15. Before a minor is released from INS custody pursuant to Paragraph 14 above, the custodian must 

execute an Affidavit of Support (Form I-134) and an agreement to: 

A. provide for the minor's physical, mental, and financial well-being; 

B. ensure the minor's presence at all future proceedings before the INS and the immigration 

court; 

C. notify the INS of any change of address within five (5) days following a move; 

D. in the case of custodians other than parents or legal guardians, not transfer custody of the 

minor to another party without the prior written permission of the District Director; 

E. notify the INS at least five days prior to the custodian's departing the United States of such 

departure, whether the departure is voluntary or pursuant to a grant of voluntary departure or 

order of deportation; and 

F. if dependency proceedings involving the minor are initiated, notify the INS of the initiation of a 

such proceedings and the dependency court of any immigration proceedings pending against the 

minor.

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In the event of an emergency, a custodian may transfer temporary physical custody of a minor prior to 

securing permission from the INS but shall notify the INS of the transfer as soon as is practicable 

thereafter, but in all cases within 72 hours. For purposes of this Paragraph, examples of an "emergency" 

shall include the serious illness of the custodian, destruction of the home, etc. In all cases where the 

custodian in writing seeks written permission for a transfer, the District Director shall promptly respond to 

the request. 

16. The INS may terminate the custody arrangements and assume legal custody of any minor whose 

custodian fails to comply with the agreement required under Paragraph 15. The INS, however, shall not 

terminate the custody arrangements for minor violations of that part of the custodial agreement outlined at 

Subparagraph 15.C above. 

17. A positive suitability assessment may be required prior to release to any individual or program 

pursuant to Paragraph 14. A suitability assessment may include such components as an investigation of 

the living conditions in which the minor would be placed and the standard of care he would receive, 

verification of identity and employment of the individuals offering support, interviews of members of the 

household, and a home visit. Any such assessment should also take into consideration the wishes and 

concerns of the minor. 

18. Upon taking a minor into custody, the INS, or the licensed program in which the minor is placed, shall 

make and record the prompt and continuous efforts on its part toward family reunification and the release 

of the minor pursuant to Paragraph 14 above. Such efforts at family reunification shall continue so long as 

the minor is in INS custody. 

VII INS CUSTODY 

19. In any case in which the INS does not release a minor pursuant to Paragraph 14, the minor shall 

remain in INS legal custody. Except as provided in Paragraphs 12 or 21, such minor shall be placed 

temporarily in a licensed program until such time as release can be effected in accordance with 

Paragraph 14 above or until the minor's immigration proceedings are concluded, whichever occurs 

earlier. All minors placed in such a licensed program remain in the legal custody of the INS and may only 

be transferred or released under the authority of the INS; provided, however, that in the event of an 

emergency a licensed program may transfer temporary physical custody of a minor prior to securing 

permission from the INS but shall notify the INS of the transfer as soon as is practicable thereafter, but in 

all cases within 8 hours. 

20. Within 60 days of final court approval of this Agreement, the INS shall authorize the United States 

Department of Justice Community Relations Service to publish in the Commerce Business Daily and/or 

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the Federal Register a Program Announcement to solicit proposals for the care of 100 minors in licensed 

programs. 

21. A minor may be held in or transferred to a suitable State or county juvenile detention facility or a 

secure INS detention facility, or INS-contracted facility, having separate accommodations for minors 

whenever the District Director or Chief Patrol Agent determines that the minor: 

A. has been charged with, is chargeable, or has been convicted of a crime, or is the subject of 

delinquency proceedings, has been adjudicated delinquent, or is chargeable with a delinquent 

act; provided, however, that this provision shall not apply to any minor whose offense(s) fall(s) 

within either of the following categories: 

i. Isolated offenses that (1) were not within a pattern or practice of criminal activity 

and (2) did not involve violence against a person or the use or carrying of a weapon 

(Examples: breaking and entering, vandalism, DUI, etc. This list is not exhaustive.); 

ii. Petty offenses, which are not considered grounds for stricter means of detention in 

any case (Examples: shoplifting, joy riding, disturbing the peace, etc. This list is not 

exhaustive.); 

As used in this paragraph, "chargeable" means that the INS has probable cause to believe that 

the individual has committed a specified offense; 

B. has committed, or has made credible threats to commit, a violent or malicious act (whether 

directed at himself or others) while in INS legal custody or while in the presence of an INS officer; 

C. has engaged, while in a licensed program, in conduct that has proven to be unacceptably 

disruptive of the normal functioning of the licensed program in which he or she has been placed 

and removal is necessary to ensure the welfare of the minor or others, as determined by the staff 

of the licensed program (Examples: drug or alcohol abuse, stealing, fighting, intimidation of 

others, etc. This list is not exhaustive.); 

D. is an escape-risk; or 

E. must be held in a secure facility for his or her own safety, such as when the INS has reason to 

believe that a smuggler would abduct or coerce a particular minor to secure payment of 

smuggling fees. 

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22. The term "escape-risk" means that there is a serious risk that the minor will attempt to escape from 

custody. Factors to consider when determining whether a minor is an escape-risk or not include, but are 

not limited to, whether: 

A. the minor is currently under a final order of deportation or exclusion; 

B. the minor's immigration history includes: a prior breach of a bond; a failure to appear before 

the INS or the immigration court; evidence that the minor is indebted to organized smugglers for 

his transport; or a voluntary departure or a previous removal from the United States pursuant to a 

final order of deportation or exclusion; 

C. the minor has previously absconded or attempted to abscond from INS custody. 

23. The INS will not place a minor in a secure facility pursuant to Paragraph 21 if there are less restrictive 

alternatives that are available and appropriate in the circumstances, such as transfer to (a) a medium 

security facility which would provide intensive staff supervision and counseling services or (b) another 

licensed program. All determinations to place a minor in a secure facility will be reviewed and approved 

by the regional juvenile coordinator. 

24A. A minor in deportation proceedings shall be afforded a bond redetermination hearing before an 

immigration judge in every case, unless the minor indicates on the Notice of Custody Determination form 

that he or she refuses such a hearing. 

B. Any minor who disagrees with the INS's determination to place that minor in a particular type of facility, 

or who asserts that the licensed program in which he or she has been placed does not comply with the 

standards set forth in Exhibit 1 attached hereto, may seek judicial review in any United States District 

Court with jurisdiction and venue over the matter to challenge that placement determination or to allege 

noncompliance with the standards set forth in Exhibit 1. In such an action, the United States District Court 

shall be limited to entering an order solely affecting the individual claims of the minor bringing the action. 

C. In order to permit judicial review of Defendants' placement decisions as provided in this Agreement, 

Defendants shall provide minors not placed in licensed programs with a notice of the reasons for housing 

the minor in a detention or medium security facility. With respect to placement decisions reviewed under 

this paragraph, the standard of review for the INS's exercise of its discretion shall be the abuse of 

discretion standard of review. With respect to all other matters for which this paragraph provides judicial 

review, the standard of review shall be de novo review. 

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D. The INS shall promptly provide each minor not released with (a) INS Form I-770; (b) an explanation of 

the right of judicial review as set out in Exhibit 6, and (c) the list of free legal services providers compiled 

pursuant to INS regulation (unless previously given to the minor). 

E. Exhausting the procedures established in Paragraph 37 of this Agreement shall not be a precondition 

to the bringing of an action under this paragraph in any United District Court. Prior to initiating any such 

action, however, the minor and/or the minors' attorney shall confer telephonically or in person with the 

United States Attorney's office in the judicial district where the action is to be filed, in an effort to informally 

resolve the minor's complaints without the need of federal court intervention. 

VIII TRANSPORTATION OF MINORS 

25. Unaccompanied minors arrested or taken into custody by the INS should not be transported by the 

INS in vehicles with detained adults except 

A. when being transported from the place of arrest or apprehension to an INS office, or 

B. where separate transportation would be otherwise impractical. 

When transported together pursuant to Clause (B) minors shall be separated from adults. The INS shall 

take necessary precautions for the protection of the well-being of such minors when transported with 

adults. 

26. The INS shall assist without undue delay in making transportation arrangements to the INS office 

nearest the location of the person or facility to whom a minor is to be released pursuant to Paragraph 14. 

The INS may, in its discretion, provide transportation to minors. 

IX TRANSFER OF MINORS 

27. Whenever a minor is transferred from one placement to another, the minor shall be transferred with all 

of his or her possessions and legal papers; provided, however, that if the minor's possessions exceed the 

amount permitted normally by the carrier in use, the possessions will be shipped to the minor in a timely 

manner. No minor who is represented by counsel shall be transferred without advance notice to such 

counsel, except in unusual and compelling circumstances such as where the safety of the minor or others 

is threatened or the minor has been determined to be an escape-risk, or where counsel has waived such 

notice, in which cases notice shall be provided to counsel within 24 hours following transfer. 

X MONITORING AND REPORTS 

28A. An INS Juvenile Coordinator in the Office of the Assistant Commissioner for Detention and 

Deportation shall monitor compliance with the terms of this Agreement and shall maintain an up-to-date 

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record of all minors who are placed in proceedings and remain in INS custody for longer than 72 hours. 

Statistical information on such minors shall be collected weekly from all INS district offices and Border 

Patrol stations. Statistical information will include at least the following: (1) biographical information such 

as each minor's name, date of birth, and country of birth, (2) date placed in INS custody, (3) each date 

placed, removed or released, (4) to whom and where placed, transferred, removed or released, (5) 

immigration status, and (6) hearing dates. The INS, through the Juvenile Coordinator, shall also collect 

information regarding the reasons for every placement of a minor in a detention facility or medium 

security facility. 

B. Should Plaintiffs' counsel have reasonable cause to believe that a minor in INS legal custody should 

have been released pursuant to Paragraph 14, Plaintiffs' counsel may contact the Juvenile Coordinator to 

request that the Coordinator investigate the case and inform Plaintiffs' counsel of the reasons why the 

minor has not been released. 

29. On a semi-annual basis, until two years after the court determines, pursuant to Paragraph 31, that the 

INS has achieved substantial compliance with the terms of this Agreement, the INS shall provide to 

Plaintiffs' counsel the information collected pursuant to Paragraph 28, as permitted by law, and each INS 

policy or instruction issued to INS employees regarding the implementation of this Agreement. In addition, 

Plaintiffs' counsel shall have the opportunity to submit questions, on a semi-annual basis, to the Juvenile 

Coordinator in the Office of the Assistant Commissioner for Detention and Deportation with regard to the 

implementation of this Agreement and the information provided to Plaintiffs' counsel during the preceding 

six-month period pursuant to Paragraph 28. Plaintiffs' counsel shall present such questions either orally or 

in writing, at the option of the Juvenile Coordinator. The Juvenile Coordinator shall furnish responses, 

either orally or in writing at the option of Plaintiffs' counsel, within 30 days of receipt. 

30. On an annual basis, commencing one year after final court approval of this Agreement, the INS 

Juvenile Coordinator shall review, assess, and report to the court regarding compliance with the terms of 

this Agreement. The Coordinator shall file these reports with the court and provide copies to the parties, 

including the final report referenced in Paragraph 35, so that they can submit comments on the report to 

the court. In each report, the Coordinator shall state to the court whether or not the INS is in substantial 

compliance with the terms of this Agreement, and, if the INS is not in substantial compliance, explain the 

reasons for the lack of compliance. The Coordinator shall continue to report on an annual basis until three 

years after the court determines that the INS has achieved substantial compliance with the terms of this 

Agreement. 

31. One year after the court's approval of this Agreement, the Defendants may ask the court to determine 

whether the INS has achieved substantial compliance with the terms of this Agreement. 

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XI ATTORNEY-CLIENT VISITS 

32. A. Plaintiffs' counsel are entitled to attorney-client visits with class members even though they may 

not have the names of class members who are housed at a particular location. All visits shall occur in 

accordance with generally applicable policies and procedures relating to attorney-client visits at the facility 

in question. Upon Plaintiffs' counsel's arrival at a facility for attorney-client visits, the facility staff shall 

provide Plaintiffs' counsel with a list of names and alien registration numbers for the minors housed at that 

facility. In all instances, in order to memorialize any visit to a minor by Plaintiffs' counsel, Plaintiffs' 

counsel must file a notice of appearance with the INS prior to any attorney-client meeting. Plaintiffs' 

counsel may limit any such notice of appearance to representation of the minor in connection with this 

Agreement. Plaintiffs' counsel must submit a copy of the notice of appearance by hand or by mail to the 

local INS juvenile coordinator and a copy by hand to the staff of the facility. 

B. Every six months, Plaintiffs' counsel shall provide the INS with a list of those attorneys who may make 

such attorney-client visits, as Plaintiffs' counsel, to minors during the following six month period. Attorneyclient visits may also be conducted by any staff attorney employed by the Center for Human Rights & 

Constitutional Law in Los Angeles, California or the National Center for Youth Law in San Francisco, 

California, provided that such attorney presents credentials establishing his or her employment prior to 

any visit. 

C. Agreements for the placement of minor in non-INS facilities shall permit attorney-client visits, including 

by class counsel in this case. 

D. Nothing in Paragraph 32 shall affect a minor's right to refuse to meet with Plaintiffs' counsel. Further, 

the minor's parent or legal guardian may deny Plaintiffs' counsel permission to meet with the minor. 

XII FACILITY VISITS 

33. In addition to the attorney-client visits permitted pursuant to Paragraph 32, Plaintiffs' counsel may 

request access to any licensed program's facility in which a minor has been placed pursuant to Paragraph 

19 or to any medium security facility or detention facility in which a minor has been placed pursuant to 

Paragraphs 21 or 23. Plaintiffs' counsel shall submit a request to visit a facility under this paragraph to the 

INS district juvenile coordinator who will provide reasonable assistance to Plaintiffs' counsel by conveying 

the request to the facility's staff and coordinating the visit. The rules and procedures to be followed in 

connection with any visit approved by a facility under this paragraph are set forth in Exhibit 4 attached, 

except as may be otherwise agreed by Plaintiffs' counsel and the facility's staff. In all visits to any facility 

pursuant to this Agreement, Plaintiffs' counsel and their associated experts shall treat minors and staff 

with courtesy and dignity and shall not disrupt the normal functioning of the facility. 

XIII TRAINING 

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34. Within 120 days of final court approval of this Agreement, the INS shall provide appropriate guidance 

and training for designated INS employees regarding the terms of this Agreement. The INS shall develop 

written and/or audio or video materials for such training. Copies of such written and/or audio or video 

training materials shall be made available to Plaintiffs' counsel when such training materials are sent to 

the field, or to the extent practicable, prior to that time. 

XIV DISMISSAL 

35. After the court has determined that the INS is in substantial compliance with this Agreement and the 

Coordinator has filed a final report, the court, without further notice, shall dismiss this action. Until such 

dismissal, the court shall retain jurisdiction over this action. 

XV RESERVATION OF RIGHTS 

36. Nothing in this agreement shall limit the rights, if any, of individual class members to preserve issues 

for judicial review in the appeal of an individual case or for class members to exercise any independent 

rights they may otherwise have. 

XVI NOTICE AND DISPUTE RESOLUTION 

37. This paragraph provides for the enforcement, in this District Court, of the provisions of this Agreement 

except for claims brought under Paragraph 24. The parties shall meet telephonically or in person to 

discuss a complete or partial repudiation of this Agreement or any alleged non-compliance with the terms 

of the Agreement, prior to bringing any individual or class action to enforce this Agreement. Notice of a 

claim that defendants have violated the terms of this Agreement shall be served on plaintiffs addressed 

to:

CENTER FOR HUMAN RIGHTS & CONSTITUTIONAL LAW 

Carlos Holguín 

Peter A. Schey 

256 South Occidental Boulevard 

Los Angeles, CA 90057 

NATIONAL CENTER FOR YOUTH LAW 

Alice Bussiere 

James Morales 

114 Sansome Street, Suite 905 

San Francisco, CA 94104 

and on Defendants addressed to: 

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Michael Johnson 

Assistant United States Attorney 

300 N. Los Angeles St., Rm. 7516 

Los Angeles, CA 90012 

Allen Hausman 

Office of Immigration Litigation 

Civil Division 

U.S. Department of Justice 

P.O. Box 878, Ben Franklin Station 

Washington, DC 20044 

XVII PUBLICITY 

38. Plaintiffs and Defendants shall hold a joint press conference to announce this Agreement. The INS 

shall send copies of this Agreement to social service and voluntary agencies agreed upon by the parties, 

as set forth in Exhibit 5 attached. The parties shall pursue such other public dissemination of information 

regarding this Agreement as the parties shall agree. 

XVIII ATTORNEYS FEES AND COSTS 

39. Within 60 days of final court approval of this Agreement, Defendants shall pay to Plaintiffs the total 

sum of $______, in full settlement of all attorneys' fees and costs in this case. 

XIX TERMINATION 

40. All terms of this Agreement shall terminate the earlier of five years from the date of final court 

approval of this Agreement or three years after the court determines that the INS is in substantial 

compliance with the Agreement, except the following: the INS shall continue to house the general 

population of minors in INS custody in facilities that are state-licensed for the care of dependent minors. 

XX REPRESENTATIONS AND WARRANTY 

41. Counsel for the respective parties, on behalf of themselves and their clients, represent that they know 

of nothing in this Agreement that exceeds the legal authority of the parties or is in violation of any law. 

Defendants' counsel represent and warrant that they are fully authorized and empowered to enter into this 

Agreement on behalf of the Attorney General, the United States Department of Justice, and the 

Immigration and Naturalization Service, and acknowledge that Plaintiffs enter into this Agreement in 

reliance on such representation. Plaintiffs' counsel represent and warrant that they are fully authorized 

and empowered to enter into this Agreement on behalf of the Plaintiffs, and acknowledge that Defendants 

enter into this Agreement in reliance on such representation. The undersigned, by their signatures on 

AILA InfoNet Doc. No. 14111359. (Posted 11/13/14) PSI-014
behalf of the Plaintiffs and Defendants, warrant that upon execution of this Agreement in their 

representative capacities, their principals, agents, and successors of such principals and agents shall be 

fully and unequivocally bound hereunder to the full extent authorized by law. 

EXHIBIT 1 

Minimum Standards for Licensed Programs 

A. Licensed programs shall comply with all applicable state child welfare laws and regulations and all 

state and local building, fire, health and safety codes and shall provide or arrange for the following 

services for each minor in its care: 

1. Proper physical care and maintenance, including suitable living accommodations, food, 

appropriate clothing, and personal grooming items. 

2. Appropriate routine medical and dental care, family planning services, and emergency health 

care services, including a complete medical examination (including screening for infectious 

disease) within 48 hours of admission, excluding weekends and holidays, unless the minor was 

recently examined at another facility; appropriate immunizations in accordance with the U.S. 

Public Health Service (PHS), Center for Disease Control; administration of prescribed medication 

and special diets; appropriate mental health interventions when necessary. 

3. An individualized needs assessment which shall include: (a) various initial intake forms; (b) 

essential data relating to the identification and history of the minor and family; (c) identification of 

the minors' special needs including any specific problem(s) which appear to require immediate 

intervention; (d) an educational assessment and plan; (e) an assessment of family relationships 

and interaction with adults, peers and authority figures; (f) a statement of religious preference and 

practice; (g) an assessment of the minor's personal goals, strengths and weaknesses; and (h) 

identifying information regarding immediate family members, other relatives, godparents or 

friends who may be residing in the United States and may be able to assist in family reunification. 

4. Educational services appropriate to the minor's level of development, and communication skills 

in a structured classroom setting, Monday through Friday, which concentrates primarily on the 

development of basic academic competencies and secondarily on English Language Training 

(ELT). The educational program shall include instruction and educational and other reading 

materials in such languages as needed. Basic academic areas should include Science, Social 

Studies, Math, Reading, Writing and Physical Education. The program shall provide minors with 

AILA InfoNet Doc. No. 14111359. (Posted 11/13/14) PSI-015
appropriate reading materials in languages other than English for use during the minor's leisure 

time.

5. Activities according to a recreation and leisure time plan which shall include daily outdoor 

activity, weather permitting, at least one hour per day of large muscle activity and one hour per 

day of structured leisure time activities (this should not include time spent watching television). 

Activities should be increased to a total of three hours on days when school is not in session. 

6. At least one (1) individual counseling session per week conducted by trained social work staff 

with the specific objectives of reviewing the minor's progress, establishing new short term 

objectives, and addressing both the developmental and crisis-related needs of each minor. 

7. Group counseling sessions at least twice a week. This is usually an informal process and takes 

place with all the minors present. It is a time when new minors are given the opportunity to get 

acquainted with the staff, other children, and the rules of the program. It is an open forum where 

everyone gets a chance to speak. Daily program management is discussed and decisions are 

made about recreational activities, etc. It is a time for staff and minors to discuss whatever is on 

their minds and to resolve problems. 

8. Acculturation and adaptation services which include information regarding the development of 

social and inter-personal skills which contribute to those abilities necessary to live independently 

and responsibly. 

9. Upon admission, a comprehensive orientation regarding program intent, services, rules (written 

and verbal), expectations and the availability of legal assistance. 

10. Whenever possible, access to religious services of the minor's choice. 

11. Visitation and contact with family members (regardless of their immigration status) which is 

structured to encourage such visitation. The staff shall respect the minor's privacy while 

reasonably preventing the unauthorized release of the minor. 

12. A reasonable right to privacy, which shall include the right to: (a) wear his or her own clothes, 

when available; (b) retain a private space in the residential facility, group or foster home for the 

storage of personal belongings; (c) talk privately on the phone, as permitted by the house rules 

and regulations; (d) visit privately with guests, as permitted by the house rules and regulations; 

and (e) receive and send uncensored mail unless there is a reasonable belief that the mail 

contains contraband. 

AILA InfoNet Doc. No. 14111359. (Posted 11/13/14) PSI-016
13. Family reunification services designed to identify relatives in the United States as well as in 

foreign countries and assistance in obtaining legal guardianship when necessary for the release 

of the minor.

14. Legal services information regarding the availability of free legal assistance, the right to be 

represented by counsel at no expense to the government, the right to a deportation or exclusion 

hearing before an immigration judge, the right to apply for political asylum or to request voluntary 

departure in lieu of deportation. 

B. Service delivery is to be accomplished in a manner which is sensitive to the age, culture, native 

language and the complex needs of each minor. 

C. Program rules and discipline standards shall be formulated with consideration for the range of ages 

and maturity in the program and shall be culturally sensitive to the needs of alien minors. Minors shall not 

be subjected to corporal punishment, humiliation, mental abuse, or punitive interference with the daily 

functions of living, such as eating or sleeping. Any sanctions employed shall not: (1) adversely affect 

either a minor's health, or physical or psychological well-being; or (2) deny minors regular meals, 

sufficient sleep, exercise, medical care, correspondence privileges, or legal assistance. 

D. A comprehensive and realistic individual plan for the care of each minor must be developed in 

accordance with the minor's needs as determined by the individualized need assessment. Individual 

plans shall be implemented and closely coordinated through an operative case management system. 

E. Programs shall develop, maintain and safeguard individual client case records. Agencies and 

organizations are required to develop a system of accountability which preserves the confidentiality of 

client information and protects the records from unauthorized use or disclosure. 

F. Programs shall maintain adequate records and make regular reports as required by the INS that permit 

the INS to monitor and enforce this order and other requirements and standards as the INS may 

determine are in the best interests of the minors. 

Exhibit 2 

Instructions to Service Officers re: 

Processing, Treatment, and Placement of Minors 

These instructions are to advise Service officers of INS policy regarding the way in which minors in INS 

custody are processed, housed and released. These instructions are applicable nationwide and 

supersede all prior inconsistent instructions regarding minors. 

AILA InfoNet Doc. No. 14111359. (Posted 11/13/14) PSI-017
(a) Minors. A minor is a person under the age of eighteen years. However, individuals who have been 

"emancipated" by a state court or convicted and incarcerated for a criminal offense as an adult are not 

considered minors. Such individuals must be treated as adults for all purposes, including confinement and 

release on bond. 

Similarly, if a reasonable person would conclude that an individual is an adult despite his claims to be a 

minor, the INS shall treat such person as an adult for all purposes, including confinement and release on 

bond or recognizance. The INS may require such an individual to submit to a medical or dental 

examination conducted by a medical professional or to submit to other appropriate procedures to verify 

his or her age. If the INS subsequently determines that such an individual is a minor, he or she will be 

treated as a minor for all purposes. 

(b) General policy. The INS treates and shall continued to treat minors with dignity, respect and special 

concern for their particular vulnerability. INS policy is to place each detained minor in the least restrictive 

setting appropriate to the minor's age and special needs, provided that such setting is consistent with the 

need to ensure the minor's timely appearance and to protect the minor's well-being and that of others. 

INS officers are not required to release a minor to any person or agency whom they have reason to 

believe may harm or neglect the minor or fail to present him or her before the INS or the immigration 

courts when requested to do so. 

(c) Processing. The INS will expeditiously process minors and will provide them a Form I-770 notice of 

rights, including the right to a bond redetermination hearing, if applicable. 

Following arrest, the INS will hold minors in a facility that is safe and sanitary and that is consistent with 

the INS's concern for the particular vulnerability of minors. Such facilities will have access to toilets and 

sinks, drinking water and food as appropriate, medical assistance if the minor is in need of emergency 

services, adequate temperature control and ventilation, adequate supervision to protect minors from 

others, and contact with family members who were arrested with the minor. The INS will separate 

unaccompanied minors from unrelated adults whenever possible. Where such segregation is not 

immediately possible, an unaccompanied minor will not be detained with an unrelated adult for more than 

24 hours. 

If the minor cannot be immediately released, and no licensed program (described below) is available to 

care for him, he should be placed in an INS or INS-contract facility that has separate accommodations for 

minors, or in a State or county juvenile detention facility that separates minors in INS custody from 

delinquent offenders. The INS will make every effort to ensure the safety and well-being of juveniles 

placed in these facilities. 

AILA InfoNet Doc. No. 14111359. (Posted 11/13/14) PSI-018
(d) Release. The INS will release minors from its custody without unnecessary delay, unless detention of 

a juvenile is required to secure her timely appearance or to ensure the minor's safety or that of others. 

Minors shall be released in the following order of preference, to: 

(i) a parent; 

(ii) a legal guardian; 

(iii) an adult relative (brother, sister, aunt, uncle, or grandparent); 

(iv) an adult individual or entity designated by the parent or legal guardian as capable and 

willing to care for the minor's well-being in (i) a declaration signed under penalty of perjury 

before an immigration or consular officer, or (ii) such other documentation that establishes to 

the satisfaction of the INS, in its discretion, that the individual designating the individual or 

entity as the minor's custodian is in fact the minor's parent or guardian; 

(v) a state-licensed juvenile shelter, group home, or foster home willing to accept legal 

custody; or 

(vi) an adult individual or entity seeking custody, in the discretion of the INS, when it appears 

that there is no other likely alternative to long term detention and family reunification does not 

appear to be a reasonable possibility. 

(e) Certification of custodian. Before a minor is released, the custodian must execute an Affidavit of 

Support (Form I-134) and an agreement to: 

(i) provide for the minor's physical, mental, and financial well-being; 

(ii) ensure the minor's presence at all future proceedings before the INS and the immigration 

court; 

(iii) notify the INS of any change of address within five (5) days following a move; 

(iv) if the custodian is not a parent or legal guardian, not transfer custody of the minor to 

another party without the prior written permission of the District Director, except in the event 

of an emergency; 

(v) notify the INS at least five days prior to the custodian's departing the United States of such 

departure, whether the departure is voluntary or pursuant to a grant of voluntary departure or 

order of deportation; and 

AILA InfoNet Doc. No. 14111359. (Posted 11/13/14) PSI-019
(vi) if dependency proceedings involving the minor are initiated, notify the INS of the initiation 

of a such proceedings and the dependency court of any deportation proceedings pending 

against the minor. 

In an emergency, a custodian may transfer temporary physical custody of a minor prior to securing 

permission from the INS, but must notify the INS of the transfer as soon as is practicable, and in all cases 

within 72 hours. Examples of an "emergency" include the serious illness of the custodian, destruction of 

the home, etc. In all cases where the custodian seeks written permission for a transfer, the District 

Director shall promptly respond to the request. 

The INS may terminate the custody arrangements and assume legal custody of any minor whose 

custodian fails to comply with the agreement. However, custody arrangements will not be terminated for 

minor violations of the custodian's obligation to notify the INS of any change of address within five days 

following a move. 

(f) Suitability assessment. An INS officer may require a positive suitability assessment prior to releasing 

a minor to any individual or program. A suitability assessment may include an investigation of the living 

conditions in which the minor is to be placed and the standard of care he would receive, verification of 

identity and employment of the individuals offering support, interviews of members of the household, and 

a home visit. The assessment will also take into consideration the wishes and concerns of the minor. 

(g) Family reunification. Upon taking a minor into custody, the INS, or the licensed program in which the 

minor is placed, will promptly attempt to reunite the minor with his or her family to permit the release of 

the minor under Paragraph (d) above. Such efforts at family reunification will continue so long as the 

minor is in INS or licensed program custody and will be recorded by the INS or the licensed program in 

which the minor is placed. 

(h) Placement in licensed programs. A "licensed program" is any program, agency or organization 

licensed by an appropriate state agency to provide residential group, or foster care services for 

dependent children, including a program operating group homes, foster homes or facilities for special 

needs minors. Exhibit 1 of the Flores v. Reno Settlement Agreement describes the standards required of 

licensed programs. Juveniles who remain in INS custody must be placed in a licensed program within 

three days if the minor was apprehended in an INS district in which a licensed program is located and has 

space available, or within five days in all other cases, except when: 

(i) the minor is an escape risk or delinquent, as defined in Paragraph (l) below; 

(ii) a court decree or court-approved settlement requires otherwise; 

AILA InfoNet Doc. No. 14111359. (Posted 11/13/14) PSI-020
(iii) an emergency or influx of minors into the United States prevents compliance, in which 

case all minors should be placed in licensed programs as expeditiously as possible; or 

(iv) where the minor must be transported from remote areas for processing or speaks an 

unusual language such that a special interpreter is required to process the minor, in which 

case the minor must be placed in a licensed program within five business days. 

(i) Secure and supervised detention. A minor may be held in or transferred to a State or county juvenile 

detention facility or in a secure INS facility or INS-contracted facility having separate accommodations for 

minors, whenever the District Director or Chief Patrol Agent determines that the minor - 

(i) has been charged with, is chargeable, or has been convicted of a crime, or is the subject 

of delinquency proceedings, has been adjudicated delinquent, or is chargeable with a 

delinquent act, unless the minor's offense is 

(a) an isolated offense not within a pattern of criminal activity which did not involve 

violence against a person or the use or carrying of a weapon (Examples: breaking 

and entering, vandalism, DUI, etc. ); or 

(b) a petty offense, which is not considered grounds for stricter means of detention in 

any case (Examples: shoplifting, joy riding, disturbing the peace, etc.);

(ii) has committed, or has made credible threats to commit, a violent or malicious act 

(whether directed at himself or others) while in INS legal custody or while in the presence of 

an INS officer; 

(iii) has engaged, while in a licensed program, in conduct that has proven to be unacceptably 

disruptive of the normal functioning of the licensed program in which he or she has been 

placed and removal is necessary to ensure the welfare of the minor or others, as determined 

by the staff of the licensed program (Examples: drug or alcohol abuse, stealing, fighting, 

intimidation of others, etc.); 

(iv) is an escape-risk; or 

(v) must be held in a secure facility for his or her own safety, such as when the INS has 

reason to believe that a smuggler would abduct or coerce a particular minor to secure 

payment of smuggling fees. 

AILA InfoNet Doc. No. 14111359. (Posted 11/13/14) PSI-021
"Chargeable" means that the INS has probable cause to believe that the individual has committed a 

specified offense. 

The term "escape-risk" means that there is a serious risk that the minor will attempt to escape from 

custody. Factors to consider when determining whether a minor is an escape-risk or not include, but are 

not limited to, whether: 

(a) the minor is currently under a final order of deportation or exclusion; 

(b) the minor's immigration history includes: a prior breach of a bond; a failure to appear 

before the INS or the immigration court; evidence that the minor is indebted to organized 

smugglers for his transport; or a voluntary departure or a previous removal from the United 

States pursuant to a final order of deportation or exclusion; 

(c) the minor has previously absconded or attempted to abscond from INS custody. 

The INS will not place a minor in a State or county juvenile detention facility, secure INS detention facility, 

or secure INS-contracted facility if less restrictive alternatives are available and appropriate in the 

circumstances, such as transfer to a medium security facility that provides intensive staff supervision and 

counseling services or transfer to another licensed program. All determinations to place a minor in a 

secure facility must be reviewed and approved by the regional Juvenile Coordinator. 

(j) Notice of right to bond redetermination and judicial review of placement. A minor in deportation 

proceedings shall be afforded a bond redetermination hearing before an immigration judge in every case 

in which he either affirmatively requests, or fails to request or refuse, such a hearing on the Notice of 

Custody Determination. A juvenile who is not released or placed in a licensed placement shall be 

provided (1) a written explanation of the right of judicial review in the form attached, and (2) the list of free 

legal services providers compiled pursuant to 8 C.F.R. § 292a. 

(k) Transportation and transfer. Unaccompanied minors should not be transported in vehicles with 

detained adults except when being transported from the place of arrest or apprehension to an INS office 

or where separate transportation would be otherwise impractical, in which case minors shall be separated 

from adults. INS officers shall take all necessary precautions for the protection of minors during 

transportation with adults. 

When a minor is to be released, the INS will assist him or her in making transportation arrangements to 

the INS office nearest the location of the person or facility to whom a minor is to be released. The Service 

may, in its discretion, provide transportation to such minors. 

AILA InfoNet Doc. No. 14111359. (Posted 11/13/14) PSI-022
Whenever a minor is transferred from one placement to another, she shall be transferred with all of her 

possessions and legal papers; provided, however, that if the minor's possessions exceed the amount 

permitted normally by the carrier in use, the possessions must be shipped to the minor in a timely 

manner. No minor who is represented by counsel should be transferred without advance notice to 

counsel, except in unusual and compelling circumstances such as where the safety of the minor or others 

is threatened or the minor has been determined to be an escape-risk, or where counsel has waived 

notice, in which cases notice must be provided to counsel within 24 hours following transfer. 

(l) Periodic reporting. All INS district offices and Border Patrol stations must report to the Juvenile 

Coordinator statistical information on minors placed in proceedings who remain in INS custody for longer 

than 72 hours. Information will include: (a) biographical information, including the minor's name, date of 

birth, and country of birth, (b) date placed in INS custody, (c) each date placed, removed or released, (d) 

to whom and where placed, transferred, removed or released, (e) immigration status, and (f) hearing 

dates. The Juvenile Coordinator must also be informed of the reasons for placing a minor in a medium 

security facility or detention facility as described in paragraph (i). 

(m) Attorney-client visits by Plaintiffs' counsel. The INS will permit lawyers for the Reno v. Flores 

plaintiff class to visit minors even though they may not have the names of minors who are housed at a 

particular location. A list of Plaintiffs' counsel entitled to make attorney-client visits with minors is available 

from the district Juvenile Coordinator. Attorney-client visits may also be conducted by any staff attorney 

employed by the Center for Human Rights & Constitutional Law of Los Angeles, California, or the 

National Center for Youth Law of San Francisco, California, provided that such attorney presents 

credentials establishing his or her employment prior to any visit. 

Visits must occur in accordance with generally applicable policies and procedures relating to attorneyclient visits at the facility in question. Upon Plaintiffs' counsel's arrival at a facility for attorney-client visits, 

the facility staff must provide Plaintiffs' counsel with a list of names and alien registration numbers for the 

minors housed at that facility. In all instances, in order to memorialize any visit to a minor by Plaintiffs' 

counsel, Plaintiffs' counsel must file a notice of appearance with the INS prior to any attorney-client 

meeting. Plaintiffs' counsel may limit the notice of appearance to representation of the minor in 

connection with his placement or treatment during INS custody. Plaintiffs' counsel must submit a copy of 

the notice of appearance by hand or by mail to the local INS juvenile coordinator and a copy by hand to 

the staff of the facility. 

A minor may refuse to meet with Plaintiffs' counsel. Further, the minor's parent or legal guardian may 

deny Plaintiffs' counsel permission to meet with the minor. 

AILA InfoNet Doc. No. 14111359. (Posted 11/13/14) PSI-023
(n) Visits to licensed facilities. In addition to the attorney-client visits, Plaintiffs' counsel may request 

access to a licensed program's facility (described in paragraph (h)) or to a medium-security facility or 

detention facility (described in paragraph (i)) in which a minor has been placed. The district juvenile 

coordinator will convey the request to the facility's staff and coordinate the visit. The rules and procedures 

to be followed in connection with such visits are set out in Exhibit 4 of the Flores v. Reno Settlement 

Agreement,, unless Plaintiffs' counsel and the facility's staff agree otherwise. In all visits to any facility, 

Plaintiffs' counsel and their associated experts must treat minors and staff with courtesy and dignity and 

must not disrupt the normal functioning of the facility. 

EXHIBIT 3 

Contingency Plan 

In the event of an emergency or influx that prevents the prompt placement of minors in licensed programs 

with which the Community Relations Service has contracted, INS policy is to make all reasonable efforts 

to place minors in licensed programs licensed by an appropriate state agency as expeditiously as 

possible. An emergency is an act or event, such as a natural disaster (e.g. earthquake, fire, hurricane), 

facility fire, civil disturbance, or medical emergency (e.g. a chicken pox epidemic among a group of 

minors) that prevents the prompt placement of minors in licensed facilities. An influx is defined as any 

situation in which there are more than 130 minors in the custody of the INS who are eligible for placement 

in licensed programs. 

1. The Juvenile Coordinator will establish and maintain an Emergency Placement List of at least 80 beds 

at programs licensed by an appropriate state agency that are potentially available to accept emergency 

placements. These 80 placements would supplement the 130 placements that INS normally has 

available, and whenever possible, would meet all standards applicable to juvenile placements the INS 

normally uses. The Juvenile Coordinator may consult with child welfare specialists, group home 

operators, and others in developing the list. The Emergency Placement List will include the facility name; 

the number of beds at the facility; the name and telephone number of contact persons; the name and 

telephone number of contact persons for nights, holidays, and weekends if different; any restrictions on 

minors accepted (e.g. age); and any special services that are available. 

2. The Juvenile Coordinator will maintain a list of minors affected by the emergency or influx, including (1) 

the minor's name, (2) date and country of birth, and (3) date placed in INS custody. 

3. Within one business day of the emergency or influx the Juvenile Coordinator, or his or her designee will 

contact the programs on the Emergency Placement List to determine available placements. As soon as 

available placements are identified, the Juvenile Coordinator will advise appropriate INS staff of their 

AILA InfoNet Doc. No. 14111359. (Posted 11/13/14) PSI-024
availability. To the extent practicable, the INS will attempt to locate emergency placements in geographic 

areas where culturally and linguistically appropriate community services are available. 

4. In the event that the number of minors needing emergency placement exceeds the available 

appropriate placements on the Emergency Placement List, the Juvenile Coordinator will work with the 

Community Relations Service to locate additional placements through licensed programs, county social 

services departments, and foster family agencies. 

5. Each year, the INS will reevaluate the number of regular placements needed for detained minors to 

determine whether the number of regular placements should be adjusted to accommodate an increased 

or decreased number of minors eligible for placement in licensed programs. However, any decision to 

increase the number of placements available shall be subject to the availability of INS resources. The 

Juvenile Coordinator shall promptly provide Plaintiffs' counsel with any reevaluation made by INS 

pursuant to this paragraph. 

6. The Juvenile Coordinator shall provide to Plaintiffs' counsel copies of the Emergency Placement List 

within six months after the court's final approval of the Settlement Agreement. 

EXHIBIT 4 

Agreement Concerning Facility Visits Under Paragraph 33 

The purpose of facility visits under paragraph 33 is to interview class members and staff and to observe 

conditions at the facility. Visits under paragraph 33 shall be conducted in accordance with the generally 

applicable policies and procedures of the facility to the extent that those policies and procedures are 

consistent with this Exhibit. 

Visits authorized under paragraph 33 shall be scheduled no less than seven (7) business days in 

advance. The names, positions, credentials, and professional association (e.g., Center for Human Rights 

and Constitutional Law) of the visitors will be provided at that time. 

All visits with class members shall take place during normal business hours. 

No video recording equipment or cameras of any type shall be permitted. Audio recording equipment 

shall be limited to hand-held tape recorders. 

The number of visitors will not exceed six (6) or, in the case of a family foster home, four (4), including 

interpreters, in any instance. Up to two (2) of the visitors may be non-attorney experts in juvenile justice 

and/or child welfare. 

AILA InfoNet Doc. No. 14111359. (Posted 11/13/14) PSI-025
No visit will extend beyond three (3) hours per day in length. Visits shall minimize disruption to the routine 

that minors and staff follow. 

Exhibit 5 

List of Organizations to Receive Information re: Settlement Agreement 

Eric Cohen, Immig. Legal Resource Center, 1663 Mission St. Suite 602, San Francisco, CA 94103 

Cecilia Munoz, Nat'l Council Of La Raza, 810 1st St. NE Suite 300, Washington, D.C. 20002 

Susan Alva, Immig. & Citiz. Proj Director, Coalition For Humane Immig Rights of LA, 1521 Wilshire Blvd., 

Los Angeles, CA 90017 

Angela Cornell, Albuquerque Border Cities Proj., Box 35895, Albuquerque, NM 87176-5895 

Beth Persky, Executive Director, Centro De Asuntos Migratorios, 1446 Front Street, Suite 305, San 

Diego, CA 92101 

Dan, Kesselbrenner, , National Lawyers Guild, National Immigration Project, 14 Beacon St.,#503, Boston, 

MA 02108 

Lynn Marcus , SWRRP, 64 E. Broadway, Tucson, AZ 85701-1720 

Maria Jimenez, , American Friends Service Cmte., ILEMP, 3522 Polk Street, Houston, TX 77003-4844 

Wendy Young, , U.S. Cath. Conf., 3211 4th St. NE, , Washington, DC, 20017-1194 

Miriam Hayward , International Institute Of The East Bay, 297 Lee Street , Oakland, CA 94610 

Emily Goldfarb, , Coalition For Immigrant & Refugee Rights, 995 Market Street, Suite 1108 , San 

Francisco, CA 94103 

Jose De La Paz, Director, California Immigrant Workers Association, 515 S. Shatto Place , Los Angeles, 

CA, 90020 

Annie Wilson, LIRS, 390 Park Avenue South, First Asylum Concerns, New York, NY 10016 

Stewart Kwoh, Asian Pacific American Legal Center, 1010 S. Flower St., Suite 302, Los Angeles, CA 

90015 

Warren Leiden, Executive Director, AILA, 1400 Eye St., N.W., Ste. 1200, Washington, DC, 20005 

AILA InfoNet Doc. No. 14111359. (Posted 11/13/14) PSI-026
Frank Sharry, Nat'l Immig Ref & Citiz Forum, 220 I Street N.E., Ste. 220, Washington, D.C. 20002 

Reynaldo Guerrero, Executive Director, Center For Immigrant's Rights, 48 St. Marks Place , New York, 

NY 10003 

Charles Wheeler , National Immigration Law Center, 1102 S. Crenshaw Blvd., Suite 101 , Los Angeles, 

CA 90019 

Deborah A. Sanders, Asylum & Ref. Rts Law Project, Washington Lawyers Comm., 1300 19th Street, 

N.W., Suite 500 , Washington, D.C. 20036 

Stanley Mark, Asian American Legal Def.& Ed.Fund, 99 Hudson St, 12th Floor, New York, NY 10013 

Sid Mohn, Executive Director, Travelers & Immigrants Aid, 327 S. LaSalle Street, Suite 1500, Chicago, IL, 

60604 

Bruce Goldstein, Attornet At Law, Farmworker Justice Fund, Inc., 2001 S Street, N.W., Suite 210, 

Washington, DC 20009 

Ninfa Krueger, Director, BARCA, 1701 N. 8th Street, Suite B-28, McAllen, TX 78501 

John Goldstein, , Proyecto San Pablo, PO Box 4596,, Yuma, AZ 85364 

Valerie Hink, Attorney At Law, Tucson Ecumenical Legal Assistance, P.O. Box 3007 , Tucson, AZ 85702 

Pamela Mohr, Executive Director, Alliance For Children's Rights, 3708 Wilshire Blvd. Suite 720, Los 

Angeles, CA 90010 

Pamela Day, Child Welfare League Of America, 440 1st St. N.W., , Washington, DC 20001 

Susan Lydon, Esq., Immigrant Legal Resource Center, 1663 Mission St. Ste 602, San Francisco, CA 

94103 

Patrick Maher, Juvenile Project, Centro De Asuntos Migratorios, 1446 Front Street, # 305, San Diego, CA 

92101 

Lorena Munoz, Staff Attorney, Legal Aid Foundation of LA-IRO, 1102 Crenshaw Blvd., Los Angeles, CA 

90019 

Christina Zawisza, Staff Attorney, Legal Services of Greater Miami, 225 N.E. 34th Street, Suite 300, 

Miami, FL 33137 

AILA InfoNet Doc. No. 14111359. (Posted 11/13/14) PSI-027
Miriam Wright Edelman, Executive Director, Children's Defense Fund, 122 C Street N.W. 4th Floor, 

Washington, DC 20001 

Rogelio Nunez, Executive Director, Proyecto Libertad, 113 N. First St., Harlingen, TX 78550 

Exhibit 6 

Notice of Right to Judicial Review 

"The INS usually houses persons under the age of 18 in an open setting, such as a foster or group home, 

and not in detention facilities. If you believe that you have not been properly placed or that you have been 

treated improperly, you may ask a federal judge to review your case. You may call a lawyer to help you 

do this. If you cannot afford a lawyer, you may call one from the list of free legal services given to you with 

this form." 

AILA InfoNet Doc. No. 14111359. (Posted 11/13/14) PSI-028
PSI-029
PSI-030
PSI-031
PSI-032
PSI-033
PSI-034
PSI-035
PSI-036
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PSI-039
 

ORR UAC/FRP-2 [Rev. 05/14/2018] 

OMB 0970-0278 [valid through 10/31/2018] 

THE PAPERWORK REDUCTION ACT OF 1995 (Pub. L. 104-13) Public reporting burden for this collection of information is estimated to average 0.25 

hour per response, including the time for reviewing instructions, gathering and maintaining the data needed, and reviewing the collection of information. 

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB 

control number. Please see the accompanying privacy notice / Privacy Act statement for a discussion of (1) the authority for solicitation of information, 

and whether disclosure is mandatory or voluntary, (2) the principal purposes for which the information is intended to be used, (3) other routine uses 

which may be made of the information, and (4) the effects, if any, of not providing all or any part of the requested information.

Page 2 of 5

I Understand that this information will become the property of the ORR and may be reviewed by its 

employees, grantees, contractors, and delegates. I also understand that the ORR may share this 

information with the employees and contractors of other federal agencies. 

I Hereby Relinquish any claim or right under the laws of the United States against the federal 

government, its employees, grantees, contractors, or delegates, for the legally authorized use of any 

information gathered during a search of my criminal history, child welfare information, past or 

present immigration status, any information contained in my sponsorship application and supporting 

documentation, and any information gathered from any verbal or written sources regarding this 

sponsorship application. I hereby relinquish any claim or previous agreement with any federal, state, 

local, or private agency that would bar the ORR or the agency’s official delegate from obtaining the 

requested information. 

I declare and affirm under penalty of perjury that the information contained in this authorization is 

true and accurate to the best of my knowledge. 

YOUR SIGNATURE _________________________________________ DATE _______________ 

YOUR FULL NAME (PRINT CLEARLY) 

___________________________________________________

STAFF USE ONLY 

UAC NAME(S)

UAC A#(S) 

CARE PROVIDER 

DIGITAL SITE LOCATION (IF ANY) 

PSI-040
 

ORR UAC/FRP-2 [Rev. 05/14/2018] 

OMB 0970-0278 [valid through 10/31/2018] 

THE PAPERWORK REDUCTION ACT OF 1995 (Pub. L. 104-13) Public reporting burden for this collection of information is estimated to average 0.25 

hour per response, including the time for reviewing instructions, gathering and maintaining the data needed, and reviewing the collection of information. 

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB 

control number. Please see the accompanying privacy notice / Privacy Act statement for a discussion of (1) the authority for solicitation of information, 

and whether disclosure is mandatory or voluntary, (2) the principal purposes for which the information is intended to be used, (3) other routine uses 

which may be made of the information, and (4) the effects, if any, of not providing all or any part of the requested information.

Page 3 of 5

Information required for background check

1) About the minor(s) 

 List the names and dates of birth of all children you are applying to sponsor 

Minor’s Name Minor’s Date of Birth 

 

2) Your full name (include first name, 

middle name, and last name) 

3) Other names you have used 

List other names you have used, such as your name before you were married or maternal last 

names and when you stopped using them. 

Previous name When you stopped using this name 

(month/year, e.g., 12/2010)

 

4) Your date of birth 

 e.g., 12/31/1979 

5) Your place of birth

Where were you born? City 

State Country 

County 

PSI-041
 

ORR UAC/FRP-2 [Rev. 05/14/2018] 

OMB 0970-0278 [valid through 10/31/2018] 

THE PAPERWORK REDUCTION ACT OF 1995 (Pub. L. 104-13) Public reporting burden for this collection of information is estimated to average 0.25 

hour per response, including the time for reviewing instructions, gathering and maintaining the data needed, and reviewing the collection of information. 

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB 

control number. Please see the accompanying privacy notice / Privacy Act statement for a discussion of (1) the authority for solicitation of information, 

and whether disclosure is mandatory or voluntary, (2) the principal purposes for which the information is intended to be used, (3) other routine uses 

which may be made of the information, and (4) the effects, if any, of not providing all or any part of the requested information.

Page 4 of 5

6) Addresses: Where have you lived in the last five (5) years? 

Street address 

(+ apartment number, if 

applicable)

City 

(Country) 

State Zip 

code 

From date 

(month/year)

To date 

(month/year)

 (EXAMPLE) 

2539 Lowndes Hill Park Road San Antonio TX 78201 12/2014 11/2015 

Current Address 

 

 

Current 

 

 

 

 

 

 

Immigration Information (if applicable) 

If you are not a US citizen, please provide the following information 

7a) Alien registration number A# 

7b) Country of Citizenship 

PSI-042
 

ORR UAC/FRP-2 [Rev. 05/14/2018] 

OMB 0970-0278 [valid through 10/31/2018] 

THE PAPERWORK REDUCTION ACT OF 1995 (Pub. L. 104-13) Public reporting burden for this collection of information is estimated to average 0.25 

hour per response, including the time for reviewing instructions, gathering and maintaining the data needed, and reviewing the collection of information. 

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB 

control number. Please see the accompanying privacy notice / Privacy Act statement for a discussion of (1) the authority for solicitation of information, 

and whether disclosure is mandatory or voluntary, (2) the principal purposes for which the information is intended to be used, (3) other routine uses 

which may be made of the information, and (4) the effects, if any, of not providing all or any part of the requested information.

Page 5 of 5

United States Citizenship information 

If you are a U.S. citizen but were not born in the U.S., provide information about at least one of the 

following proofs of citizenship. 

8a) Naturalization Certificate 

8b) Citizenship Certificate Where was the certificate issued? 

City State Certificate Number Month/Day/Year Issued

 

8c) State Department Form 240 – Report of Birth Abroad of a Citizen of the United States

Date form was prepared 

(Month/Day/Year) 

Explanation (if needed) 

 

 8d) U.S. Passport This may be either a current or previous U.S. Passport

Passport Number Month/Day/Year Issued 

 

9e) DUAL CITIZENSHIP (if applicable) 

Name the country where you are a citizen in addition to the U.S. 

Court City State Certificate Number Month/Day/ 

Year Issued 

 

PSI-043
PSI-044
PSI-045
PSI-046
PSI-047
PSI-048
PSI-049
Office of Refugee Resettlement 

National Call Center 

HELP LINE 1 (800) 203-7001 | information@ORRNCC.com 

NINOS 

Text the word NINOS to 66467 

FOR CHILDREN 

If you are in immediate danger, call 9-1-1 

If you experience any of the following, we are here to help: 

• Nowhere to sleep 

• Someone is forcing you to do something that makes you 

feel uncomfortable 

• Someone is keeping you away from food, shelter, 

school, or medicine 

• Trouble feeling safe and happy 

• You are angry or hurting 

For Parents and Sponsors

 Looking for a child coming to the United States? 

• We will ensure your message gets to the shelter caring 

for your child 

Open 24 hours a day, 7 days a week. Call or

NINOS

text the word NINOS to 66467 any time. 

1 (800) 203-7001
 

• Feeling very sad or unwanted 

• Family problems 

• Kids being mean to you at school 

• Difficulty finding help 

• Difficulty with court 

• Trouble finding your paperwork 

Is your child already home? We can help with: 

• Finding resources in your community for education, 

medical care, emotional support, juvenile justice, 

substance use, legal support and safety 

• Assistance with child behavioral issues after 

reunification, including:

◦ Kids running away

◦ Kids feeling very sad or angry

◦ Involvement with drugs or gangs

◦ Inappropriate relationships

◦ Kids hurting other kids

◦ Kids getting into trouble at school

◦ Any behavior that worries you 

• Support for you to help strengthen your relationship 

with your child 

• Assistance making sure your child has access to schools 

and education 

• Support with family problems or domestic violence 

• Help getting copies of child/immunization records and 

completing paperwork 

• Assistance finding legal support and understanding 

court processes 

Text NINOS to 66467

PSI-050 
 
PSI-051
PSI-052
PSI-053
PSI-054
1

From: (HSGAC)

Sent: Tuesday, February 06, 2018 10:33 AM

To: (HHS/ASL)'; (HHS/ASL)

Cc: (HSGAC); (HSGAC); (HSGAC); 

 (HSGAC)

Subject: RE: PSI Briefing

Hi ,  

We will have follow‐up related to the responses below, but in the meantime I wanted to pass along a related briefing

request:

We would also like to request a separate briefing focused on HHS ORR’s gang initiative discussed during the January

17th briefing. In general, we are interested in the origins of this initiative and any specific safety or security‐related

incidents among UACs that may have led to the program being prioritized by HHS ORR. We are also interested in

learning more about the secure and staff secure facilities that HHS ORR maintains. Please be prepared to discuss the

locations of these facilities, the number of UACs housed in each with demographic breakdowns by gender and country

of origin, and the number of supervisory officers assigned to work in each facility.  

Please let us know if you need a more formal request or if you have any questions.

Best,

From: (HHS/ASL) ] 

Sent: Sunday, February 04, 2018 11:53 AM 

To: (HSGAC); (HHS/ASL) 

Cc: (HSGAC); (HSGAC); (HSGAC); (HSGAC) 

Subject: RE: PSI Briefing 

,

Here are the answers to your follow‐up questions. Please note that since the ORR team started pulling this information

after the briefing, we missed a question in your Jan. 26 email. We’ll still need to get you the data on number of staff

secure facilities (we’ve already asked). I’ll give you a buzz tomorrow or Tuesday to discuss next steps considering there

are several of your folks working with ORR currently.  

1. When did ORR make a request of OGC to review the statutory authority to determine if ORR could follow‐up on

UACs post‐release and take them back into custody?

ORR Response: In April 2017, a request was sent to general counsel concerning the issue. Conversations about

the operational and legal implications and considerations have been ongoing. Most recently, in January 2018,

additional questions were sent to general counsel.

2. What does HHS do with information received when they are contacted by state child welfare agencies with 

concerns about a UAC’s safety and welfare? How is that information used by HHS for future child protection? 

PSI-055
2

ORR Response: When a sponsor does not fulfill his/her sponsorship obligation (an agreement is signed at the

time of release) for any reason they are flagged in the ORR portal. This alerts ORR if they try to sponsor another

child. Child abuse would fall into this category of not upholding the sponsorship agreement because of failure to

protect the child. Other reasons, for example, might include not enrolling the child in school or not participating

in post release services.

3. Have there been any changes to policies regarding the provision of post-release services since summer 2017? 

ORR Response: ORR Post Release service policy is published on the ORR website,

https://www.acf.hhs.gov/orr/resource/children‐entering‐the‐united‐states‐unaccompanied‐section‐6#6.2.

Updates are noted at the bottom of the policy with the date the policy was updated.

4. In FY17, out of 41,000 total UAC releases, HHS was allotted funding for the provision of PRS to 11,000 children. 

How many UAC were actually provided PRS in FY17? 

ORR Response: In FY16, ORR conducted 3,540 home studies and provided 10,546 UACs with post release

services. In FY17, ORR conducted approximately 2,900 home studies and provided 11,500 UACs with post

release services.  

5. The list of contractors and grantees providing post-release services. 

ORR Response:

 BCFS Health and Human Services

 The Children's Village, Inc.

 Florence Crittenton Services of Orange County, Inc.

 Heartland Human Care Services

 Lutheran Immigration and Refugee Services, Inc.

 MercyFirst

 Morrison Child and Family Services

 Southwest Key Programs, Inc.

 United States Conference of Catholic Bishops

 United States Committee for Refugees and Immigrants

6. ORR policy on placements in secure and staff secure facilities. 

ORR Response: We have attached the full Policy and Procedures relating to placement in ORR facilities, and our

corresponding forms. Below are descriptions of the attached documents.

 Template UAC Initial Placement Form‐ This is our referral form. It is duplicated in the Portal for referrals

received directly there. We require receipt of this form for all referrals made.  

 UAC Placement Tool‐ Intakes completes the first part of this tool (which is housed in the Portal) as an aid in

determining placement level of care when processing referrals for minors with criminal history, gang

involvement, or other factors (as outlined in the Policy Guide) that may require a more restrictive

placement. The referral information and score from this tool are shared with an FFS Supervisor who

approves type of placement for the UAC. (This procedure is outlined in the UAC MAP Section 1.3.2)

 UAC Policy Guide Section 1‐ This is where all the policies relating to placement in ORR facilities are housed.

The policies that relate most directly to Intakes are in Section 1.2‐1.3. These are also found online here:

https://www.acf.hhs.gov/orr/resource/children‐entering‐the‐united‐states‐unaccompanied‐section‐1#1.1

7. Details on the JCO process including the dates the JCO was shared with DHS and returned to HHS, the expected 

timeline based on a joint commitment with DHS, and more information on what is holding up progress on the 

JCO. 

PSI-056
3

ORR Response: ORR submitted the last draft to DHS on October 6. DHS submitted their revised comments to the

ORR draft on January 24, 2018.

8. How often do sponsors decline post‐release services or not follow through?  

ORR Response: About 13% of sponsors decline or do not follow through with post release services.

Thanks!

From: (HSGAC) [ ] 

Sent: Friday, January 26, 2018 3:05 PM 

To: (HHS/ASL); (HHS/ASL) 

Cc: (HSGAC); (HSGAC); (HSGAC); (HSGAC) 

Subject: RE: PSI Briefing 

,

Thanks again for your help arranging last week’s briefing for PSI and HSGAC staff. Below are the list of follow‐up items

from that discussion. I’d like to flag items #1 and 10 as priorities for the Subcommittee.

As always, please let me know if you have any questions.

Best,

Follow-up items from HHS ORR’s 1/17/18 briefing: 

1. Timing of the request to OGC regarding legal responsibilities for UAC after placement with sponsors in the 

United States and the form of that request. 

2. What does HHS do with information received when they are contacted by state child welfare agencies with 

concerns about a UAC’s safety and welfare? How is that information used by HHS for future child protection? 

3. A copy or link to the program rules and guidelines for provision of PRS. 

4. Have there been any changes to policies regarding the provision of post-release services since summer 2017? 

5. In FY17, out of 41,000 total UAC releases, HHS was allotted funding for the provision of PRS to 11,000 children. 

How many UAC were actually provided PRS in FY17? 

6. The list of contractors and grantees providing post-release services. 

7. ORR policy on placements in secure and staff secure facilities. 

8. Further information on the type of information HHS would like access to from DHS. 

9. Details on the JCO process including the dates the JCO was shared with DHS and returned to HHS, the expected 

timeline based on a joint commitment with DHS, and more information on what is holding up progress on the 

JCO. 

PSI-057
 	


	







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PSI-063
	
 
  
 

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PSI-064
	
 
  
 



 

PSI-065
	
 
  
 

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PSI-066
	
 
  
 



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PSI-072
	
 
  
 

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##&(.,&#*--($$:&"#& #9.$.##&&.0-3 )&.0-("*(*$$.,"-!$#(0*$*$ *"*, "#$(9.$%( *"(*$"$<1/#*0:*$ 1*/$#&%-(*0,9(" "#&*$-#( ."-#&*##&$$(9.$:/0-11"%..*0#&0! 2!#&&.0-$/!!(#-*"-$*%*%#((/".%.*#."3)!(*#.":.#&!$#(0*$$(9.$:.00 "#"0&0!#&&.0-<1/#*"19(&0!%/0##&:&0%* .03 PSI-073
	
 
  
 

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PSI-074
	
 
  
 



PSI-075
	
 
  
 

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PSI-076
	
 
  
 

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`Y1B!&+FB+D&'(+ !.-BF#%+$#+,(#'!.$.(!-.!D$. "+.!.#-%+$"%+(!'+'$#.D%#(!&((B. '$#U[%B!!#+.-.!B,($/.!&"#' (B#+$$(!'+'/!.&+(!'(!$#%.&'+(+ +'#(F!" !.(B%B$U[%B!!#+.-.!B,($/.!&$#%.&'+(' + +'#(F!"!.(B%B$,+#$!'.+%) %!!.)'+(!'+!. '). !') '$.)#H"+!.'(+(!')$#+,(F)%(a'#B-)!.&& .+(!' #(+("#U b'&!#(#(+(#)%B$.'%+','.!$'#%B!!-+#((B+ !/`cUd!"%+'%B%*(!#(B !$#(+ F!"%+''.!+%B$'-",%#%B!!+((B#1,#(I B((-Iee111U%B$(.'$#U!. ef'$%+(!.#gB Bh#%B!!h$.!-!"(h.+(#

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PSI-077
	
 
  
 

 

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%%*BCC!# ""&*#%1' &C# %(!D !(%' /C?@AD2".'D,/DG%#%!1%0

IJKLMNO PQRSTUQVWXYRZ[\R\]^_^]^\UQ^^WTSX\`Va\UWT\\b]QV\V\UTWWRXc]Y[TSUdefgRUT[\RRX[UT]V^S )#!&# !h+ !0!"%-,'%)*'")' )#"( !"SRRX]^U^iaWdjV]Q]QRUQVWXk\\UQ^^W

#%%!"#"(!12.%!(0))!)%''0#"/#/)#%)(''-%!(0#/#$!%'&'%'% +#"(/ ('+ %-' %!)*'")' 0#/#$!%'*#/."!)1

PSI-078
	
 
  
 

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 )(&'()4$$1($+"$&!$ (,*& %!&'".$($#"&!)(")#) !.$($#/J1)&")#" #$&$3$#1$#+(($!())#$ !().)#4)#($"$-"&$$!"/ J1)&")#"#$#$w%#$!()$&"%#$($ !#$&&($##$#$$3$+$! #$/v"#&'$"#)+ -"$4_%1"&!#$'% #3&()&"()+$!  (($&()&)#&&x%#,)# &$"""&$$!$!/v" ")11 $" ()1",(#+$!()&"/ !"1#$"#-$!&$$""#, +$!()&"()4$$1+"$*"1)&")#"#$#$w%#$!() +4$"%#$($ !'$("($+$!&$$y"$&$$!"/z$!  #$&'$(${1$&"3$*&!($#$#$)($&"%11)#("& +&, )()&"((&$ 1.(+$! )"("/v)!$&(, )._)"(+$! "$#3$"&,)%##$* ($6778()&  5 5$&($#(|_}~~_~_~~|/ utqtutiklmljn J1)&")#"+%"( ")4$$1 !#$&"$-,+4&'"%#$($,3$!$w%($!% ("%1$#3")&/ J(($"3$!$#$&(#% $"-)%(("*-%()3$# * !#$&+,&)(-$ $(()+$%&(($&!$!*

  

 ¡    ¡ ¢

PSI-079
	
 
  
 

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9'"% 1$'3(('$0 ('$-$"(&! $4,(),$'$"$&(!(,$"$/'$""-$* +%"$&(!' ,/."(- "#$'$1'"$"1!(&$*9!(&$,(!!&-$"/ '-$" ("$'3($,/ )$"(%'-"(""'/"%("$&(!"-4$ '$$:$(%$*;

1'.%(! '$"'$1'"' ,/((-$""$&'(-(!&"*5'$!1'$1'"()"" &(!!$%"/ '&'$.'(%/ '$%'("""$&(!-()"' ,/./ &&!!"$<== >"(!?!!?$"$'%' 11'""@ABCCADCEAFCC@* 7$>"(!?$"$'%'G(()H61!("$?(!'$I>?GH?J()'$"'$ '&$%' '$1'"()/ '&(!-(().>?GH?,(!!4$$1"((%'-"((&$"'!(K$"#$" &-- (&"$,("!,$%'&$-$""(!!/*7'$1'"/ '&(!-(()">?GH?.&!!@A BCCABLEAMNFB* 

OPQRSSTUVTSPTWXYZ[YY\][PWQ ^_`ab`cbdcedfb`ceghicejk`_c`kelkdlmifjnbeo`ki`adfpeffA#$()*+"$q("$2""$. !" -/""'$"$&(!,("'-*21'!-/"( !"'$-"(!!/'$r$&"&(!'$*

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PSI-080
	
 
  
 

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PSI-081
	
 
  
 

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PSI-082
	
 
  
 



PSI-083
	
 
  
 



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PSI-084
	
 
  
 

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PSI-085
	
 
  
 

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PSI-086
	
 
  
 

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PSI-087
	
 
  
 

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}qys~~xq}s}vqw|sstuovqw  PSI-088
	
 
  
 

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PSI-090
	
 
  
 

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PSI-091
	
 
  
 

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PSI-092
	
 
  
 

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PSI-093
	
 
  
 

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f i"!"2)+2")'')#*"&%"''2"&%#%k%*%&)%'%'%")9"%#$'(%&%$"2)"9"%. PSI-094
	
 
  
 

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PSI-095
	
 
  
 

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PSI-096
	
 
  
 

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  PSI-098
	
 
  
 

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PSI-109
1

 (HSGAC)

From:

Sent: Friday, August 03, 2018 2:56 PM

To: (HSGAC); 

Cc:

Subject: Follow Up- UAC and Trafficking

,

It was great to meet you on Wednesday. We are very appreciative for Senator Portman's leadership on this important

issue.

we wanted to share the trafficking case example below.

Case Example – Trafficking by Sponsor in FL

The limited use of home studies and post‐release services has resulted in children being released to situations of abuse,

abandonment, neglect, and trafficking. These are youth like Juan,* who was released from ORR care without services to

his half‐uncle in Florida. Shortly after his reunification, Juan’s uncle withdrew him from school and sent him to work in

the fields with his two cousins (who had not been in the care of ORR). This forced labor continued until Juan’s cousin

was injured and brought, with Juan, to the Emergency Room, where the injury raised abuse and trafficking concerns. CPS

investigated the situation and removed the children from the home, placing the children in state custody. (*Child’s name

changed to protect identity.)

Have a nice weekend.

Sincerely,

The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.

PSI-110
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Agenda

USCIS Asylum Division Quarterly Stakeholder Meeting

Friday, Aug. 11, 2017

Tomich Center

111 Massachusetts Ave. NW

Washington, D.C. 20001 

2 – 4 p.m. (Eastern)

I. Welcome and Introductions 

 

II. Asylum Division Updates

a. The current RAIO-CT and ADOTP classes have enrolled 84 and 47 students, respectively. 

b. Regularly Provided Statistics (posted on USCIS.Gov)

Affirmative Asylum Statistics (April 2017 – June 2017)

NACARA Statistics (June 1999 – June 2017)

Credible and Reasonable Fear Statistics and Nationality Reports (April 2017 – June 2017)

Unaccompanied Alien Children Statistics (April 2017 – June 2017) 

We publish the regularly provided statistics on the uscis.gov website before the quarterly engagement so 

you can review them before the meeting and print a copy if you so choose. 

III. Asylum Office Jurisdiction Over Affirmative Asylum Applicants with Expedited 

Removal Orders and/or Notice To Appears (NTAs) 

a. We have a handful of clients who have been released from detention and issued NTAs, but 

those NTAs have not been filed with the immigration court. Immigration courts will not 

accept an asylum filing if an NTA has not yet been filed with the court. USCIS also rejects 

asylum filings for these applicants citing lack of jurisdiction, even though the 2013 

Affirmative Asylum Manual states that the asylum office maintains jurisdiction unless an 

NTA has been served on an applicant and filed with the Executive Office for Immigration 

Review (EOIR). How can the issue be addressed to allow applicants caught in this “catch 

22” to file before the one-year deadline? Does the asylum office consider itself to have 

jurisdiction when ICE has produced an NTA and served it upon an applicant, but ICE has 

not filed the NTA with EOIR? If the asylum office does not accept jurisdiction because it 

wants to give ICE an opportunity to file the NTA, would it make a difference if substantial 

time has passed without ICE taking any action? 

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Response: Due to ongoing litigation in Mendez-Rojas v. Duke, we are unable to respond to

these questions at this time. Please note, if you have specific cases with related concerns

and if ICE or CBP issued the NTA, we recommend you contact ICE to request that ICE file 

the NTA with the immigration court. If an Asylum Office issued the NTA after conducting a 

credible fear screening, please contact the Asylum Office to request that it file the NTA 

with the immigration court.

b. Some practitioners have seen that their local asylum offices are declining jurisdiction over 

affirmative asylum applications due to the existence of an expedited removal order even if: 

- That order was later rescinded/vacated/never effectuated due to the superseding 

issuance of a Notice to Appear, and 

- No charging document was filed with an immigration court. When the asylum office 

learns of the expedited removal order, they are administratively closing the case sua 

sponte for lack of jurisdiction. 

In many cases practitioners and applicants are not provided notice of the administrative 

closure, and closure appears to stop the EAD clock and erase the time elapsed on the 

clock. 

Please confirm the Asylum Division’s interpretation of regulations and the INA regarding 

jurisdiction.

Response: See the response to question III.a. above.

IV. Policy Memorandum PM-602-0137

a. USCIS issued a Policy Memorandum PM-602-0137, dated Oct. 5, 2016, “Revised Guidance 

for Processing Asylum Cases Involving Terrorism-Related Inadmissibility Grounds and 

Amendment to the Hold Policy for Such Cases.” Based on this memo, cases that were 

previously on hold at HQ due to possible TRIG will be “referred” to EOIR. 

Can you please provide an update on how many cases remain at HQ that were previously 

on hold due to TRIG? 

Response: We have approximately 10-15 TRIG cases that were removed from TRIG hold 

following the October 2016 policy memorandum still pending with HQ. 

What is the process to remove these cases from hold for referral to EOIR and how long is 

this process expected to take? 

Response: We cannot provide a timeline for when the processing of these cases will be 

completed. We are making every effort to review cases and return them to the field in a 

timely manner. 

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How will cases in which a TRIG exemption is authorized be processed under the new 

policy? 

Response: Cases involving a TRIG exemption continue to receive two levels of review 

prior to decision service. 

b. What is the date of the next of the next TRIG Quarterly Stakeholder Meeting? 

Response: The next meeting has not been scheduled at this time. Please address inquiries 

on the scheduling of the next engagement to Karen Sohrakoff, chief of the RAIO TRIG Unit.

V. Conflicts While Awaiting Adjustment

a. Normally, a person who entered as a nonimmigrant, but has become in violation of his 

status, will be allowed to adjust status through the petition of a U.S. citizen immediate 

relative. If such a person has an I-130 and I-485 pending, and is awaiting his adjustment 

interview, upon the non-grant of an affirmative asylum application, would the asylum office 

refer the case to the EOIR, or allow the person to continue to await his adjustment 

interview? What would be the result of a non-grant of a person awaiting a TPS application 

adjudication, referral to the EOIR or allow the person to await adjudication of the TPS 

application? 

Response: Asylum offices are required by regulation to issue Notices to Appear to 

affirmative asylum applicants who are not in valid immigration status and are not found 

eligible for asylum, but asylum offices may be willing to coordinate on a case-by-case basis

with other USCIS components to delay issuance of an NTA if the adjudication of a 

concurrently pending application and/or petition is imminent.

VI. Changes of Address

a. If an asylum applicant lives in the jurisdiction of an asylum office, for example New Jersey, 

and moves to the jurisdiction of another office, for example New York, does the applicant 

need to do anything other than file an AR-11 to ensure that the case is transferred to the 

correct office? For example, should she write a letter to one or both offices? 

Concerning the above example, does the transferred case join the asylum office queue 

based on the date of application? For example, in the example above, if the applicant filed in 

January 2015 and moved from the NJ jurisdiction to the NY jurisdiction, she should now be 

“current” for a NY interview. Should she expect to be interviewed immediately or are case 

transfers added to the queue in some other way?

Response: Asylum offices are notified of a change of address automatically, if the customer 

follows the directions in the uscis.gov website under File a Change of Address Online, 

including answering “yes” to the question: “Is this change of address for an application or 

petition currently in progress?” These steps must be taken to notify the asylum office where 

the application is pending of the change of address. 

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The Change of Address Online system captures the data provided by a customer or the 

representative in one central location to fulfill two processes: 1) notifying USCIS that a 

customer has changed his/her address and 2) in the case of a customer with a pending 

benefit request, informing the specific USCIS office of the change of address to ensure that 

asylum offices send mail to the proper address. 

The applicant may also submit a change of address through the mail by sending one copy to 

the address on the website and one copy to the asylum office where the application is 

currently pending. Both steps must be taken if completing the change of address by mail.

Yes, the transferred case joins the asylum office queue at the new office based on the filing 

date. 

b. Asylum adjudication jurisdiction—if an applicant changed address while asylum is pending, 

does the case follow to respective jurisdiction or stay with the initial jurisdiction? 

Response: Generally, if the applicant has not been interviewed before the move, the 

applicant will be interviewed in the new asylum office jurisdiction. If the applicant was 

interviewed before moving to a new asylum office jurisdiction, generally the case will be 

adjudicated by the asylum officer in the old jurisdiction unless an additional interview is 

required. 

VII. Biometrics Notices 

a. During the call in January (I believe) there was mention that the biometric notices were 

going to be for date/time specific appointments. Notices arriving still have the two week 

window. Is this going to change?

Response: Yes. As of Aug. 3, the Asylum Division began to issue biometric notices for 

date/time specific appointments for all cases. However, applicants may continue to receive 

biometrics notices with two-week windows that were scheduled before the change for a 

short time during the transition. 

b. What should practitioners do when the USCIS notification for asylum interview arrives 

before biometrics notification? Who should we contact to initiate fingerprints? Should we 

alert USCIS?

Response: In the fall of 2016, the Asylum Division began to “refresh or re-submit” existing 

asylum-related fingerprints for applicants such that the applicant no longer had to attend an 

appointment for biometrics collection. This provides better customer service to the 

applicants and also allows the Application Support Centers (ASC) to better handle 

increasing new asylum application receipts. If the applicant or dependent was previously 

fingerprinted for the asylum application and receives the interview notice without receiving 

a biometrics appointment, the applicant is not required to go to the ASC again for 

biometrics collection prior to the interview.

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If the applicant or dependent has never been fingerprinted for the asylum application and 

received the interview notice before the biometrics appointment notice, please contact the 

asylum office where the application is pending so that they can schedule a biometrics 

appointment before the asylum interview. 

c. After an asylum application is filed, we are receiving a biometrics notice with a range of 

dates, usually a week during which the applicants need to go to the local ASC office to have 

their fingerprints done. However, the local ASC office is refusing to fingerprint applicants 

with this type of notice and is asking them to provide a notice with a specific date and time. 

What should be done in this case?

Response: Applicants should now receive a biometrics notice with a specific date and time. 

Please continue to attend biometrics appointments and take your appointment notice. If you 

need to re-schedule your appointment, follow the instructions on the notice or contact the 

local asylum office for assistance.

VIII. Affirmative Asylum Scheduling Bulletin and Interview Priorities

a. Asylum offices have stated at some local liaison meetings that the Affirmative Scheduling 

Bulletin is not accurate (delays are longer than what the website indicates). Will the bulletin 

be generally updated for accuracy?

Response: Creating the scheduling bulletin is not a science. It’s an estimation based on the 

number of cases scheduled for interview the previous month and the number of cases that 

were not scheduled for interview (from a particular filing month). The Asylum Division will 

look into ways to make the bulletin less manual and more accurate and informative, to 

include additional priorities and interview locations. 

b. Will the asylum offices continue to prioritize scheduling of children’s cases? If so, would 

they consider issuing a separate scheduling bulletin for children’s cases so representatives 

can better plan for when those cases will be scheduled?

Response: The scheduling priorities currently remain the same. See the response to VIII.a 

above.

c. I recall there was a recent announcement that the scheduling bulletin would include circuit 

rides. When is this likely to be implemented?

Response: See the response to VIII.a above.

d. Are the asylum offices still scheduling interviews on a first-in-first-out basis? Have there 

been any changes in the prioritization or scheduling process for asylum interviews or are 

any such changes anticipated in the future?

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Response: Generally, the asylum offices continue to follow the scheduling priorities as 

described on uscis.gov in the Affirmative Asylum Scheduling Bulletin. The Asylum Division 

continuously examines scheduling priorities based on receipts, pending caseloads, resources 

and priorities. 

c. How many cases, as a percentage, typically have an applicant called back in for a followup/second interview? Anecdotal reports suggest an uptick in this occurring. 

Response: We do not track this information in our case management system.

e. Can you please tell me how to request an expedited hearing?

Response: Asylum office directors may consider applicants’ requests for urgent interview 

scheduling outside of the prioritization categories on a case-by-case basis. Please submit any 

urgent interview scheduling requests in writing to the asylum office with jurisdiction over 

your case. Go to the USCIS Service and Office locator page for contact information.

f. On average, how many months does the asylum process take?

Response: The length of time for completing an affirmative asylum application depends on 

various factors, including but not limited to: 

• The date the application was filed; 

• The caseload of the asylum office with jurisdiction over the application; and

• Whether the applicant is interviewed at a local asylum office or at a circuit ride 

interview location. 

Please see the Affirmative Asylum Scheduling Bulletin | USCIS Affirmative Asylum Scheduling 

Bulletin for more information about interview priorities on uscis.gov/asylum. 

IX. Including Updated Information in the Applicant’s File in Time for the Interview 

a. Many years go by before one obtains an interview with a two weeks’ notice given before 

the interview. What is the best method to submit updated information or additional 

evidence to the asylum office? Is it better to do so in person at the time of the interview or 

should we do so within the two weeks by sending it to the asylum office? My problem with 

the latter is often times the additional documents do not get placed in the correct file for 

the officer to find before the interview. 

Response: Check with the asylum office with jurisdiction over your case for local 

procedures for submitting supplemental documentation. Generally, you should submit the 

supplemental documents before or immediately after you receive the interview notice

(within two weeks before the interview date). If you cannot submit the supplemental 

documents before two weeks, bring extra copies for the interviewing officer. You may drop 

them off earlier in the week with the interviewing officers at your circuit ride location.

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X. Post-Interview Delays 

a. We have experienced high number for asylum seekers approaching our agency asking for 

assistance. Could you please explain the delays in processing asylum applications, more 

specifically for clients from Syria? Some of these clients have been interviewed by an asylum 

officer more than once, and yet their cases are still pending for over two years. Is there a 

way for an applicant’s attorney to advocate for an expedited decision following an asylum 

interview, for example, in the case where a client’s family is in danger as they wait for the 

decision? How might an applicant find out how long a decision might take if they have been 

waiting for a year or longer for an interview decision?

Response: We are not aware of delays specific to Syrian asylum cases. Asylum office 

directors have the discretion to consider applicants’ requests for urgent post-interview 

processing on a case-by-case basis. Please submit your request to the asylum office with 

jurisdiction over your case.

b. Does USCIS have any estimates of how much longer the additional screening of applicants 

will add to current waiting times? Is there anything in particular that stakeholders who work 

with the affected populations can do to help USCIS with the new and expanded processes?

Response: See the Executive Orders on Protecting the Homeland page on DHS’s website 

for information outlining the impact of the executive orders. 

c. Is there any policy change regarding asylum issues?

Response: There are no changes regarding affirmative asylum issues. 

XI. I-94s for Defensive Asylees

a. There is a problem around I-94s which has taken up so much time—yours, mine, and the 

new asylees! The problem is that sometimes new asylees are not handed an I-94 when they 

are released from detention, following a grant of asylum. Some are able to obtain one when 

they reach their destination and contact the local USCIS office. How do I resolve this 

problem? 

Response: The procedures for requesting and receiving an I-94 card after a grant of asylum 

by an immigration judge are available online at Immigration Benefits in EOIR Removal 

Proceedings. At the final hearing, you will receive orally and in writing the “Post-Order 

Instructions,” which explain you must make the request to the local USCIS Field Office. The 

Asylum Offices do not provide I-94 cards to individuals granted asylum by an immigration 

judge. 

XII. Unaccompanied Children

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a. Is there any new or anticipated guidance on circumstances under which unaccompanied 

children will be re-designated as accompanied? Likewise, is there guidance or procedures 

for when those designated as unaccompanied children turn 18?

Response: Under Executive Order 13767 and the DHS implementation memo for 

Executive Order 13767, DHS is currently developing uniform guidance and procedures on

applications for asylum filed by UACs for adjudication by USCIS under the “initial 

jurisdiction” provision of the TVPRA. However, the May 2013 USCIS memo, Updated 

Procedures for Determination of Initial Jurisdiction over Asylum Applications Filed by 

Unaccompanied Alien Children, is still in effect. The memo has not been rescinded nor

replaced with new procedures for determining initial jurisdiction. 

b. Are the asylum offices still following the 2013 memo that says they will not do an 

independent analysis of UAC status for individuals who were designated UACs and never 

affirmatively "re-designated"? In other words, will the AO still treat an I-589 as filed by a 

UAC even if the applicant is now over 18 or appears to have reunified with a parent, so 

long as there was no re-designation? 

Response: The May 2013 USCIS memo, Updated Procedures for Determination of Initial 

Jurisdiction over Asylum Applications Filed by Unaccompanied Alien Children, is currently still in 

effect. At this time, the memo has not been rescinded or replaced with new procedures for 

determining initial jurisdiction. Under Executive Order 13767 and the DHS implementation 

memo for Executive Order 13767, however, DHS is currently developing new uniform 

guidance and procedures on applications for USCIS adjudication of asylum applications filed 

by UACs under the “initial jurisdiction” provision of the TVPRA.

c. Does the Asylum Office have jurisdiction over cases filed by a UAC who was in court even 

if the UAC took prosecutorial discretion and the case was admin closed or terminated? If 

they were designated as UACs and never re-designated, would the Asylum Office have 

jurisdiction even if several years have passed and the individual is no longer a minor?

Response: Under current procedures, if a UAC’s removal proceedings were 

administratively closed, the NTA is still active in the case. Therefore, the Asylum Office may 

have jurisdiction over an asylum application pursuant to the “initial jurisdiction” provision of 

the TVPRA. If a UAC’s removal proceedings were terminated, the Asylum Office would 

have jurisdiction over an asylum application as an affirmative asylum application since the 

applicant is no longer in removal proceedings, regardless of whether the application was 

filed by a UAC. 

Under the 2013 memo currently still in effect, if CBP or ICE determined that an applicant 

was a UAC, and, as of the date of initial filing of the asylum application, that UAC status 

determination was still in place, USCIS will take initial jurisdiction over the case. 

Under Executive Order 13767 and the DHS implementation memo for Executive Order 

13767, however, DHS is currently developing new uniform guidance and procedures on 

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USCIS adjudication of applications for asylum filed by UACs under the “initial jurisdiction” 

provision of the TVPRA.

d. Sponsors and other adult caregivers are expressing increasing fear of attending child asylum 

interviews as witnesses or “trusted adults” because of increased immigration enforcement 

efforts. Does the Asylum Division have a policy regarding the sharing of witness and other 

adults’ information with Immigration and Customs Enforcement? Will asylum officers be 

encouraged to give more weight to written declarations given these concerns? 

Response: Asylum officers continue to be instructed to elicit testimony on all relevant 

eligibility requirements. Asylum interview notes are part of the record in the A-File. If the 

application is not approved, the asylum office transfers the file to ICE OPLA for removal 

proceedings. If the asylum application is approved, USCIS informs ICE so that appropriate 

arrangements may be made to terminate proceedings. Asylum officers will consider written 

declarations. 

f. We have learned of a situation in which the SF Asylum Office denied a UAC’s asylum claim 

based on evidence from ICE’s EARM (Enforcement Alien Removal Module) system. Counsel 

for the UAC was not provided with the evidence or given an opportunity to address it at 

any time during the application process. Has USCIS implemented a new policy permitting

asylum officers to issue denials without giving an applicant the opportunity to respond to 

the evidence used to deny the case? Please provide a copy of any written agency guidance 

regarding this practice.

Response: No, there is no new or revised policy. Please direct case specific inquiries and 

concerns to the interviewing office. 

XIII. Gang-Related Questions

a. Are there new policies or practices on sending gang-related cases to Headquarters for 

review? If so, does this apply to victims of gang activity? Does the policy/practice apply to 

minors as well as adults? Advocates have also heard that any unaccompanied minors that 

are or were previously in a “staff-secure” or “secure” Office of Refugee Resettlement 

facility will have their cases sent to Headquarters for review. Is there a new policy in place 

on this?

Response: The Asylum Division has always maintained and exercised the ability to request 

certain cases be submitted to Headquarters for review before decision issuance, even if for 

only a short period of time, in order to get a better understanding of the types of cases 

being seen in the field. Recently, there has been significant reporting on gang activity in the 

United States associated with Central American gangs. As such, we believe it is prudent at 

this time to ensure that we understand what cases may be coming through the affirmative 

asylum process in which there are indications that the applicant has a history of violent 

criminal activity or gang affiliation or involvement. Therefore, we have asked offices to 

submit proposed grants to Headquarters for review if the adjudicator detects indicators of 

past or current gang affiliation regardless of whether the applicant is a juvenile or an adult. 

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Under ORR rules for placement, this type of history may be a factor considered when 

determining placement in these facilities. Therefore, as part of this request, we have 

requested to review proposed grants where the applicant was previously or is currently 

being held in a “staff-secure” or “secure” ORR facility. We may conduct a similar review of 

proposed referrals/denials in the future. We have not asked to see cases based on whether 

an applicant is a victim of gang activity. 

b. Advocates have observed an increase in the number and detail of questions on whether 

unaccompanied minors had ever associated with gangs, or been victim of a gang. We have 

also noted an increase in questions relating to the child’s journey to the United States and 

specifically who bore any costs associated with the journey. Can you comment on the 

purpose or intention of such questions? 

Response: We are not aware of an increase in the number or type of questions being 

asked about gang association, being a victim of gang violence, the applicant’s journey to the 

U.S., or those who bore the costs for this journey. Adjudicators are trained to develop the 

record as necessary to make a legally sufficient determination, which could include asking 

about any of the issues raised in this question, depending on the facts of the case.

c. Which unaccompanied child asylum case decisions are currently being sent to Headquarters 

for review before the decisions can be issued? How long is it taking for Headquarters to 

complete these reviews? What percentage of UAC cases requires Headquarters review 

now? 

Response: We do not ask that UAC cases come to Headquarters categorically. They may 

be submitted for review if they are subject to the review discussed above, involving 

potential gang affiliation, or for other reasons, such as if they are novel, high profile, likely to 

be publicized, or involve national security issues. We do not have data on how long these 

cases take to review or what percentage of UAC cases receive Headquarters review. 

d. AILA has received reports that asylum officers have implemented new procedures related 

to the adjudication of cases that may have possible MS-13 connections or possible gangrelated issues. Has Headquarters provided any new guidance to the field concerning the 

adjudication of asylum cases with possible MS-13 connections or gang-related issues? If yes, 

please specify what these changes are. Are there written policies on these changes? Will 

USCIS provide stakeholders with a copy of these written policy changes? 

Response: Other than the steps mentioned above to require that certain proposed grants 

come to Headquarters for review, no additional guidance has gone to the field concerning 

the adjudication of asylum cases with possible MS-13 connections or gang-related issues. 

e. Please identify which categories of asylum cases are now being sent to Headquarters for 

review. Will USCIS provide stakeholders with a copy of this updated written policy 

guidance? 

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Response: Cases that currently come to Headquarters include those described above in 

XIII.a. and c., including cases that may be likely to be publicized or are otherwise high 

profile, as well as any that involve national security issues. 

XIV. Publication of Lesson Plans and Training Modules

a. Why does the Asylum Division publish just some, but not all, lesson plans and training 

modules? Why not publish all of them? 

b. Will the Asylum Officer Basic Training Course lesson plan materials be made available in 

the USCIS Electronic Reading Room or in any other public location? If not, please 

explain. 

c. When will USCIS guidance and officer training materials on children’s asylum claims, 

such as the RAIO training materials, be available on the website again?

Response: Most training materials used to train new officers at RAIO are no longer 

available on RAIO’s public website. The Asylum Division’s lesson plans that are used to train 

asylum officers have been removed completely from the website and we are working to 

remove the remaining lesson plans because they will be posted for the public to access 

elsewhere. 

In response to a series of recent Freedom of Information Act (FOIA) requests, all of our 

current lesson plans have been submitted to the USCIS FOIA office. The FOIA office will 

determine whether the materials are subject to any exceptions to disclosure. Any materials 

deemed sensitive or subject to a FOIA exception will be redacted by the FOIA office as 

appropriate. The FOIA office will post the remaining lesson plans, which we expect to be 

the majority of the lesson plans, in the USCIS Electronic Reading Room. Some of the 

materials have already been posted there, including training materials on adjudicating 

children’s asylum claims and gender-related claims. We are working with the USCIS FOIA 

office to determine when the remaining materials will be posted. 

XV. Staffing

a. How are the overall staffing levels for asylum officers? Are there many openings? Are there 

plans to increase the workforce at this time? 

Response: The Asylum Division is currently authorized 625 field asylum officers. As of July 

10, there are 516 field asylum officers onboard with an additional 102 individuals selected 

to fill some of the remaining vacancies. USCIS is currently engaged in its annual staffing 

needs assessment. No additional information is available at this time.

b. Please provide the current number of asylum officers currently on staff.

Response: See response to XVII.a above.

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c. Please provide the average number of asylum officers assigned to conduct affirmative asylum 

interviews from January to August 2017, broken down by month. 

Response: We do not capture the requested data. 

d. During the May 2, 2017 Asylum Stakeholder meeting, the Asylum office indicated that 

asylum officers had been assigned to conduct CFIs and RFIs at the following detention 

centers: Cibola, Eloy, Florence, Adelanto, Imperial, Otay Mesa, Pearsall, Polk, Dilley, and 

Karnes. Please provide an updated list of the detention centers where asylum officers have 

been assigned to conduct CFIs and RFIs. Please provide the current number of asylum 

officers assigned to each facility.

Response: The facilities have not changed. The number of asylum officers assigned to these 

locations fluctuates weekly and, at times, daily. During the week of July 24, a total of 46 

asylum officers were assigned to the above mentioned sites. 

XVI. CBP and Transgender Asylum Seekers

a. I’m concerned about reports I’ve heard from Human Rights First and the Transgender Law 

Center that asylum seekers, including a number of transgender women fleeing violence in 

Central America, are being told by CBP at the border that they can’t seek asylum and 

whether USCIS is working with CBP on addressing this issue. I would like to know if USCIS 

is working with CBP to address reports of CBP officers turning asylum seekers away at the 

border. 

Response: The issue of CBP actions at the border related to asylum seekers is subject to 

litigation. Due to the litigation, we are unable to respond to this question.

XVII. Initiation of Removal Proceedings

a. Has there been any change in the past eight months to the policy or procedure for initiating 

removal proceedings against asylum applicants who have applied for asylum affirmatively and 

whose affirmative asylum cases have yet to be adjudicated by the asylum office? 

Response: No, the Asylum Division has not made such changes in the past eight months. 

a. For FY 2016 and 2017, how many cases have removal proceedings been initiated against 

people who had affirmative applications for asylum pending without decision at the time the 

NTA was issued? Please provide a breakdown by (a) asylum office, and (b) nationality of 

applicant. In how many of these cases had the affirmative asylum applicant been (a) charged 

with a criminal offense; (b) convicted of a criminal offense? 

 

Response: USCIS Asylum does not track this information in our case management system.

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c. If a case looks improbable, inconsistent with country conditions, or just falsified, is the 

interview process speeded up, to throw the person in court? Cases in the asylum office 

now take 27 months to be heard.

Response: USCIS schedules the affirmative asylum interview and considers the evidence 

on a case-by-case basis. If the individual does not establish eligibility for asylum and is not in 

lawful immigration status, the asylum office places the individual in removal proceedings.

XVIII. Detention and Affirmative Asylum

a. I have heard of those asylum applicants who have been stopped at checkpoints where CBP

agents are present. The applicants have informed agents that they filed their asylum 

application before the expiration of their six months of their I-94 and are still being 

detained. 

The ICE agent or CBP agent are saying that an asylum applicant has no legal status even if 

they filed before the six months of the expiration of their I-94, which is troubling, because if 

they detain every person who is awaiting an asylum interview, it would be contradictory to 

the acknowledgement of receipt that they receive after they file their I-589, which states 

you're allowed to remain in the United States while your asylum application is pending. 

Therefore, perhaps further clarification is necessary to the CBP or to ICE agents so that a 

memo can be sent out that asylum applicants should not be detained, since they have an 

asylum application pending and it is not their fault that the USCIS has a backlog of asylum 

applications and they cannot have their interview conducted within six months so they 

should not have to bear the consequence of their asylum application not being processed 

for an interview and thus being detained saying that they’re under no lawful status and that 

asylum applicants have no lawful status. 

Even though they do not have a lawful status they are an asylum applicant and their I-797 

acknowledgement of receipt states that you are allowed to remain in the United States 

while you're asylum application is pending. Therefore, my question is whether there is any 

clarification to ICE agents or to CBP agents, so they are aware that those asylum applicants 

with pending asylum applications before the USCIS, should not be detained if their six 

months have expired and their I-589 is pending before USCIS.

Response: ICE and CBP have the legal authority to determine whether to take aliens into 

custody when they encounter them at the border or inside the United States, and to 

determine whether to place them into removal proceedings. If ICE or CBP places them into 

removal proceedings, USCIS loses jurisdiction over the application and they may apply for 

asylum or other protection as a defense to removal while in detention.

XIX. Credible Fear and Reasonable Fear Cases 

a. USCIS revised its Credible Fear of Persecution and Torture Determinations and Reasonable 

Fear of Persecution and Torture Determinations on Feb. 13, 2017. These new lesson plans 

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are effective as of Feb. 27, 2017. Has any additional guidance been issued to the field 

concerning CFIs and RFIs? 

 

Response: No. 

b. During the May 2, 2017, Asylum Stakeholder meeting, the Asylum Office stated that there is 

a random review process for CFI and RFI cases. Please identify any categories of CFI and 

RFI cases that are required to be reviewed by Headquarters. 

Response: Headquarters does not review any specific categories of CFI or RFI cases. 

Cases are selected at random for submission to Headquarters for review. 

XX. Attorney Interaction with the Asylum Officer at the Interview

a. Under the current training model, what exactly are new asylum officers trained to expect 

from their interactions with attorneys representing asylum applicants at the asylum 

interview? Interactions with asylum officers still vary substantially from officer to officer. 

Some welcome attorney participation to clear up obvious confusion so the interview is not 

needlessly sidetracked for 15-20 minutes because something is lost in translation. Others 

clearly do not want the attorney to open her mouth. What does the asylum division 

consider to be appropriate in terms of an attorney speaking during an asylum interview?

I know that the older Asylum Officer Basic Training Course stated: “In certain instances, it 

may be appropriate for the representative to comment during the course of the interview 

to avoid confusion or misunderstandings. Such comments may be helpful and should not be 

discouraged.” 

This issue was also raised in the May 2, 2017, Stakeholder Meeting. However, I recently 

experienced the variance in asylum officer attitudes toward attorney participation in the 

asylum interview in interviews on June 7 and June 14. I feel it is necessary to continue to 

raise this issue until the problem has been rectified. Is the Asylum Division taking steps to 

assure that all asylum officers are familiar with the desired role that attorneys should play in 

an asylum interview? This seems particularly important as there are over 270,000 (likely 

tens of thousands more by the time the stakeholder meeting takes place) pending 

applications in which interviews will be necessary. 

Response: All asylum officers receive training on non-adversarial interview techniques. The 

training materials emphasize the role of the asylum officer to manage the interview. 

“Because of the non-adversarial nature of the process, described below, the role of the 

representative during the interview is minimal. You [the asylum officer] control the 

interview and will ask most of the questions. You may allow the representative to comment 

or ask questions during the course of the interview to clarify specific points. After your last 

question, you should give the attorney an opportunity to offer a closing statement. You 

have the discretion to limit the length of the closing statement, or in rare circumstances, 

require that a statement be submitted in writing instead.” Interviewing – Intro to the NonAdversarial Interview.

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We have shared your concerns with the Arlington Asylum Office. The Arlington Asylum 

Office encourages attorneys to engage with local office management, by asking for a 

supervisor, after the completion of the interview if you have a particular concern regarding 

the officer’s conduct in an interview. Also, all asylum offices have regular local stakeholder 

engagements and we encourage you to submit your questions to be discussed at those 

engagements. Contact the local asylum office management for the details regarding these 

engagements. 

XXI. Information Provided at the Waiting Room Window

a. Some applicants report that when they inquire at the asylum office window, they are told 

their exact position on the short notice list (for example: “You are number 245.”). Others 

are told that no information can be shared on that topic. For applicants that eagerly await 

their interviews because they seek to be reunited with their loved ones after receiving 

asylum, it helps when they can receive at least some information about where they are in 

the process. However, for those that are turned away with no information, it causes them 

confusion and frustration. Many have heard from friends that they were provided 

information when they inquired at the office window, so the applicant will wonder why she 

was not treated the same way. I would encourage the open sharing of this kind of 

information... but at the very least, there should be a consistent policy of dealing with these 

inquiries. Does such a policy already exist?

Response: The Asylum Division has general national customer access standards which 

establishes multiple means for applicants to contact asylum offices while also protecting 

their confidentiality under 8 C.F.R. § 208.6. Asylum office management may also develop 

local procedures which meet the national standards. We have shared your concerns with 

Arlington Asylum management, and they will endeavor to provide standardized responses 

to this question.

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USCCB Migration Lutheran Immigration 

and Refugee Services and Refugee Service 

3211 4th Street, NE 700 Light Street 

Washington, D.C. 20071 Baltimore, MD 21230 

Phone: 202-541-3352 Phone: 410-230-2700 

Fax: 202-722-8750 Fax: 410-230-2890 

www.usccb.org/MRS http://www.lirs.org 

 

Post-Release Services: Family Preservation Services for Immigrant Children 

Released from Federal Custody

Frequently Asked Questions (FAQ)s 

What are post-release services?

Who receives post-release services?

When are post-release services required?

Why are post-release services necessary?

Where are post-release services available?

Who assists children and families through post-release services?

Who has custody of children during the post-release service period?

How do post-release service providers assist children and families?

When does Child Protective Services assist?

What is the post-release service period?

Who funds post-release services?

What are post-release services? 

Post-release services ensure safety, well-being, and a path to permanency for unaccompanied alien children1

(UAC) released from federal custody to family members and other caregivers throughout the United States. 

Through risk assessment, action-planning with families around areas of need and concern, systems advocacy 

with community providers, and culturally-appropriate services and community referrals, post-release services 

strengthen families and protect children. Lutheran Immigration and Refugee Service (LIRS) and the United 

States Conference of Catholic Bishops (USCCB) have provided post-release services for children released from 

federal custody since 1994. 

Who receives post-release services? 

In the US, UAC who are apprehended by immigration authorities due to their lack of immigration status are 

placed in the custody and care of the U.S. Department of Health and Human Services’ Office of Refugee 

Resettlement (HHS/ORR). HHS/ORR makes and implements placement and service decisions of all UAC’s 

while in federal custody. UACs have the right under federal law to be released to family members or other 

responsible adults (referred to as “sponsors”). HHS/ORR-funded care providers refer UAC who are released to 

family members (or other approved sponsor) to one of the HHS/ORR-funded agencies providing post-release 

services based on their assessment of the needs of the child, relationship and motivation of the sponsor, and 

ability of the sponsor to meet the child’s unique needs. Not all children released from federal custody receive 

post-release services. The percentage of released children who receive post-release services fluctuates and is 

subject to allocation of funding.

 

1

 The term `unaccompanied alien child' means a child who has no lawful immigration status in the United States; has not attained 18 

years of age; and with respect to whom there is no parent or legal guardian in the United States; or no parent or legal guardian in the 

United States is available to provide care and physical custody. (Homeland Security Act of 2002). 

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When are post-release services required? 

The Trafficking Victims Protection Re-Authorization Act (TVPRA) of 2008 requires the Secretary of Health 

and Human Services to conduct follow-up services2, during the pendency of removal proceedings, for children 

for whom a home study was conducted. Home studies are required if the child is a victim of severe trafficking 

in persons, has a disability as defined in Section 3 of the American Disabilities Act, if the child has been a 

victim of physical or sexual abuse under circumstances that indicate that the UAC’s health or welfare has been 

significantly harmed or threatened, or if the proposed sponsor clearly presents a risk of abuse, maltreatment, 

exploitation, or trafficking to the child.3The TVPRA also authorizes the Secretary to conduct follow-up 

services in cases involving children with mental health or other needs who could benefit from ongoing 

assistance from a social welfare agency. A sponsor is not obligated by law to accept post release services. 

Why are post-release services necessary? 

Child welfare practitioners have found the provision of family preservation services following family 

reunification to be essential to reducing the risk of harm to children and increasing the ability of parents to 

protect and supervise. Although family reunification, when safe and appropriate, is in the child’s best interest, 

it can also be a highly stressful time, in particular, for families that have been separated for years, or, for 

children who are released to adults with whom they have little or no previous relationship. For UAC and their 

sponsors, environmental factors such as immigration status, English language ability, extent of integration, and 

lack of an extended family support structure in the US further compound the risk for breakdown upon 

reunification. Ultimately, supporting a successful reunification through post-release services reduces the 

likelihood of family breakdown, placement into foster care, commission of crime, recidivism into the juvenile 

justice system, recidivism into treatment placement, or first time entry into adult corrections. 

 

Where are post-release services available? 

UAC referred to LIRS and USCCB receive post-release services from a local, community-based organization 

anywhere in the US or U.S. territories. Post-release services follow the child; therefore, if the child and family 

move, or the approved sponsor arrangement breaks down and the child moves in with another family member, 

the child continues to receive services anywhere in the US. 

Who assists children and families through post-release services? 

LIRS and USCCB provide post-release services through their established networks of community-based 

agencies with expertise in professional child and family services and services for immigrants. We believe 

community-based services are essential and practitioners with established local partnerships and knowledge of 

local resources are best equipped to do this work. Education and ongoing support are necessary to assist 

community-based providers in tailoring their service approach to adequately address the unique needs of 

undocumented and mixed status families and help them navigate systems such as medical and mental health 

services, schools, direct assistance and the immigration courts. 

Who has custody of children during the post-release service period? 

The federal government relinquishes custody of the UAC once they are released to sponsors. Therefore, 

HHS/ORR retains no custodial authority once a child is released to a sponsor, even in cases in which 

LIRS/USCCB are providing post-release services. Although the sponsor signs a document stating s/he will care 

for the child, this document does not grant legal guardianship. Sponsors may apply for and receive legal 

guardianship according to state law; however, due to fear of being made known to immigration authorities, 

instability in housing or employment, and other challenges faced by undocumented sponsors, it is common that 

sponsors do not obtain guardianship leaving the UAC with no legal guardian. 

 

2 While the term “follow up services” is used in the TVPRA, we use the term “post release services” for the purpose of this document 

since the implementing agency within HHS, the Office of Refugee Resettlement (ORR), uses the term “post release services”, and our 

agencies have also adopted the term. They are two terms used synonymously. 

3

 http://www.justice.gov/olp/pdf/wilberforce-act.pdf 

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How do post-release providers assist children and their families? 

USCCB and LIRS implement a strengths-based family strengthening and kinship navigator approach adapted to 

the UAC’s unique needs. This approach engages the family as active participants in goal-planning and 

achievement by empowering them to navigate community resources independently. This includes identifying 

the family’s protective factors,4such as strong extended family relationships, the desire for education and 

achievement for their children, and the maintaining of cultural connections while integrating into U.S. society. 

An assigned case manager coordinates an individualized package of services to UAC and their sponsors 

depending on their unique needs. Services include: 

 Home visits and family preservation services 

 Ongoing psycho-educational support and opportunities to foster community integration 

 Systems advocacy and education to overcome barriers to services to include enrolling in public school,

ensuring access to individual service plans (IEP) in school to include ESL courses and tutoring, and 

finding affordable and bilingual health care providers 

 Identification of resources to support the family in meeting basic needs 

 Connection to community supports, whether places of worship, ethnic community, and/or support 

groups 

 Continuous assessment of child safety and well-being 

 Referring children to low cost or pro bono immigration legal assistance and educating children and their 

families about immigration processes 

 Convening, supporting, and encouraging interdisciplinary panel to discuss cases, as needed 

When does Child Protective Services assist? 

Local child protective services (CPS) are contacted per mandated reporting requirements, i.e. in cases of alleged 

child maltreatment by the sponsor. If needed, CPS may assign a guardian ad litem, or open an investigation. 

Responses by CPS to cases of alleged maltreatment of undocumented children vary by location, and LIRS and 

USCCB provide ongoing education to CPS about the needs of children in immigration proceedings. 

What is the post-release service period? 

The TVPRA mandates post-release services for children who received a home study continue throughout the 

duration of his or her removal proceedings, or, until they turn 18 years old, whichever happens first. For 

children released without a home study, post-release services are provided for six months, and potentially 

longer if in a professional’s judgment, the child could benefit from ongoing assistance. 

Who funds post-release services? 

Currently, most post-release services are funded by HHS/ORR. However, LIRS and USCCB also provide nongovernmental assistance to children identified as needing services after release from custody. 

Please contact us if you would like further information about post release services for a child you know, or for 

information about becoming one of our network providers. 

Migration & Refugee Services

U.S. Conference of Catholic Bishops

3211 4th Street, NE

Washington, DC 20017-1194

(202) 541-3081 / (202) 541-5409

migratingchildren@usccb.org

www.usccb.org/MRS 

Children’s Services

Lutheran Immigration & Refugee Service

700 Light Street

Baltimore, MD 21230

(410) 230-2757

childrenservices@lirs.org

http://www.lirs.org

 

4 Weine, S. (2008). Family Roles in Refugee Youth Resettlement from a Prevention Perspective. Child and Adolescent Psychiatric Clinics of North America, 17 (3), 515-532. 

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commonwealth of virginia 

Secretary of Public Safety and Homeland Security 

AUgust 13, 2018

 

Virginia Department of 

Juvenile Justice Report of 

Findings 

Shenandoah Valley 

Juvenile Center 

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 Page 1 

Table of contents 

Executive Summary 

Background 

Role of the Department of Juvenile Justice 

Secretary of Public Safety and Homeland Security and Department of Juvenile Justice Inquiry 

The Findings 

Department of Juvenile Justice Report 

Introduction 

Review Process 

Findings 

Conclusion and Recommendations 

Recommendations for SVJC 

Recommendation for Virginia Board of Juvenile Justice 

Memo From Child Protective Services (CPS) 

 

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Executive summary 

background 

In fall 2017, three migrant children detained by the federal government’s Office of 

Refugee Resettlement (ORR) at the Shenandoah Valley Juvenile Center (SVJC) filed a federal 

class action lawsuit alleging abuse by the guards at SVJC. In early 2018, out of concern for the 

safety of the residents, Virginia Department of Juvenile Justice (DJJ) certification team 

reviewed prior certification documents and visited SVJC to monitor and observe conditions in 

the facility. The certification team did not find any immediate concerns regarding the health 

and safety of the residents. 

On June 21, 2018, a story was published reporting the alleged abuse contained in the 

lawsuit. The Governor takes these allegations very seriously and, recognizing the severity of 

the information contained in the lawsuit, directed Secretary Brian J. Moran to initiate an 

inquiry. The Secretary immediately contacted the director of Department of Juvenile Justice 

and the Governor’s Chief of Staff to identify a plan of action and commenced the 

investigation. 

Findings and the process of the investigation are contained below.

role of the department of juvenile justice 

Pursuant to regulations issued by the State Board of Juvenile Justice, DJJ has oversight 

but not operational responsibility for locally operated juvenile detention centers. According to 

6VAC35-20-36.1, whenever the DJJ becomes aware of a health, welfare, or safety violation in a 

locally operated detention center, the Department shall take immediate action to correct the 

violation, if not already done by the program or facility.1

 The actions include reporting the 

situation to child protective services (CPS), the Virginia State Police, or the local law 

enforcement agency as applicable. Additionally, 6VAC35-20-37 provides for the DJJ Director 

to take immediate administrative actions when evidence is found of health, welfare, or safety 

violations to include but not limited to: 

 The immediate removal of juveniles from the program. The immediate removal by DJJ 

would be limited to court involved youth who are in local or state custody. The Director 

would notify ORR of the action and ORR is responsible for any removal of youth in 

federal custody. 

 Placing the facility on probationary certification status. 

                                                            

1 Virginia regulation, 6VAC35-101-95, requires the juvenile detention center staff to report all known criminal activity by 

residents or staff to the facility administrator. The facility administrator shall notify the appropriate persons or agencies to 

include law enforcement, child protective services and DJJ, if applicable and appropriate, of suspected criminal violations 

by residents or staff. The law enforcement agency and CPS would determine necessary action.

PSI-137
 

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 Issuing a preliminary order to suspend the certification of the detention center when 

conditions or practices exist in the facility that pose an immediate and substantial threat 

to the health, welfare, or safety of the residents. 

After DJJ’s thorough investigation, it did make referrals to local child protective services, 

but based on their investigation, determined that no further action was necessary. See 

Department of Juvenile Justice Report. 

The SVJC is an independent juvenile detention facility for youth managed by the 

Shenandoah Valley Juvenile Center Commission. SVJC staff are not state employees. 

Furthermore, DJJ does not have any official relationship or jurisdiction over the ORR, nor the 

federally supervised youth at SVJC. The ORR is a federal program under the U.S. 

Department of Health and Human Services (HHS) that works with unaccompanied minors 

while their immigration cases are pending. 

Unaccompanied minors are immigrant youth under the age of 18 who have no parent or 

legal guardian in the United States. Unaccompanied minors are placed at SVJC when ORR 

has determined that a less secure placement would not be appropriate. The DJJ has no 

contractual relationship with ORR, nor auditing or monitoring authority or responsibility over 

the federal youth housed at SVJC. The federal youth program is audited and overseen solely 

by ORR. Pursuant to a cooperative agreement that SVJC entered with ORR and HHS, ORR 

monitors SVJC for compliance with their requirements through announced and unannounced 

monitoring visits. These are not the youth who have been subject to the recent family 

separation policies of the Trump administration. 

secretary of public safety and homeland 

security and department of juvenile justice 

inquiry 

On the evening of June 21, 2018, upon the Governor’s directive, Secretary Moran and 

DJJ Director, Andrew Block, met with the SVJC Superintendent and toured the facility, 

including visiting the units housing the youth in ORR custody. 

On June 21, 2018, with permission and conditions set by ORR, the DJJ certification and 

quality assurance teams conducted interviews with SVJC staff and all federal residents at 

SVJC at that time. According to the SVJC, none of the youth originally named as plaintiffs in 

the October ’17 lawsuit were still present at SVJC during the visits and interviews. 

Additionally, a protective order had been entered in March 2018 that prohibits SVJC and 

ORR from disclosing the identities of any of the plaintiffs in the litigation. The following day, 

the Secretary participated in a call with DJJ detailing the results of their interviews at the 

facility. The team, with the addition of DJJ investigators who are sworn law-enforcement 

officers, returned to SVJC on June 25 to continue their interviews and review the files of 

federal residents. 

 

PSI-138
 

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On June 22, 2018, Secretary Moran communicated with Virginia’s Congressional 

delegation and other government leaders, including all members of the Virginia General 

Assembly. He provided them with a fact-sheet and other details relevant to the investigation 

and the facility’s relationship with the Commonwealth. 

On June 27, 2018, Secretary Moran and Governor’s Office staff completed a conference 

call with Scott Lloyd, Director of ORR, and Laura Trueman, Principal Deputy Director of the 

Office of Intergovernmental and External Affairs at HHS, regarding standard overview of 

facilities in Virginia and other background and operational information. 

the findings 

On June 28, the DJJ submitted a preliminary report and Child Protective Services (CPS) 

provided an update to their investigation to Secretary Moran. The conclusions of their 

investigations indicate that there were no life, health, or safety concerns for the residents at 

SVJC. 

As of July 3, CPS completed its investigation into the allegations of abuse and found that 

there was no evidence of abuse or neglect (see accompanying DJJ and CPS reports). 

 

PSI-139
 

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Department of Juvenile Justice Report 

introduction 

On June 21, 2018, Governor Ralph Northam requested Brian J. Moran, Secretary of 

Public Safety and Homeland Security, and the Department of Juvenile Justice (DJJ) to 

conduct an inquiry into the allegations contained in a lawsuit regarding the safety of federal 

residents housed at the Shenandoah Valley Juvenile Center (SVJC). At the time of the 

inquiry there were 22 residents placed by the Office of Refugee and Resettlement (ORR) at 

the facility. As reported by the residents, one resident has been there since September 30, 

2016, and the other 21 residents were admitted between November 12, 2017, and June 12, 

2018. According to the SVJC, the residents who were named plaintiffs in the October ’17 

lawsuit were no longer in the facility at the time of the interviews. 

While the DJJ team found SVJC in compliance with applicable regulations and 

certification standards, they did identify areas where SVJC could improve programming for 

the youth in the custody of ORR. Accordingly, this memo includes both a description of the 

investigative process and findings, as well as a set of recommendations for SVJC. 

The memo also includes a recommendation that DJJ will forward to the Board of the 

Virginia Department of Juvenile Justice: to amend current certification standards so that DJJ 

can better track the youth who are housed in local detention centers but in the legal custody of 

a different agency. 

review process 

Following the Governor’s directive, a DJJ team of certification and quality assurance staff 

visited SVJC on June 21, 2018, and June 25, 2018. It is also worth noting that subsequent to 

the initial filing of the lawsuit in October of 2017, DJJ staff monitored ongoing conditions at 

SVJC. Specifically, DJJ certification staff conducted a modified certification visit to SVJC to 

monitor and observe conditions in the facility in March of 2018, and also reviewed prior 

certification documents to determine if any problems similar to those alleged in the lawsuit 

had been flagged. Neither the review of prior reports, nor the visit in March identified any 

immediate concerns about the life, health, and safety of the residents in the facility. 

During the June 21 visit, DJJ staff interviewed all of the federal residents at SVJC. The 

team was not able to substantiate the conditions described in the lawsuit concerning the 

operations of SVJC or the mistreatment of residents. After obtaining permission from ORR, 

the team returned on June 25 and reviewed case files, medical files, room confinement forms, 

and other documentation to assess compliance with regulations relating to the quality of care. 

For the case review process and interviews, ORR placed the following restrictions: 

 Case files are federal property and cannot be duplicated or copied; 

 Audit team could not keep written notes of information in case files; and 

 A SVJC staff member had to be present for all interviews. 

PSI-140
 

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findings 

During interviews, three residents reported that they had experienced abusive behavior 

by staff. A further review of documentation revealed that two of these complaints were 

reported by the facility to Child Protective Services (CPS). CPS determined that these 

complaints did not meet the legal definition of abuse and neglect. Upon further consideration, 

CPS reopened the two cases and was on-site for a further review to include interviews with all 

of the federal residents. The third report was an initial complaint that occurred during the 

interview process and was reported to CPS by DJJ staff. 

SVJC uses room confinement as part of its behavior management system to ensure the 

safety and security of residents, staff, and the facility. During interviews with the federal 

residents, and supported by room confinement records in the case files, there were no 

instances where residents were confined more than 24 hours. With the exception of one 23-

hour confinement, confinements lasted approximately 4 hours. Pursuant to the case file 

records, in each instance of confinement, visual inspections of the residents by staff were 

made at least once every 30 minutes. 

The facility uses approved restraints pursuant to the Regulations Governing Juvenile 

Secure Detention Centers, 6VAC35-101-1130. Review of training records indicated that all 

staff are trained in the use of restraints through a behavioral management system titled 

“Handle With Care.”2 Per regulation, mechanical restraints shall not be used as punishment; 

however, they are used for the protection of resident and staff. The regulation requires that 

SVJC train staff in the use of mechanical restraints including but not limited to the restraint 

chair and mesh spit guards. The restraint chair is used for out-of-control residents who cannot 

be safely restrained by less intrusive methods. While in the chair, a mesh spit guard can be 

placed on the resident’s head to prevent spitting or biting. No residents interviewed had 

knowledge of the use of the restraint chair. In two instances reviewed, staff were disciplined 

for using an unapproved physical restraint technique that did not follow “Handle with Care” 

guidelines. Neither of these restraints related to the use of the restraint chair. 

 

Interviews with staff and residents revealed due process is not well understood and this 

lack of understanding appears to be related to language barriers. A review of resident files 

showed disciplinary reports where federal residents acknowledge by noting and signing their 

right to appeal or not to appeal disciplinary action. 

A review of files documented that medical concerns are responded to immediately. 

However, there was one incident wherein one resident did not receive medication as 

prescribed because the medication ran out. The resident missed one day of medication. 

Regarding nutrition, residents stated they receive three meals a day and one evening 

snack. A review of resident files indicated special diets are documented and prepared for 

residents as required. 

                                                            

2

 See, “Behavioral Management System, Inc.”, Mark Chapman, 1984.

PSI-141
 

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Interviews revealed that residents generally understood the grievance process and how to 

get issues resolved. Documentation in the files indicated the same. 

Two DJJ investigators accompanied the team on June 25 and were tasked with identifying 

any gang activity. The investigators toured four housing units and observed three gang 

identifiers relating to MS-13. Two were drawings of the devil horn hand sign used by 

MS-13 and one was a "MS-13" etched in the window of one of the resident's doors. A fourth 

gang identifier was an 18th Street symbol scratched into the door of a resident’s room. 

Overall, the housing units were very clean and free from graffiti. When identified by ORR 

prior to placement at SVJC, the file records indicated that SVJC received the notification of 

potential gang involvement upon admission. 

child protective services follow-up 

Based on the referrals from DJJ staff, Child Protective Services (CPS) staff from 

Shenandoah Valley Social Services conducted follow-up investigations, including individual 

interviews with a staff member who had allegedly engaged in abusive behavior. 

Following these investigations, CPS found no abuse or neglect had taken place.

conclusion and recommendations 

On June 21, 2018, a DJJ team consisting of five members from the Certification Unit and 

the Quality Assurance Unit visited SVJC.3 On June 25, 2018, an eight member team from the 

Certification Unit, the Quality Assurance Unit, and the Investigative Unit also visited SVJC.4

 

CPS staff from Shenandoah Valley also conducted follow-up visits. 

During this investigation DJJ staff found no life, health, or safety violations for youth in 

ORR’s custody who have been placed at SVJC. Likewise, CPS, in their investigation, did not 

find evidence to support allegations of abuse or neglect. The team did find that the SVJC is a 

well-run facility that attempts to treat its staff and residents with respect and dignity. 

While DJJ staff did not find sufficient evidence to support the conditions described in the 

lawsuit, the DJJ staff nevertheless identified areas where SVJC could strengthen its 

programming for this uniquely challenging group of youth—young people who have been 

frequently exposed to high levels of trauma, who are separated from their families, and who 

confront numerous language and cultural barriers, among others, to succeeding in SVJC and 

upon their release. 

In addition, DJJ identified a gap in its certification authority over local detention centers 

which is that, without permission from the custodian agency (in this case ORR), DJJ does not 

have access to the records of youth, nor the youth themselves, who are in the custody of ORR 

                                                            

3 On June 21 2018, the team members included Shelia Palmer (team leader), Clarice Booker, Mark Lewis, Andrea 

McMahon, and Leah Nielsen. 

4

 On June 25, 2018, the team members included Shelia Palmer (team leader), Clarice Booker, Mark Lewis, Andrea 

McMahon, Deidre Davis, Nina Joyner, Dennis Sullivan, and John Rohde. 

PSI-142
 

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or other third parties. Accordingly, in this memo DJJ has also included a recommendation that 

it intends to propose at the next DJJ Board meeting. 

Finally, while DJJ staff found nothing to indicate their misuse or abuse at SVJC, given the 

concerns raised by the allegations in the lawsuit about physical restraints more generally, and 

the fact that the Board of DJJ is charged with regulating their use, DJJ will inform and educate 

the Board about their use in Virginia in order that the Board may properly consider the 

current regulations and whether any changes might be necessary. 

recommendations for svjc 

recommendation 1 

SVJC should provide staff with training and professional development in the areas of 

positive youth development, cognitive behavioral interventions and trauma informed care. 

 

It would benefit SVJC to invest in training for the administrative, management and line 

staff in the areas of positive youth development, cognitive behavioral interventions and 

trauma informed care. SVJC operational tenets are geared more toward a correctional 

philosophy and environment than a therapeutic model. SVJC currently operates a Community 

Placement Program for DJJ that incorporates the tenets of DJJ’s community treatment model. 

The Missouri Youth Services Institute (MYSI) has trained all staff in the CPP in the 

principles of a therapeutic environment. As the youth placed by ORR are typically long term 

residents and similar to DJJ youth in that they have significant exposure to trauma, it would be 

of value for SVJC to adopt a similar community treatment model framework into the units 

housing the federal residents. Consistent staff and interactions with residents can diminish 

aggressive behaviors. If ORR were willing to collaborate with DJJ in this effort, it would 

promote a consistent philosophical approach within SVJC. 

recommendation 2 

SVJC should increase the staff’s understanding of and sensitivity toward the unique 

cultural backgrounds of the youth in the federal program, expand the culturally relevant 

programming for these youth, and increase the number of bilingual staff. 

Culturally competent practices are crucial for ensuring effective services and treatment 

delivery to the Latino population at SVJC. SVJC staff need increased awareness of cultural 

factors that influence the federal residents’ behavior and thinking patterns. A lack of social 

and emotional support networks impact stress and anxiety for the Latino youth and frequently 

is displayed as aggressive and negative behaviors. SVJC should reach out to and collaborate 

with local Latino serving agencies for assistance in the development of culturally relevant 

training and resources, and for assistance with recruitment of bilingual staff. Additional 

bilingual line staff and mental health counselors that understand the variations in the Spanish 

language within different Latino cultures would assist in addressing miscommunication and 

misunderstandings by the federal residents. 

PSI-143
 

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recommendation 3 

SVJC should strengthen the procedures for the use of mechanical restraints and re-train 

staff on the use of physical and mechanical restraints. 

Although SVJC’s procedures for mechanical restraints meet certification regulations, the 

procedure could be clearer and specific to the use of mechanical restraints. The use of a 

restraint chair and spit guards, as well as when and how it is used, should be better defined. 

DJJ suggests re-training all staff on the use of all restraints both physical and mechanical to 

include enhanced training on de-escalation techniques (see Recommendation 4). 

recommendation 4 

SVJC should provide ongoing training in the effective use of de-escalation techniques for 

all staff at SVJC. 

SVJC staff require additional training on effective de-escalation practices. De-escalation 

techniques can prevent disruptive behavior, reduce the need for physical or mechanical 

restraints, and enhance the safety of the resident and staff. As many de-escalation techniques 

require effective communication this recommendation is linked to the need for additional 

bilingual staff. 

recommendation 5 

SVJC should explore design and furniture modifications to create a setting more 

conducive to working with a population that has high rates of trauma. 

SVJC was designed and constructed as a secure juvenile detention center meant to 

provide short-term confinement for pre-adjudicated youth. At the forefront, it must provide a 

safe and secure environment for residents and staff and protect the public safety. The physical 

design of the facility is based on a more traditional correctional setting. Housing units and 

individual rooms are designed for direct supervision of residents and monitoring by staff 

inside and outside of the housing areas. As SVJC is not able, without considerable cost, to 

change the physical design of the housing units or rooms, it should explore other options with 

regard to furniture styles, arrangement of furniture and paint colors that could help modify 

the environment and make it more developmentally appropriate and trauma responsive. 

 

PSI-144
 

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recommendation for virginia board of 

juvenile justice 

recommendation 1 

The Board of Juvenile Justice should promulgate an amendment to the regulations 

governing local juvenile detention centers to require that any time such a center enters into a 

contract with a third-party to house youth in the custody of the third-party, the contract must 

allow for DJJ staff to have the same access to the youth and their records as DJJ has to all 

other youth in that facility. 

Recommendation 2 

DJJ will inform and educate the Board about the use of mechanical restraints in juvenile 

correctional centers and locally operated juvenile detention centers in Virginia in order that 

the Board may properly consider the current regulations regarding the use of mechanical 

restraints and whether any changes might be necessary. 

PSI-145
 

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memo from child protective services (cps) 

On 06/22/2018, the Shenandoah Valley Department of Social Services (SVDSS) began 

receiving numerous calls regarding allegations of abuse/neglect, which had been outlined in 

media reports released on 06/21/2018, as referenced within the executive summary of the DJJ 

report preceding this appendix. Specific to the calls received were allegations of 

abuse/neglect by guards against unaccompanied migrant children being detained at the 

SVJDC. These reports alleged the migrant children to having been “beaten and handcuffed” 

while also being “tied to chairs with bags placed over their heads”. Additional allegations 

referenced these minors as being left “nude and shivering within their concrete cells”. While 

none of these current reports identified any specific alleged abuser(s)/neglector(s), two 

previous reports had alleged physical abuse by one facility guard in the attempt to restrain two 

migrant children. As both of these previous reports had been determined invalid of meeting 

the requirements for a CPS response, it was suggested this decision be reconsidered. 

Therefore, on 06/22/2018, the SVDSS initiated an investigation into all allegations received. 

The SVDSS began the process of interviewing all migrant children on 06/25/2018. This 

included eighteen children, again, all migrant children housed at the SVJDC. Interviews 

continued on 06/27/2018 and 06/28/2018 to include both migrant children and a number of 

administrative and supervisory staff. A final interview with the alleged abuser took place on 

07/03/2018. 

The interview process with all children included the CPS investigator employed by the 

SVDSS, the use of an interpreter retained by the SVDSS in addition to oversight by the CPS 

Regional Consultant with the Virginia Department of Social Services. Interviews with 

administrative and supervisory staff in addition to the alleged abuser involved the CPS 

investigator and the CPS regional consultant. The investigative process also included a full 

tour of the juvenile facility in addition to the review of hard record files for each migrant child. 

Also reviewed was video footage relating specifically to one of the allegations of physical 

abuse. Video footage relating to the second allegation of physical abuse was no longer 

accessible. 

In conclusion of the CPS investigation, no information was obtained to implicate any 

additional alleged abuser(s)/neglector(s). Furthermore, the information obtained through 

child interviews found no evidence to support the allegations of any mistreatment or neglect. 

This was further evidenced by a complete tour of the SVJDC and visual 

inspection/demonstration of the restraint and protective equipment utilized by the facility, 

which, according to the DJJ, does meet certification regulations. Finally, a face-to-face 

interview with the alleged abuser and a review of the available video footage specific to the 

allegations of physical abuse found no preponderance of evidence to support a CPS finding. 

Verbal notification of these preliminary findings being in support of an unfounded CPS 

disposition was provided to the alleged abuser and the SVJDC on 07/03/2018. The final 

report documenting all evidence obtained and including all required, written notifications will 

be completed by 08/03/2018. 

PSI-146
1 

Unaccompanied Alien Children 

Joint Concept of Operations

July 31, 2018 

PSI-147
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PSI-148
3 

List of Acronyms 

A-File Alien File

A-Number Alien Number

ACF Administration for Children and Families

CBP U.S. Customs and Border Protection

COA Change of Address

COV Change of Venue

CRCL Office of Civil Rights and Civil Liberties

DHS U.S. Department of Homeland Security

DOJ U.S. Department of Justice

DUCO Division of Unaccompanied Children’s Operations

EOIR Executive Office for Immigration Review

ERO Enforcement and Removal Operations

FEMA Federal Emergency Management Agency

FFS Federal Field Specialist 

FOJC Field Office Juvenile Coordinator

HHS U.S. Department of Health and Human Services

HPC HHS Processing Centers 

ICE U.S. Immigration and Customs Enforcement 

IJ Immigration Judge

INA Immigration and Nationality Act

JCO Joint Concept of Operations

JFRMU Juvenile and Family Residential Management Unit

MOA Memorandum of Agreement

MOU Memorandum of Understanding 

NCIC National Crime Information Center

NTA Notice to Appear

OFO Office of Field Operations

OIG Office of Inspector General 

OREC Order of Recognizance 

ORR Office of Refugee Resettlement 

ROR Released on Own Recognizance

SEN Significant Event Notification

SIJ Special Immigrant Juvenile

SIR Significant Incident Report

TVPRA William Wilberforce Trafficking Victims Protection Reauthorization Act

of 2008

UAC Unaccompanied Alien Child(ren)

UAC MAP Unaccompanied Alien Children Manual of Procedures 

USBP U.S. Border Patrol

USCG U.S. Coast Guard 

PSI-149
4 

TABLE OF CONTENTS

1. Introduction ................................................................................................................................... 5

2. Custody Transfer and Transportation .................................................................................... 8

A. Placement into ORR Custody ................................................................................................. 8

 1. Referral Notification .......................................................................................................... 8

 2. Preparation......................................................................................................................... 10

 3. Logistics............................................................................................................................. 11

 4. Custody Transfer .............................................................................................................. 12

 5. Transfers to Long-Term Foster Care ............................................................................. 14

B. Discharge from ORR Custody .............................................................................................. 15

 1. Discharge Notification..................................................................................................... 15

 2. Preparation......................................................................................................................... 16

 3. Logistics............................................................................................................................. 18

3. UAC Processing........................................................................................................................... 22

A. Immigration Processing ......................................................................................................... 22

 1. Issuing NTAs to UAC...................................................................................................... 22

 2. Filing NTAs....................................................................................................................... 23

 3. Information Requests between HHS and DHS............................................................. 24

 4. Change of Address/Change of Venue Notices ............................................................. 26

B. Influx Matters.......................................................................................................................... 27

 1. Placement Prioritization................................................................................................... 27

 2. Use of HHS Influx Care Facilities ................................................................................. 29

 3. Services at HHS Influx Care Facilities.......................................................................... 29

4. UAC Care and Services............................................................................................................. 33

A. Service Requirements............................................................................................................. 33

 1. Medical Evaluation in DHS Custody............................................................................. 33

 2. Medical Emergencies in DHS Custody ......................................................................... 34

 3. Flores Minimum Standards for HHS Licensed Facilities........................................... 35

B. Allegations of Abuse in DHS Custody................................................................................ 37

 1. UAC Reported Abuse to DHS ........................................................................................ 37

 2. UAC Reported Abuse to HHS ........................................................................................ 39

C. Notifications and Access ....................................................................................................... 41

 1. Notification and Approved Contacts in DHS Custody................................................ 41

 2. Notification and Contact of UAC Family in HHS Custody........................................ 41

5. Conclusion .................................................................................................................................... 43

PSI-150
5 

1. INTRODUCTION

An unaccompanied alien child (UAC) is defined in statute as a child who: A) has no lawful 

immigration status in the United States; B) has not attained 18 years of age; and C) with respect 

to whom (i) there is no parent or legal guardian in the United States, or (ii) no parent or legal 

guardian in the United States is available to provide immediate care and physical custody.1

 

The Department of Homeland Security (DHS) and the Department of Health and Human 

Services (HHS) each have separate responsibilities for the care, custody, and transfer of UAC. 

U.S. Customs and Border Protection (CBP) apprehends and holds UAC encountered at or near 

the border. U.S. Immigration and Customs Enforcement (ICE) apprehends UAC in the interior 

of the country, is responsible for custody transfer and repatriation activities, and represents the 

U.S. Government in removal proceedings before the U.S. Department of Justice (DOJ). HHS’ 

Office of Refugee Resettlement (ORR) is responsible for coordinating and implementing UAC 

care and placement responsibilities once UAC are transferred to the program by DHS, as well as 

conducting suitability determinations to ensure safe releases of UAC to sponsors who can 

provide for their physical and mental well-being.

2

The 1997 Flores Settlement Agreement, Homeland Security Act of 20023, and the William 

Wilberforce Trafficking Victims Protection Reauthorization Act of 2008 (TVPRA)4 directly 

impact UAC policies and procedures. Departmental guidance, policies, procedures, and 

interagency agreements further inform UAC operations. 

Office of Inspector General (OIG) Report Background 

In March 2008, the HHS Office of Inspector General (OIG) issued a report recommending that 

HHS and DHS establish a Memorandum of Understanding (MOU) that would, “...clearly 

delineate the role and responsibilities of each Department” with regard to UAC operations. In 

written comments to the draft report, HHS’ Administration for Children and Families (ACF) 

pointed out that ORR was drafting a Joint Operations Manual with DHS as a first step toward 

drafting an MOU. Due to intervening changes in statutory authority and other administrative 

priorities, work on a Joint Operations Manual stalled. 

2016 Memorandum of Agreement 

On February 19, 2016, DHS and HHS signed a Memorandum of Agreement (MOA) regarding 

UAC. The purpose was to accomplish the following: continue addressing the needs of UAC to 

ensure the safe and expedited transfer and placement from DHS to HHS custody; maximize 

efficiency in the allocation and expenditure of respective program costs; ensure information is 

transmitted to facilitate appropriate placement decisions and for HHS to promptly place the child 

 

1 6 U.S.C. §279(g)(2). Although these children may have a parent or guardian who lives in the United States, they 

are classified as unaccompanied if the parent or guardian cannot provide immediate care. 2 Certain UAC from contiguous countries (Mexico and Canada) will not be transferred to ORR. This document does 

not address these UAC.

3 6 U.S.C. § 279.

4 8 U.S.C. § 1232.

PSI-151
6 

in the least restrictive setting that is in the child’s best interest until the child is released to an 

appropriate sponsor; continue the statutorily-required consultation between the departments with

respect to UAC placement determinations; protect UAC in the custody of the United States or 

released to sponsors from mistreatment, exploitation, and trafficking; and promote effective 

immigration processing as well as the safe repatriation and reintegration of UAC. 

Working Group Structure 

The 2016 MOA called for the establishment of a working group comprised of UAC subject 

matter experts from both departments to address operational matters for inclusion in a Joint 

Concept of Operations (JCO). The working group from HHS included ORR staff from a diverse 

group of backgrounds including supervisory program operations staff; field components; grantee 

oversight; monitoring and compliance; and policy and procedures. The working group from 

DHS included representatives from the Office of Policy, Strategy, and Plans, Office of General 

Counsel, Office of Privacy, Office of Civil Rights and Civil Liberties, CBP, ICE, U.S. 

Citizenship and Immigration Services (USCIS), USCIS Ombudman’s Office, U.S. Coast Guard 

(USCG), and Federal Emergency Management Agency (FEMA). The working group met on 

several occasions in late 2016 and concluded that a JCO outlining the responsibilities of DHS 

and HHS in the overlapping operations concerning processing, care and services, and 

transportation of UAC, would fulfill each responsibility required under Paragraph 4A of the 2016 

MOA. The co-chairs of the working group left open the possibility of further collaboration on 

additional overlapping topic areas for inclusion in the JCO outline once the initial draft is 

published in order to further document joint efforts between the agencies or address operational 

issues in a cooperative manner. 

2018 Memorandum of Agreement 

On April 13, 2018, ORR, ICE, and CBP entered into a new Memorandum of Agreement (MOA) 

regarding consultation and information sharing practices between the agencies. In the 2018 

MOA, ORR agreed to do the following: fingerprint all sponsors and adult members of the 

sponsor’s household prior to the release of a UAC from ORR care and custody; transmit 

fingerprints/biographic information on sponsors and adult household members to DHS while a 

UAC is in ORR care; and to report certain situations or incidents to DHS component agencies as 

outlined in the MOA. DHS agreed to provide ORR certain documents at the time of initial 

referral necessary for ORR to make informed placement decisions; provide ORR with criminal 

history information or investigatory information, to the extent allowed by law, that would aid 

ORR in making care and placement decisions for UAC; provide ORR summary responses to 

fingerprint/biographic submissions, specifically immigration status information, criminal history 

checks of the national databases, and checks for wants and warrants. The 2016 MOA remains in 

effect and is not superceded by the 2018 MOA. 

Purpose and Scope 

PSI-152
7 

The JCO provides field guidance and standardization of interagency policies, procedures, and 

guidelines related to the processing of UAC encountered by DHS, whose care will be transferred 

to HHS, after being placed in removal proceedings pursuant to section 240 of the Immigration 

and Nationality Act (INA). The process for returning UAC to a contiguous country (i.e., Canada 

or Mexico) through withdrawal of an application for admission is not directly addressed in the 

JCO and shall be in accordance with the TVPRA. 

The JCO memorializes current practices in accordance with:

• Homeland Security Act of 2002, Pub. L. No. 107-296, § 462, 116 Stat. 2135, 2202 

(codified at 6 U.S.C. § 279); 

• Immigration and Nationality Act of 1952, Pub. L. 82–414, 66 Stat. 163, 8 U.S.C. ch. 12; 

• Trafficking Victims Protection Reauthorization Act of 2008 (TVPRA), Pub. L. No. 110-

457, § 235, 122 Stat. 5044 (codified in principal part at8 U.S.C. § 1232); 

• Prison Rape Elimination Act of 2003 (PREA), 42 U.S.C. §15607, 

• Jenny Lisette Flores, et al. v. Janet Reno, Attorney General of the United States, et al., 

Case No. CV 85-4544-RJK (Px) (C.D. Cal. 1996) (Flores Settlement Agreement); 

• Memorandum of Agreement ORR-ICE-CBP Regarding Consultation and Information 

Sharing in UAC Matters (April 13, 2018) (MOA ORR-ICE-CBP); 

• Memorandum of Agreement DHS-HHS Regarding Unaccompanied Alien Children 

(February 22, 2018). (MOA 2016); 

• Departmental and agency guidelines, policies, and procedures. 

The JCO does not take the place of agency policy regarding the processing of UAC nor is it a 

substitute for legislative action, where required; rather it is an interagency agreement to 

standardize agency operational relations. The JCO will prove helpful in many situations, but it is 

not intended to be all-inclusive nor to provide comprehensive guidance for every situation. 

Situations requiring interagency coordination with the U.S. Department of Justice and/or U.S. 

Department of Defense – for example, certain influx scenarios and appropriate family 

reunification efforts – will be coordinated separately, in accordance with the law, and as 

resources and capabilities require. 

The JCO will be made available to all applicable staff within each department, as appropriate. 

Updates, amendments, and expansions will occur as needed with agreement from both 

departments. If field staff members have a question that is not addressed here, they shall elevate 

the issue through their respective chain of command. 

The JCO will be revised as needed, and in accordance with applicable department policies and 

changes in law. Suggestions for changes and additions are to be referred to each department’s 

respective chain of command for consideration; however, all additions or alterations must be 

submitted to and approved by headquarters-level policy and counsel offices. 

2. CUSTODY TRANSFER AND TRANSPORTATION

PSI-153
8 

Transfer and transportation from DHS custody to HHS custody, and determination of placement 

while in HHS custody, is a shared responsibility between CBP, ICE – Enforcement and Removal 

Operations (ICE/ERO), and HHS/ORR.

A. PLACEMENT INTO ORR CUSTODY

1. Referral Notification 

a. Responsible Agency: 

i. The DHS agency responsible for the initial UAC determination is responsible 

for notifying ORR and becomes the Referring Agency. 

ii. Upon referral notification, ORR is responsible for UAC placement 

determination. ORR makes the placement determination and notifies both the 

Referring Agency and the facility’s representative by email (“Placement 

Confirmation”) when UAC placement has been obtained. See ORR Policy 

Guide, sections 1.1, 1.2.; See UAC MAP, sections 1.3.1-1.3.2; 

iii. Upon placement confirmation from ORR, ICE/ERO is responsible for 

facilitating the physical transfer of the UAC from DHS custody to HHS 

custody. ICE/ERO may have local agreements in place with CBP to conduct 

transfers to ORR care providers. See ORR Policy Guide, section 1.1; UAC 

MAP, section 1.3.4. 

iv. In most areas, the ICE/ERO transportation contractor coordinates directly with 

CBP and HHS for operational arrangements and estimated time of arrival 

notices.5

 

b. Timeframe/Deadline: 

i. Notification by the Referring Agency to ORR should be made as soon as 

possible, but no later than 48 hours after the UAC determination is made.

6

 

ii. ORR attempts to make a placement determination within (3) three hours of 

notification during standard business hours, absent exceptional circumstances, 

and within 24 hours in most cases, in order to ensure transfer from DHS 

custody to HHS custody occurs within 72 hours of the UAC determination in 

order to meet the statutorily-mandated transfer requirement. See UAC MAP, 

section 1.3.2 

iii. Notification to ICE/ERO for transportation is made immediately upon receipt 

of ORR placement notification. 

 

5 To meet the statutorily mandated 72-hour transfer requirement the ICE/ERO transportation contractor tracks 

movements from the Referring Agency’s time of UAC determination. 6 8 U.S.C. § 1232(b)(2).

PSI-154
9 

c. Operational Requirements: 

i. Notification to ORR and/or ICE through U.S. Border Patrol’s (USBP) system 

of record (E3), Office of Field Operations (OFO) Secure Integrated 

Government Mainframe Access (SIGMA), direct e-mail, and/or the UAC 

Portal includes (see UAC MAP, sections 1.1, 1.3; 2018 MOA ORR-ICECBP, Section IV(A)(1)): 

1. Basic UAC Biographical Data (name, date of birth, country of birth, 

potential sponsor information); 

2. Situational Factors (Health, Pregnancy, travel companions, etc.); 

3. Human trafficking indicators; and 

4. Known criminal or behavioral issues, including arrests, criminal charges 

and convictions, immigration history, gang affiliation or suspected gang 

affiliation, and violence or behavioral concerns. 

ii. ORR sends Placement Confirmation email notification to the Referring 

Agency, which includes (see UAC MAP, section 1.3.3; 2018 MOA ORRICE-CBP, Section IV(A)(3)): 

1. Basic UAC Biographical Data; 

2. Care provider facility name and address; and

3. Facility point-of-contact name and phone number. 

iii. DHS I-191: ICE/ERO generates DHS I-191, Accounting for Disclosure, for 

each record, or group of records disclosed to ORR. 

iv. UAC Initial Placement Referral Form: The UAC Portal should be used 

whenever feasible. However, in the event that the UAC Portal is not 

available, a placement request can be submitted by completing the UAC Initial 

Placement Referral Form and submitting to the ORR Intakes mailbox. A 

completed UAC Initial Placement Referral Form, along with any supporting 

documentation, should be scanned and emailed to 

orrducs_intakes@acf.hhs.gov (with read receipt), or faxed to (202) 401-1022. 

If there are concerns regarding the placement request, please call ORR Intakes 

directly at (202) 401-5709. See UAC MAP, sections 1.3.1-1.3.2 

v. The referring agency should review and verify all information to ensure 

accuracy of UAC medical and disability information (where possible), 

criminal records (if applicable), and sibling or other family with whom the 

UAC was traveling. Contact information for parents, legal guardians, or adult 

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10 

relatives should also be included, as this information can assist in ORR’s 

reunification process. Medical conditions, disabilities, language spoken, and 

criminal history must be disclosed if known, to allow ORR to place each UAC 

in a facility that is equipped to handle that UAC’s specific needs. In the event 

a child is separated from a parent or legal guardian CBP or ICE will enter this 

information into the UAC Portal. See UAC MAP, sections 1.3, 1.3.2. 

vi. For UAC with indicators requiring placement in a restrictive setting (e.g. 

secure, staff secure, or residential treatment facility), ORR Intakes staff 

additionally complete the Intakes Placement Checklist and forward the 

placement request to an ORR FFS Supervisor for a final placement decision. 

The Intakes team communicates the final placement decision to DHS. See

UAC MAP sections, 1.2.4; 1.3.2 

2. Preparation 

a. Responsible Agency: 

i. Prior to transporting, CBP and ICE are responsible for ensuring that the UAC 

has been processed, a Notice to Appear (NTA) has been properly served as 

applicable, ORR shelter placement has been requested, and bed space is 

confirmed. 

ii. The Referral Agency is responsible for any emergency or otherwise necessary 

medical screening, to the extent required by law. For example, the CBP 

Transport, Escort, Detention, and Search (TEDS) policy states that if 

officers/agents suspect that a detainee has an observed or reported medical 

condition, such as a contagious disease, appropriate protective precautions 

must be taken and any required notifications be made according to the 

operational office’s policies and procedures.7

 

iii. ICE/ERO is required to provide appropriate numbers of escort and 

transportation vehicles for transporting UAC, in accordance with agency 

policy. 

b. Timeframe/Deadline: 

i. The UAC must be transferred to ORR within 72 hours after the UAC 

determination, absent exceptional circumstances.

8

c. Operational Requirements: 

 

7 For more information about the CBP TEDS policy, please visit: https://www.cbp.gov/document/directives/cbpnational-standards-transport-escort-detention-and-search. 8 8 U.S.C. § 1232(a)(4). 

PSI-156
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i. ICE IHSC-795J, Medical Summary (Juvenile): The UAC cannot travel 

without a recent medical summary, including an attached list of any 

medications.9

ii. CBP-93, UAC Screening Addendum: Utilized, as appropriate, to assess the 

likelihood that a UAC has been a victim of trafficking or is at risk of being 

trafficked, has a fear of return, and assesses the child’s ability for independent 

decision-making. 

iii. Form I-770, Notice of Rights and Request for Disposition: DHS must provide 

this form to all UACs.

3. Logistics 

a. Responsible Agency: 

i. Non-Secure Staff/Shelter

1. Commercial Air: The ICE/ERO UAC transportation contractor 

coordinates directly with HHS, and CBP as appropriate, for operational 

arrangements and estimated time of arrival notices. The ICE/ERO UAC 

transportation contractor provides unarmed escorts nationwide on longdistance commercial air services of UAC that terminates at non-secure 

ORR shelters.

2. Ground Transport: The ICE/ERO UAC transportation contractor also 

provides ground transportation to local ORR shelters in some areas. 

3. Charter: The ICE/ERO UAC transportation contractor can coordinate 

charter flights for travel to New York, Chicago, Miami, and Phoenix, if 

approved by ICE/ERO Juvenile & Family Residential Management Unit. 

These cities have high concentration of ORR shelter beds. 

ii. Secured Staff Shelter

1. ICE/ERO conducts transportation to ORR secure and staff-secure

facilities. 

b. Timeframe/Deadline: 

i. Movements are conducted expeditiously to ensure there are no TVPRA 

violations. 

4. Custody Transfer

 

9 For more information, see ICE’s Juvenile and Family Residential Management Unit Field Office Juvenile 

Coordinator Handbook. 

PSI-157
12 

a. Responsible Agency: 

i. DHS transfers physical custody of the UAC to ORR. ORR assumes custody 

upon physical arrival of UAC at the designated care provider facility. See 

ORR Policy Guide, section 1.1, 1.2. 

b. Timeframe/Deadline: 

i. Except in the case of exceptional circumstances, DHS shall transfer the 

custody of such child to ORR no later than 72 hours after the UAC 

determination is made. 

c. Operational Requirements: 

i. The custody-transfer packet includes (see UAC MAP, section 1.3.4; MOA 

ORR-ICE-CBP, section IV(A)(2)): 

1. Copies of all identification documents; 

2. Form I-213, Record of Deportable/Inadmissible Alien; 

3. Form I-216, Record of Person and Property Transferred; 

4. Form I-217, Information for Travel Document or Passport;

5. Form I-862, Notice to Appear; 

6. Form I-770, Notice of Rights and Request for Disposition for Minors; 

7. Form I-200, Warrant for Arrest of Alien;

8. CBP Form 93, UAC Screening Addendum (trafficking information); 

9. Copies of any publicly available federal, state, or local criminal records in 

possession of the apprehending DHS Component (ICE or CBP) at the time 

of transfer describing any gang, immigration, criminal or other activity 

that may affect placement; 

10. Orantes notification as applicable; 

11. DIHS-794, In-Processing Health Screening Form; 

12. Any medical paperwork (e.g., hospital records); and 

13. List of medications. 

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ii. Although it is standard operating procedure for ICE/ERO to deliver custody 

transfer packets in the manner prescribed in this section, an ORR care 

provider cannot refuse to accept a UAC because of missing DHS-issued 

paperwork, without ORR’s permission. See ORR Policy Guide, section 1.3.3. 

iii. At the time of placement designation, DHS will be responsible for providing 

ORR the information referred to in the JCO. 

iv. ORR considers the following factors when making a placement determination: 

See ORR Policy Guide, section 1.2.1 

1. Trafficking or other safety concerns; 

2. Any special needs or issues requiring specialized services (for example, a 

child with language needs, mental health or medical concerns, or a youth 

who is pregnant or parenting); 

3. Possibility of heightened vulnerability to sexual abuse due to prior sexual 

victimization; 

4. Prior sexual abusiveness; 

5. Identification as lesbian, gay, bisexual, transgender, questioning or 

intersex, or gender non-conforming appearance or manner; 

6. Location of potential sponsor and family sponsorship options; 

7. Siblings or parents in ORR custody; 

8. Immigration issues (for example, legal representation needs, immigration 

proceedings); 

9. Behavior; 

10. Criminal or juvenile background; 

11. Danger to self; 

12. Danger to the community; 

13. Escape risk; 

14. Age;

15. Gender;

PSI-159
14 

16. Expected length of stay in ORR custody; and

17. Location where the child or youth was apprehended. 

5. Transfers to Long Term Foster Care 

a. Responsible Agency: 

i. ORR is responsible for Long Term Foster Care (LTFC) placement 

determinations for UAC. Non-ORR LTFC care providers in conjunction with 

the ORR/FFS explore viable placement options dependent on the UAC’s 

individual needs and best interest. See ORR Policy Guide, sections 1.2.6, 

1.4.3, 1.4.4. 

b. Timeframe/Deadline: 

i. After determining appropriateness of placement into LTFC, the ORR care 

provider case manager files a transfer request in consultation with the 

ORR/FFS. The proposed LTFC provider has ten (10) business days to review 

the request and supporting documentation and make a request for additional 

information from the UAC’s current care provider case manager. See UAC 

MAP, section 1.4.4. 

ii. Requests for additional information by the LTFC provider must be responded 

to within three (3) business days by the UAC’s care provider case manager. 

iii. The LTFC provider completes and submits a LTFC Placement Memo within 

ten (10) business days of the original transfer request, and submits the 

completed memo to the ORR/FFS. The ORR/FFS reviews and communicates 

the transfer decision (generally within three (3) business days of receiving the 

completed memo) to the UAC’s receiving/sending Case Coordinators, the 

UAC’s care provider case manager, the LTFC provider case manager and the 

DHS/ICE FOJC. See UAC MAP, section 1.4.4. 

c. Operational Requirements:

i. LTFC Placement Memo.

ii. Transfer Request.

iii. Change of Address/Change of Venue, as applicable.

iv. Logistics for transfer are coordinated between the sending care provider and 

the LTFC provider. 

B. DISCHARGE FROM ORR CUSTODY 

PSI-160
15 

1. Discharge Notification 

a. Responsible Agency: 

i. Release to Sponsor: ORR will notify ICE/ERO that a UAC is being prepared 

for release, and again when a UAC is released. See ORR Policy Guide, 

section 2.8.2; 2.8.3; UAC MAP, section 2.8. 

ii. Age-Outs: ORR is responsible for notifying ICE/ERO that a UAC is turning 

18 years old or that an age-determination has found the alien to be more than 

18 years old. See ORR Policy Guide, section 1.6; UAC MAP, section 1.6. 

iii. Voluntary Departure/Final Orders of Removal: ICE/ERO will notify ORR 

that a UAC in ORR’s custody was granted Voluntary Departure or was issued 

a Final Order of Removal.10 

b. Timeframe/Deadline

i. Release to Sponsor: The ORR care provider will notify ICE/ERO at least 24 

hours prior to the UAC’s physical release from ORR custody. The ORR care 

provider will notify ICE/ERO again within 24 hours of the UAC’s physical 

release. See ORR Policy Guide, section 2.8.2; 2.8.3; UAC MAP section 2.8. 

ii. Age-Outs: The ORR care provider and/or ORR/Federal Field Specialists 

(FFS) will notify ICE/ERO that the child will be turning 18 years old 

approximately 30 days before the UAC’s 18th birthday, and again 24-hours 

prior to the UAC’s 18th birthday. In the case of an age redetermination, ORR 

will notify ICE/ERO within three (3) calendar days from when ORR 

reasonably suspects that an individual in ORR’s custody is over 18 years old. 

See ORR Policy Guide, section 1.6; UAC MAP, section 1.6. 

iii. Voluntary Departure/Final Orders of Removal: ICE/ERO will notify ORR 

and the ORR care provider within three (3) business days of a grant of 

Voluntary Departure or the entry of a Final Order of Removal issued for a 

UAC in ORR custody. 

 

c. Requirements: 

i. Release to Sponsor: The ORR care provider provides a Discharge 

Notification to ICE/ERO with the UAC’s biographical information, the name 

of the UAC’s sponsor, the relationship to the sponsor, and the sponsor’s 

address. See ORR Policy Guide, section 2.8.3; UAC MAP, section 2.8. 

 

10 It is likely that a UAC’s attorney will notify ORR and the child ORR care provider prior to the ICE/ERO

notification of the immigration case outcome. However, ICE, as the prosecuting office, will be in the best position 

to notify ORR in all cases. 

PSI-161
16 

ii. Age-Outs: The ORR care provider and/or ORR/FFS will notify the ICE/ERO

ICE/ERO Juvenile Coordinator via email of the pending Age-Out. See ORR 

Policy Guide, section 1.6; UAC MAP, section 1.6. 

iii. Voluntary Departure/Final Orders of Removal: ICE/ERO transmits copies of 

the Immigration Judge’s order to the ORR care provider and ORR/FFS. 

ICE/ERO is responsible for obtaining necessary travel documents from the 

consulate of the UAC’s country of origin. 

2. Preparation 

a. Responsible Agency: 

i. Release to Sponsor: ORR will prepare the UAC for transport to a sponsor, 

with assistance from the sponsor as required. ORR, working with the ORR 

care provider, will follow all ORR policies regarding adult escorts to ensure 

UAC arrive safely to a point of release with the UAC’s sponsor. See ORR 

Policy Guide, section 2.8.2. 

ii. Age-Outs: 

1. Post-18/Release on Own Recognizance (ROR): Attorney and/or ORR/FFS 

must work with ICE/ERO Field Office Juvenile Coordinator (FOJC) to 

determine whether a UAC approaching 18 years old may be released on an 

Order of Recognizance (OREC) thereafter. Once the DHS/ICE FOJC has 

made a decision they will notify the UAC’s ORR care provider, attorney, 

and the ORR/FFS that the UAC may be directly released from the ORR. 

See ORR Policy Guide, section 3.3.2. 

2. Age Determinations/Transfers to DHS custody: For cases where an alien 

was determined through joint HHS-DHS policies to be over 18 years old 

or for UAC approaching 18 who are not ROR cases, the ORR care 

provider will notify the individual and attorney or ORR funded local-legal 

service provider that the individual is being prepared for transfer to 

ICE/ERO. See ORR Policy Guide, section 1.6; UAC MAP, section 1.6; 

TVPRA, 8 U.S.C. § 1232(c)(2)(B).

i. Voluntary Departure/Final Orders of Removal: 

1. The ORR care provider requests that the ORR funded local-legal service 

provider screen the UAC for immigration relief if the UAC has no legal 

relief options and no available sponsor and/or the UAC requests an 

expedited hearing or other hearing before an immigration judge. See ORR 

Program Guidance, Notice to Appear Changes (July 3, 2014). 

PSI-162
17 

2. ICE/ERO has responsibility to notify the local consulate of a pending 

Voluntary Departure or Final Order of Removal in order to obtain travel 

documents. DHS and ORR will closely coordinate preparations between 

each respective agency, the UAC, and the consulate, as required. 

b. Timeframe/Deadline: 

i. Release to Sponsor: ORR care providers are expected to physically release 

the UAC within three (3) calendar days of an ORR/FFS approving the release, 

absent exigent circumstances. See ORR Policy Guide, section 2.8.2. 

ii. Age-Outs: 

1. Post-18/ROR: ORR care provider submits a Post-18 Plan to ICE/ERO

FOJC two (2) weeks prior to UAC’s 18th birthday, if applicable. See ORR 

Policy Guide, section 3.3.2. 

2. Age Determinations: ORR provides the results of an age redetermination, including relevant evidence to ICE/ERO FOJC within three 

(3) business days of receiving results. ORR and ORR care provider will 

follow existing policies to prepare UAC for transfer to ICE/ERO within 30 

days See ORR Policy Guide, section 1.6; UAC MAP, section 1.6. 

3. Voluntary Departure/Final Orders of Removal: Timing for scheduling of 

expedited hearings is dependent on local immigration court rules, and 

current joint-EOIR, DHS, and ORR procedures. 

c. Requirements: 

i. Release to Sponsor: ORR care providers ensure UAC is prepared for travel; an 

escort is arranged, if applicable; DHS has been notified of the pending release; 

and, the sponsor and UAC’s family have received notification of the pending 

release. See ORR Policy Guide, section 2.8.2; UAC MAP, section 2.8. 

ii. Age-Outs: 

1. Post-18/ROR: ORR care provider submits the Post-18 Plan to the ORR 

and the ICE/ERO FOJC for comment. UAC MAP section 3 - PENDING

2. Age Determinations: ORR provides the results of an age redetermination, including relevant evidence to ICE/ERO FOJC within 3 

business days of receiving results. See ORR Policy Guide, section 1.6; 

UAC MAP, section 1.6. 

PSI-163
18 

3. Voluntary Departure/Final Orders of Removal: DHS provides notice to 

consulates. DHS is responsible for obtaining travel documents from 

consulate. 

3. Logistics 

b. Responsible Agency: 

i. Release to Sponsor: ORR coordinates transportation and logistics directly 

with sponsor according to ORR’s policies and procedures. See ORR Policy 

Guide, sections 2.8.2; 2.8.3; UAC MAP, section 2.8. 

ii. Age-Outs: 

1. Post-18/ROR: Logistics for release are contained in the individual Post18 Plan, agreed to in advance of the UAC turning 18 years old. UAC 

MAP section 3 - PENDING. 

2. Age Determinations: If an age re-determination indicates the UAC is over 

age 18, ORR will coordinate with the ICE/ERO FOJC to pick-up the alien 

for transfer into DHS custody, or other plans as requested. See ORR 

Policy Guide, section 1.6; UAC MAP section 1.6. 

3. All other cases: The ICE/ERO FOJC coordinates transportation for the 

UAC with the ORR care provider. Transport will occur on the day the 

alien turns 18 years old. See UAC MAP, section 1.6. 

iii. Voluntary Departure/Final Orders of Removal: 

1. Upon request from a consulate and approval from ORR, the ORR care 

provider shares relevant contact and background information on a UAC’s 

family in their country of origin. ORR Policy Guide, sections 5.4.6, 5.4.7. 

2. Once the consulate informs DHS that travel documents have been 

approved and the UAC’s family is contacted in the country of origin, or 

the consulate in the absence of known family, DHS makes transportation 

arrangements for the UAC’s repatriation to his or her country of origin. 

DHS informs the ORR care provider of the repatriation and coordinates 

with the provider the date and time ICE/ERO will arrive at the facility to 

transport the UAC for repatriation. 

c. Timeframe/Deadline: 

i. Release to Sponsor: The ORR care providers are expected to physically 

release UAC within three (3) calendar days of an ORR/FFS approving the 

release, absent exigent circumstances. See ORR Policy Guide, section 2.8.2; 

UAC MAP, section 2.8. 

PSI-164
19 

ii. Age-Outs: Logistics for age out cases should be completed at least three (3) 

calendar days prior to the UAC turning 18 years old, but in no event less than 

24-hours prior to the UAC’s 18th birthday. UAC MAP, section 1.6.2. 

iii. Voluntary Departure/Final Orders of Removal: Repatriation of UAC will 

occur between 5 to 15 days of receiving travel documents from the consulate, 

or as dictated by the terms of the travel document issued. 

d. Requirements: 

i. Release to Sponsor: Requirements follow ORR’s general policies for release 

to a sponsor which are found in the ORR Policy Guide, Section 2. ORR

provides a copy of the appropriate Discharge Notification to the local 

ICE/ERO FOJC and to the Immigration Court with jurisdiction over the 

UAC’s case. The discharge notification form should include: 

1. Date of Discharge

2. UAC Name

3. UAC A#

4. UAC Date of Birth

5. UAC Country of Birth 

6. Sponsor’s Name 

7. Relationship to Sponsor 

8. Sponsor’s Address (verify the validity of the address given by using the 

U.S. Postal Service webpage) 

9. Sponsor’s Telephone Number 

ii. Age-Outs: 

1. Post-18/ROR: Post-18 Plan; Birth certificate, copy of ICE/ERO email 

confirming ROR. UAC MAP section 3 – PENDING. 

2. Age Determinations: Copy of documents used to verify age, including but 

not limited to (see ORR Policy Guide, section 1.6.2): 

i) Official government-issued documents, including birth certificates. If 

the UAC in question is not in possession of original documentation, or 

if the authenticity of the original documentation is in question, 

PSI-165
20 

government officials of the UAC’s home country must be consulted in 

order to verify the validity of the documentation, in accordance with 

applicable privacy rights (e.g., protection of asylum seekers); 

ii) Other reliable records (e.g., baptismal certificates, school records, 

medical records) that indicate the UAC’s date of birth;

iii) Statements provided by the UAC regarding his or her age or birth date. 

Note: A UAC’s uncorroborated declaration regarding age is not used 

as the sole basis for an age determination; 

iv) Statements from the UAC’s parent(s) or legal guardian(s), if such 

persons can be identified and contacted;

v) Statements from other persons; 

vi) Information from another government agencies (Federal, State, local 

or foreign); 

vii)State/local arrest records;

viii) Child welfare agency records; 

ix) Medical records, including copies of documents used to make a 

medical age assessment. In accordance with 8 U.S.C. §1232(b)(4), 

neither DHS nor HHS relies exclusively on radiographs to determine 

age; and

3. All other cases: ICE/ERO provides order confirming UAC to be 

remanded into DHS custody. 

iii. Voluntary Departure/Final Orders of Removal: ICE/ERO FOJC notifies ORR 

and the ORR care provider of the imminent transfer of custody, and to prepare 

the UAC for travel. ORR care provider will ensure all needed legal 

documents are maintained and collected for copy into the UAC case file. 

1. If an Immigration Judge orders a UAC removed from the United States or 

grants voluntary departure, DHS arranges for the UAC’s safe return to his 

or her country of origin or last habitual residence according to applicable

policies and procedures. 

2. DHS recognizes that UAC are a particularly vulnerable population and 

must be repatriated with special consideration and care. To safeguard the 

PSI-166
21 

welfare of all UAC, DHS Components follow established policies11

whenever repatriating UAC through the following actions: 

i) Repatriate during only daylight hours; 

ii) Ensure receiving government official or designee signs for custody to 

record the transfer; 

iii) Repatriate the UAC at a designated port of entry; 

iv) Provide the UAC an opportunity to communicate with a consular 

official prior to departure; and 

v) Preserve the unity of families during repatriation (for repatriation to 

Mexico, doubts of kinship should be coordinated with the Consulate of 

Mexico to safeguard the UAC’s well-being). 

3. The majority of UAC repatriations conducted by ICE/ERO occur via 

commercial air. ICE/ERO provides two escort officers for each UAC. An 

additional officer is added for each group that exceeds five UACs. 

Instances where both male and female children are being transported 

require an escorting officer of each sex. 

3. UAC PROCESSING

DHS and HHS collaborate and coordinate the processing of all UAC. In so doing, the agencies 

comply with 6 U.S.C. § 279, the TVPRA, other legal requirements, and all agency internal 

policies, procedures, and guidance to ensure that UAC are treated with dignity and respect and 

with special concern for their vulnerability as UAC. All UAC are processed expeditiously and 

are generally given priority over other aliens in custody in order to move them swiftly to 

HHS/ORR placement.

Immediately after a minor is apprehended, the apprehending DHS component determines age, 

identity, accompanied status, and immigration status. As age and identity are determined, the 

apprehending DHS component creates an Alien File (either a permanent “A-file” or a temporary 

“T-file”), according to departmental guidelines prior to transfer of the UAC to ORR. The A-file 

or T-file must generally contain, at a minimum, the original Form I-862, with signature and 

service on the alien (if the UAC is above 14 years of age), plus three copies, and any 

documentary evidence. If the UAC is below 14 years of age, then the certificate of service on 

the NTA will be served upon HHS/ORR when the custody of the UAC is transferred. The 

ICE/ERO FOJC provides instructions to the apprehending agency for delivery of the A-file or Tfile to ICE/ERO.

 

11 Note that current DHS policies regarding repatriation of UAC from non-contiguous countries go beyond what is 

statutorily required for repatriation of UAC from contiguous countries 8 U.S.C. 1232(a)(2)(C). 

PSI-167
22 

A. IMMIGRATION PROCESSING

1. Issuing NTAs to UAC 

a. Responsible Agency: 

i. Upon encountering a potential UAC, the relevant agency must identify the 

age, identity, and immigration status of the minor. If the alien is determined 

to be a UAC, and the UAC is determined to be 14 years of age or older, the 

apprehending agency may take fingerprints of the UAC and initiate a search in 

the IDENT system to verify identity and determine if there have been any 

prior DHS apprehensions. The officer or agent will also initiate a criminal 

record check to establish if the UAC has had any previous criminal history. 

ii. NTAs can only be signed by UAC 14 years of age and older who are 

physically and mentally capable of understanding and signing the document, 

and must be left blank for UAC under 14 years of age. 

iii. The options listed in the NTA are permissible for the service to a conservator. 

FOJCs should consult with their local OCC on best practices, as this varies by 

ORR. It is best practice for UAC under 14 years of age to have the NTA 

personally served on the conservator. In most cases, the conservator will be 

an ORR care provider facility employee. This best practice puts the 

responsibility on ICE/ERO FOJC to visit the ORR facility to personally serve 

the conservator, ensuring that the conservator legibly signs the NTA and 

prints his or her name and title beneath the signature. This requirement will 

ensure that ICE/ERO can demonstrate proper service of the NTA to the 

immigration court.

b. Timeframe/Deadline: 

i. UAC who are 14 years of age and older will generally be issued an NTA prior 

to transfer to the custody of ORR. 

ii. When CBP issues an NTA to a UAC under 14 years of age or who is 

otherwise unable to be served personally, it may be necessary to delay service 

of the NTA until custody can be transferred to ORR. ORR should sign the 

NTA and other legal documentation and receive all copies of legal 

documentation on behalf of the UAC. 

c. Operational Requirements: 

i. Refer to JCO Section II(A)(4)(c)(i) for relevant documents provided in the 

DHS Transfer Packet. See also UAC MAP, section 1.3.4; 2018? MOA ORRICE-CBP, section IV(A)(2). 

PSI-168
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2. Filing NTAs 

a. Responsible Agency: 

i. CBP initiates the vast majority of removal proceedings for UAC. 

ii. ICE/ERO encounters UAC during interior enforcement operations, 

initiates removal proceedings, maintains and performs general UAC case 

management, and resolves any issues with the A-File and NTA to ensure 

proper service and to file the NTA with the DOJ’s EOIR.

b. Timeframe/Deadline: 

i. The NTA is filed (i) 30 days after the UAC’s apprehension (a UAC in an 

ORR care provider facility); (ii) upon notice by ORR to file the NTA 

while the UAC is in an ORR care provider facility; or (iii) upon notice 

provided in the ORR Discharge Notification form that a UAC was

released to a sponsor (in the jurisdiction of the UAC located at sponsor’s 

address). See ORR Program Guidance, Notice to Appear Changes (July 

3, 2014). 

c. Operational Requirements: 

i. ICE/ERO requires a properly served NTA to file with EOIR in order to 

initiate immigration proceedings. 

3. Information Requests between HHS and DHS 

a. Responsible Agency: 

i. ORR: 

1. Case File Information: ORR will process DHS requests for information 

on all UAC in ORR custody and for information contained in UAC case 

files, as applicable. See Requests for UAC Case File Information 

(September 23, 2013). 

2. Unauthorized Absence notices: In the event that a UAC absconds from 

ORR custody, ORR will notify the local ICE/ERO FOJC with jurisdiction 

over the case. ORR will immediately notify local law enforcement 

agencies. See ORR Policy Guide, section 5.8.1. 

PSI-169
24 

3. Death of a UAC in ORR custody: ORR reports deaths of UAC in ORR 

custody to the ICE/ERO FOJC with jurisdiction over the case. See ORR 

Policy Guide, section 5.8.1. 

4. Arrest of a UAC in ORR custody: The ORR funded care provider 

contacts the DHS/ICE FOJC with jurisdiction over the case by telephone 

and provides notice by email. See MOA ORR-ICE-CBP, section 

IV(B)(1).

5. Alleged or suspected fraud, human smuggling, human trafficking, drug 

trafficking, weapons trafficking, or gang-related activity. ORR notifies 

the ICE Homeland Security Investigations Tip Line by email and, for 

human trafficking specifically (either by or of a UAC), ORR also emails 

the ICE Human Trafficking Help Desk. See MOA ORR-ICE-CBP, 

section IV(B)(1).

6. Violence by a UAC while in ORR care. ORR notifies the ICE/ERO FOJC 

of incidents of physical violence or assault by a UAC in its care, including 

incidents between a UAC and facility staff. SeeMOA ORR-ICE-CBP, 

section IV(B)(1).

7. Change in level of care. ORR provides notice by email to the ICE/ERO

FOJC of any step up/step down to or from secure care for the UAC. See 

MOA ORR-ICE-CBP, section IV(B)(1).

ii. DHS 

1. If ICE or CBP becomes aware of any criminal information (e.g., 

information regarding gang affiliation) that it did not have at the time of 

initial referral and transfer, ICE or CBP will notify ORR as expeditiously 

as practicable, and as a matter of general practice, within 48 hours after 

becoming aware of the information. This includes providing supporting 

documentation to aid in ORR’s consideration of whether transfer of the 

UAC may be necessary.

2. To the extent permitted by law, and consistent with policy, ICE or CBP 

will report to ORR the results of any investigations (including 

investigations commenced following ORR’s notification under Section 

IV(B)(1) of 2018 MOA ORR-ICE-CBP) they conduct that would be 

relevant to ORR’s determinations concerning UAC care and placement. 

Such information will be provided as expeditiously as possible, and 

ideally within 96 hours of such information becoming available. 

b. Timeframe/Deadline: 

i. ORR: 

PSI-170
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1. Case File Information: DHS requests for UAC case file information are 

triaged and responded to, as soon as possible, according to the nature of 

the request and any exigent circumstances regarding the request. See 

Requests for UAC Case File Information (September 23, 2013). 

2. While UAC are in ORR care, ORR will notify ICE or CBP of incidents 

identified in section (3)(a)(i)(1)-(8) as expeditiously as possible, but no 

later than 48 hours after discovery of the incident. See MOA ORR-ICECBP, section IV(B)(1).

c. Operational Requirements: 

i. ORR: 

1. Case File Information: Request for UAC case file information will follow 

ORR’s policies regarding the disclosure of confidential information to 

government agencies.12 Additionally, the requesting party must file an 

Authorization for Release of Records.

13 ORR may redact information as 

required to protect the privacy or confidentiality of non-subjects to the 

request. ORR does not typically share psychiatric or psychological 

records absent a court-issued subpoena for those records. See Requests 

for UAC Case File Information (September 23, 2013). 

2. ORR follows reporting requirements as outlined in the 2018 ORR-ICECBP MOA as described in (a)(i)(3) and (b)(i)(2) above. 

4. Change of Address/Change of Venue Notices 

a. Responsible Agency: 

i. ORR is responsible for the filing of applicable Change of Address (COA) and 

Change of Venue Notices (COV), for UAC transferring placement between 

ORR care provider facilities (including Long Term Foster Care providers). 

The UAC’s sponsor is responsible for COA/COV notices for the UAC once 

the UAC is released. See ORR Policy Guide, section 1.4.2; UAC MAP, 

section 1.4. 

b. Timeframe/Deadline: 

 

12 For more information on Requests for UAC Case File Information, please visit: 

https://www.acf.hhs.gov/orr/resource/requests-for-uac-case-file-information. 13 The Authorization for Release of Records, normally requires the consent of the UAC prior to release of their 

records in most instances. ORR has an exception to this requirement for other government agencies requesting 

UAC case files. ORR will examine the nature of the request, including the reasons for the requested information, 

and make a determination on a case-by-case basis on what information to release, if any, to DHS. Typically, a 

UAC’s health information is not disclosed, nor is a sponsor’s home study or post-release service information unless 

relevant to the DHS request.

PSI-171
26 

i. Transfers: The ORR care provider case manager at the referring ORR care 

provider completes copies of the immigration court COA/COV documents 

and the Notice of Transfer to the ICE Chief Counsel Change of 

Address/Change of Venue. UAC MAP, section 1.4. 

ii. Releases: The ORR care provider facility provides the sponsor with the local 

immigration court’s change of address/change of venue information, if the 

UAC’s NTA has already been filed with the immigration court. See UAC 

MAP, section 1.4. 

c. Operational Requirements: 

i. Transfers: Copies of COA/COV and the UAC’s NTA are sent to the receiving 

jurisdiction’s immigration court and emailed or mailed to the local ICE/ERO 

FOJC and the local ORR-funded Legal Service Provider (LSP). See UAC 

MAP, section 1.4. 

ii. Releases: Prior to the physical release to a sponsor, the ORR care provider 

case manager will ensure the UAC (as appropriate) and sponsor are educated 

on the COA/COV process and informed on how to file for and verify that 

COA and COV has been completed. See ORR Policy Guide, section 2.8.1; 

UAC MAP, section 2.8. 

B. INFLUX MATTERS

1. Placement Prioritization

a. Responsible Agency: 

ORR is responsible for the placement of all UAC into HHS custody. The ORR 

Division of Unaccompanied Children Operations (DUCO) Intake Team is 

responsible for the placement processing following ORR’s policies and 

procedures. The Intakes Team is also responsible for the prioritization of 

placement of UAC during an influx following ORR’s policies and procedures. 

See ORR Policy Guide, section 1.7. 

b. Timeframe/Deadline: 

ORR strives, even in times of exceptional circumstances such as an influx, to 

provide timely placement into ORR custody. See ORR Policy Guide, section 1.7. 

c. Requirements:

i. The following especially vulnerable UAC are prioritized for placement (see 

ORR Policy Guide, section 1.2.2): 

PSI-172
27 

1. UAC age 12 or under; 

2. UAC with identified health concerns – or mental, physical, or 

developmental disabilities;

3. Pregnant or parenting UAC; 

4. UAC who may require a specialized placement (UAC with delinquent 

activity); and

5. UAC nearing or exceeding 72 hours in DHS custody. 

ii. Initial criteria for placement into an Influx Care Facility, include UAC who 

meet the following criteria (See ORR Policy Guide, section 1.7.3): 

1. Between 13-17 years of age; 

2. Speak either English or Spanish; 

3. Have no known behavioral or medical issues, including contagious 

diseases or health issues requiring immediate evaluation or medical 

treatment by a healthcare provider; 

4. Have no known special needs (mental health or identified health 

concerns); 

5. Deemed not a danger to self or others; 

6. Have no criminal history (i.e., not charged with having committed a 

criminal offense); 

7. Have not been a perpetrator or victim of smuggling or trafficking 

activities;

8. Is not subject to a pending age determination; 

9. Not part of a sibling group with a sibling(s) age 12 years or younger; 

10. Not pregnant or parenting; 

11. Medically cleared and vaccinated as required by the Influx Care Facility 

(for instance, if the Influx Care Facility is on a Department of Defense 

site); 

12. Have completed the Medical Checklist for Influx Transfers; 

PSI-173
28 

13. Able to be discharged from ORR expeditiously; 

14. Not involved in an active State licensing, law enforcement, or PREA 

investigation; 

15. Not turning 18 years old within 30 days of the transfer; 

16. Not scheduled to be discharged in 3 days or less; 

17. Does not have a pending Home Study; and

18. Does not have a current set docket date in immigration court or 

State/family court (juvenile included), or a pending adjustment of legal 

status, or nor an attorney of record. 

2. Use of HHS Influx Care Facilities 

a. Responsible Agency: 

i. ORR is responsible for opening and operating HHS Influx Care Facilities. 

ORR uses existing grantees or contractor(s) to operate facilities and provide 

wrap around services. See ORR Policy Guide, section 1.7. 

ii. Other Federal Departments: Other federal departments may be land holders. 

HHS will enter into MOUs to obtain a licensing permit with the land holding 

federal department for use of the property. 

b. Timeframe/Deadline:

i. Time frames for use of HHS Influx Care Facilities are primarily determined 

by need and cost (whether referral numbers and overall capacity among 

ORR’s network of care providers) to justify continued use of these facilities. 

ii. If HHS has entered into MOUs with other land holding federal departments, 

the MOU will detail the timeframe in which HHS may operate, and will also 

include termination timeframes in the event HHS no longer requires use of the 

property. 

c. Requirements: Not applicable. 

3. Services at HHS Influx Care Facilities:

a. Responsible Agency: 

PSI-174
29 

ORR is responsible for all services at HHS Influx Care Facilities. DHS is 

responsible for transportation as identified in JCO Section 1 for initial placement 

into Influx Care Facilities. 

b. Timeframe/Deadline:

i. Admission requirement (within 4 hours) for Influx Care Facility (see ORR 

Policy Guide, section 1.7.4): 

1. Admit the UAC to the program in the ORR database; 

2. Offer the UAC a meal and/or snack;

3. Offer the UAC an opportunity to shower, provide lice treatment, and give 

clean clothing; and

4. Complete an inventory of the UAC’s belongings and DHS paperwork. 

ii. Admission requirements (within 24 hours) for Influx Care Facility (see ORR 

Policy Guide, section 1.7.4):

1. Provide the UAC with all documents from the Legal Resource Guide. 

2. Explain to the UAC the HHS Processing Centers (HPC): 

• Rules and responsibilities; 

• Grievance procedures; and 

• Sexual abuse reporting procedures. 

3. Complete the Initial Intakes Assessment in the ORR database.

4. Contact the UAC’s family (following safety protocols) to notify them of 

the UAC’s placement and determines if the UAC has a potential sponsor 

who resides in the United States.

5. Inform the UAC’s family about the application process for the Safe and 

Timely Release of an UAC to a sponsor. 

6. Inform the UAC’s parent/legal guardian and identified potential sponsor 

that the placement is temporary and that when the UAC is transferred to a 

final ORR placement, the parent/legal guardian and potential sponsor will 

be notified. 

iii. Medical Services: Influx Care Facilities must complete the initial medical 

examination within 48 hours. See ORR Policy Guide, section 1.7.5. 

PSI-175
30 

c. Requirements:

i. Influx Care Facilities must follow basic standards of care including (See ORR 

Policy Guide, section 1.7.6): 

1. Maintain facilities that are safe and sanitary;

2. Provide access to toilets, sinks, and showers; 

3. Provide drinking water and food; 

4. Maintain adequate temperature control and ventilation; 

5. Provide adequate supervision; 

6. Provide same gender supervision for any area where UAC regularly undress, 

including restrooms and showers;

7. Provide UAC with appropriate clothing and personal grooming items; 

8. Provide UAC a reasonable access to privacy, which includes the opportunity 

to wear his or her own clothes, as appropriate; retain a space for storage of 

personal belongings; talk privately on the phone, as appropriate; visit 

privately with guests, as appropriate; and receive and send uncensored mail 

unless there is a reasonable belief that the mail contains contraband; 

9. Separate UAC who are subsequently found to have past criminal/juvenile 

delinquency or gang affiliation history and/or who exhibit behavior that 

presents a danger to themselves or to other UAC; 

10. Adhere to a zero-tolerance policy towards sexual abuse and assault per 

ORR regulations and policy; 

11. Adhere to ORR policy and procedures on significant incident and sexual 

abuse reporting and follow-up; 

12. Allow reasonable access to legal services providers or UAC’s attorneys of 

record that have provided proper documentation, subject to time and place 

restrictions;

13. Provide for either an in-person Know Your Rights presentation by a legal 

service provider or video Know Your Rights presentation; 

14. Provide case management services for safe and timely release;

15. Follow ORR transport policies;

16. Allow access to religious services, if available;

PSI-176
31 

17. Provide emergency clinical services;

18. Comply with reporting requirements as specified by ORR in consultation 

with HPC and Influx Care Facility providers; 

19. Provide UAC an environment free from discrimination on the basis of 

gender, race, religion, national origin or sexual orientation; and 

20. Keep UAC free from any cruel, harsh, unnecessary, demeaning or 

humiliating punishment.

ii. To the extent practicable, non-State licensed HPCs and Influx Care Facilities 

are encouraged to provide the following services: 

1. Educational services; and

2. Daily Recreational/Leisure time that includes one hour of large muscle 

activity and one hour of structured leisure time activities.

PSI-177
32 

4. UAC CARE AND SERVICES

Medical clearance, including screening, evaluation, and treatment, is a major component of the 

care, movement, and release of UAC. UAC are typically in good health; however, some may 

have communicable diseases, disabilities, mental health issues, significant behavioral or mental

health issues, access and functional needs, or acute/chronic medical conditions. Likewise, many 

UAC come into Federal custody with experiences of trauma, including cases of victimization, 

sexual assault, and human trafficking. Some are pregnant. 

UAC care and services while in DHS and HHS custody are based upon the minimum standards 

of Exhibit 1 and Paragraph 12 of the Flores Settlement Agreement, as applicable.

A. SERVICE REQUIREMENTS 

1. Medical Evaluation in DHS Custody 

a. Responsible Agency: 

i. ICE/ERO conducts a pre-transport screening to evaluate UAC for febrile 

respiratory disease and visible signs of potential communicable diseases prior 

to transfer from CBP to an ORR shelter in accordance with the Pre-Transport 

Screening Protocol. UAC diagnosed with fever, cough, sore throat, or visible 

signs of potential communicable diseases will not be cleared for transfer via 

commercial flight. Febrile UAC, or those visually presenting with symptoms 

mentioned, will be re-submitted by ICE/ERO to HHS/ORR for re-designation 

to local ORR shelters.

ii. While in CBP custody, in accordance with the CBP National Standards on 

TEDS Policy, CBP Officers and Agents must be alert to medical symptoms 

such as coughing, fever, diarrhea, rashes or emaciation, in addition to obvious 

wounds, injuries, cuts, bruising or bleeding, heat related injury or illness, and 

dehydration. Any observed or reported injury or illness must be 

communicated, and appropriate medical care must be provided or sought in a 

timely manner. TEDS also requires CBP to be alert to physical, mental, or 

developmental disabilities that may require particular care or oversight. 

b. Timeframe/Deadline: 

i. During intake by CBP or ICE , UAC are screened for obvious diseases, injury, 

and/or disability and are referred for a medical evaluation, as needed. 

ii. UAC are screened by ICE/ERO prior to transfer to ORR for febrile respiratory 

disease and visible signs of potential communicable diseases. 

iii. Any UAC with a serious medical condition or complaint will be transported to 

a local healthcare facility for evaluation and treatment. If still in DHS

PSI-178
33 

custody, DHS personnel shall accompany and remain with the UAC until the 

completion of treatment and official medical clearance is provided. 

iv. If the UAC is hospitalized, appropriate supervisory notification shall occur. 

v. Transfer: Evaluation for Suitability to Air Transfer. When the UAC is 

transported to HHS custody, ICE contractors review the paperwork to 

determine that the necessary forms (either IHSC-795J or I-779) are included 

prior to intiating the transfer. 

c. Operational Requirements: 

i. Medical Clearance for Release by either a physician, or if the UAC went to a 

healthcare facility, with a medical professional in processing health screening. 

ii. Medical or Hospital Records. 

iii. Medications, if applicable.

2. Medical Emergencies in DHS Custody 

a. Responsible Agency: 

i. DHS shall respond immediately to observed or reported medical emergencies, 

and contact local emergency medical services when a UAC is determined to 

need urgent medical care.

ii. If the UAC is removed from the facility for medical treatment and he or she is

in DHS custody during transport, DHS personnel shall accompany and remain 

with the UAC until the completion of treatment and official medical clearance 

is provided. 

iii. If the UAC is hospitalized, appropriate supervisory notifications shall occur. 

b. Timeframe/Deadline: 

i. Within two hours of reportable events or as soon as practical, telephonic 

notification must be made to the ICE/ERO Deputy Assistant for Field 

Operations for certain significant incidents, including significant injury or 

death. For other medical incidents, such as admittance to a hospital for less 

serious events, telephonic notification is not required, but the incident must be 

reported through an Executive Summary and Significant Event Notification 

(SEN) application within 24 hours. ICE/ERO should notify ORR once the 

UAC is released from the hospital or emergency care facility.

PSI-179
34 

ii. While in CBP custody, CBP assumes the responsibility to provide medical 

care for all UAC. Once the UAC is cleared for travel by a competent medical

professional, CBP will request placement from ORR via the UAC Portal, to 

which all medically relevant information is relayed. 

c. Operational Requirements: 

i. First aid supplies and equipment are the responsibility of each facility. All 

facilities should have a written emergency medical response plan (access to 9-

1-1 and 9-1-1 responders to the facility), on which all employees should be 

educated. 

3. Flores minimum standards for HHS licensed facilities:

a. Responsible Agency: ORR is responsible for the minimum standards listed in the 

Flores settlement exhibit 1 for UAC placed in a licensed facility.14 

b. Timeframe/Deadline: Refer to requirements below for timeframes of minimum 

standards. 

c. Requirements (see Flores Settlement Agreement, Exhibit 1; ORR Policy Guide, 

section 3.3): 

i. Proper physical care and maintenance, including suitable living 

accommodations, food, appropriate clothing, and personal grooming items.

ii. Appropriate routine medical and dental care, family planning services, and 

emergency health care services. A complete medical examination (including 

screenings for infectious disease) will be conducted within 48 hours of 

admission, excluding weekends and holidays, unless the UAC was recently 

examined at another ORR care provider facility; and appropriate 

immunizations will be provided as will administration of prescribed 

medication and special diets, and appropriate mental health interventions 

when necessary, in accordance with recommendations of the U.S. Department 

of Health and Human Services/U.S. Public Health Service (PHS), Centers for 

Disease Control and Prevention (CDC).

iii. An individualized needs assessment, which includes the various initial intake 

forms, collection of essential data relating to the identification and history of 

the child and his or her family, identification of the UAC’s special needs 

including any specific problems which appear to require immediate 

intervention, an educational assessment and plan, an assessment of family 

 

14 A "licensed program" refers to any program, agency or organization that is licensed by an appropriate State 

agency to provide residential, group, or foster care services for dependent children, including a program operating 

group homes, foster homes, or facilities for special needs minors. As applied to ORR care providers, this includes, 

shelters, groups homes, staff secure facilities, transitional foster care, long term foster care providers.

PSI-180
35 

relationships and interaction with adults, peers and authority figures; a 

statement of religious preference and practice; an assessment of the UAC’s

personal goals, strengths and weaknesses; identifying information regarding 

immediate family members, other relatives, godparents or friends who may be 

residing in the United States and may be able to assist in connecting the child 

with family members.

iv. Educational services appropriate to the UAC’s level of development and 

communication skills in a structured classroom setting Monday-Friday, which 

concentrates primarily on the development of basic academic competencies 

and secondarily on English Language Training. The educational program 

shall include instruction and educational and other reading materials in such 

languages as needed. Basic academic areas should include Science, Social 

Studies, Math, Reading, Writing and Physical Education. The program must 

provide unaccompanied alien children with appropriate reading materials in 

languages other than English for use during leisure time.

v. Activities according to a recreation and leisure time plan that include daily 

outdoor activity, weather permitting, with at least one hour per day of large 

muscle activity and one hour per day of structured leisure time activities (that 

should not include time spent watching television). Activities should be 

increased to a total of three hours on days when school is not in session.

vi. At least one individual counseling session per week conducted by trained 

social work staff with the specific objective of reviewing the child’s progress, 

establishing new short-term objectives, and addressing both the 

developmental and crisis-related needs of each child.

vii. Group counseling sessions at least twice a week. Sessions are usually 

informal and take place with all UAC present. The sessions give new UAC

the opportunity to get acquainted with staff, other children, and the rules of 

the program. It is an open forum where everyone gets a chance to speak. 

Daily program management is discussed and decisions are made about 

recreational and other activities. The sessions allow staff and UAC to discuss 

whatever is on their minds and to resolve problems.

viii. Acculturation and adaptation services which include information regarding 

the development of social and inter-personal skills which contribute to those 

abilities necessary to live independently and responsibly.

ix. A comprehensive orientation regarding program intent, services, rules (written 

and verbal), expectations and the availability of legal assistance.

x. Whenever possible, access to religious services of the child’s choice.

PSI-181
36 

xi. Visitation and contact with family members (regardless of their immigration 

status), which is structured to encourage such visitation. The staff must 

respect the child’s privacy while reasonably preventing the unauthorized 

release of the unaccompanied alien child.

xii. A reasonable right to privacy, which includes the right to wear his or her own 

clothes when available, retain a private space in the residential facility, group 

or foster home for the storage of personal belongings, talk privately on the 

phone and visit privately with guests, as permitted by the house rules and 

regulations, receive and send uncensored mail unless there is a reasonable 

belief that the mail contains contraband.

xiii. Services designed to identify relatives in the United States as well as in 

foreign countries and assistance in obtaining legal guardianship when 

necessary for the release of the UAC.

xiv. Legal services information, including the availability of free legal assistance, 

the right to be represented by counsel at no expense to the government, the 

right to a removal hearing before an immigration judge, the right to apply for 

asylum or to request voluntary departure in lieu of deportation.15

B. ALLEGATIONS OF ABUSE IN DHS CUSTODY16

1. UAC Reported Abuse to DHS 

a. Responsible Agency: 

i. Agencies are responsible for making appropriate notification. The Joint 

Intake Center (JIC) serves as the central "clearinghouse" for receiving, 

processing, and tracking allegations of misconduct involving personnel and 

contractors employed by CBP and ICE. The JIC receives, reviews, and 

classifies all reported allegations. Allegations are concurrently reviewed by 

the DHS Office of Inspector General (OIG). If the DHS OIG declines to 

investigate the allegation, the JIC then proceeds with investigating the 

allegation. Allegations can also be handled as an inquiry by OPR trained fact 

finders assigned to program offices. 

ii. The DHS Office of Civil Rights and Civil Liberties (CRCL) has the statutory 

authority to investigate complaints from the public alleging violations of civil 

rights or civil liberties by DHS personnel, programs, or activities. This 

includes but is not limited to allegations of UAC abuse in DHS custody. 

 

15 This information is included in the Legal Resource Guide for Unaccompanied Alien Children, available at: 

https://www.acf.hhs.gov/orr/resource/unaccompanied-childrens-services#legal. 16 Under regulatory guidelines (see 6 CFR 115.71(b) and 6 CFR 115.171(b)) the investigation will be conducted by 

the “law enforcement agency within DHS”. For more information, please visit: 

https://www.dhs.gov/sites/default/files/publications/dhs-complaint-avenues-guide_10-03-12_0.pdf

PSI-182
37 

Pursuant to 6 U.S.C. 3435(a)(6) and internal DHS policies, CRCL also refers 

all complaints opened by CRCL to the DHS OIG, and may investigate any 

matters declined by the OIG. 

b. Timeframe/Deadline: 

i. DHS and each component within DHS responsible for the custody of the UAC 

immediately ensures the safety and security of an alleged victim and offers 

adequate medical and mental health care upon an allegation of abuse. 

1. For UAC in ICE custody, within (2) two hours of notification, the Field 

Office notifies the JIC telephonically and the local ORR Field Office of 

the alleged neglect, abuse, and/or assault. Within 24 hours, the Field 

Office notifies the JIC in writing via the ICE Significant Event 

Notification Database. The Field Office also reports the allegation to the 

designated state or local services agency under applicable mandatory 

reporting law. Upon transfer out of ICE custody, the Field Office ensures 

that the receiving facility is informed of the incident and the alleged 

victim’s potential need for medical/mental healthcare and/or victim 

services. 

2. For UAC in CBP custody, upon learning of an allegation that a UAC was 

sexually abused and/or assaulted in a CBP holding facility, the first law 

enforcement staff member to respond to the report, or his or her 

supervisor, shall as promptly as possible report the incident to the JIC, the 

Commissioner’s Situation Room, and to the designated state or local 

services agency under applicable mandatory reporting laws. Upon transfer 

out of CBP custody, the Station or Port of Entry ensures that the receiving 

facility or agency is informed of the incident and the alleged victim’s 

potential need for medical or social services. CBP will also comply with 

all policies governing the investigation and response to allegations of 

sexual abuse and assault. 

c. Operational Requirements: 

i. Any employee who has information pertaining to or otherwise suspects a child 

is being neglected or abused, or has knowledge of the alleged neglect, abuse, 

and/or assault will immediately notify the supervisor and communicate the 

following information: 

• The location of the incident. 

• Any other pertinent information about the abuse or information 

concerning the child that could assist in the investigation.

PSI-183
38 

• The employee will provide the name, age, sex, nationality, and A-number 

of the child being neglected or abused, along with any other pertinent 

information such as other children involved, description of injuries, and 

adult guardian information. 

ii. The person who directly witnessed or is advised by another that a child was or

is being neglected or abused will immediately call the respective State’s 

Department of Family Protective Services’ Child Abuse Hot-Line, but no later 

than (1) one hour following the incident. 

iii. Upon receiving initial notification of the alleged neglect, abuse, and/or 

assault, the supervisor will immediately alert the HSA and/or designee, and 

the Duty Program Director. The Duty Program Director will then notify the 

relevant component headquarters office(s). 

2. UAC Reported Abuse to HHS

a. Responsible Agency: 

i. ORR documents allegations of abuse that are reported to have occurred while 

in DHS custody in Significant Incident Reports (SIRs). ORR provides notice, 

including the SIR itself, to DHS as directed in ORR policy. See ORR Policy 

Guide, section 5.8.4; MOA ORR-ICE-CBP, section IV(B)(1).

ii. ORR documents allegations of abuse that occurred in ORR custody in SIRs. 

See ORR Policy Guide, section 5.8. 

b. Timeframe/Deadline: 

i. Allegations of abuse in DHS custody reported while in ORR custody: 

1. If a UAC makes an allegation of sexual or non-sexual abuse that occurred 

while he or she was in the custody of DHS, the ORR care provider must 

report the incident to DHS by emailing a copy of the SIR to DHS CRCL 

no later than (4) four hours after learning about the allegation. See ORR 

Policy Guide, section 5.8.4. 

ii. Allegations of abuse in ORR custody reported while in ORR custody: 

1. If a UAC makes an allegation of abuse that occurs in ORR custody, the 

ORR care provider reports the incident to ORR officials no later than (4) 

four hours after learning of the allegation. The ORR care provider reports 

appropriate significant incidents to CPS, the state licensing agency, and/or 

local law enforcement in accordance with mandatory reporting laws, state 

licensing requirements, federal laws and regulations, and ORR policies 

and procedures. See ORR Policy Guide, section 5.8.2. 

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2. The ORR care provider must report immediately but no later than (4) four

hours after obtaining any of the following: knowledge, suspicion, or 

information regarding an alleged or confirmed incident of sexual abuse, 

sexual harassment, or inappropriate sexual behavior; retaliation; or staff 

neglect/violation of responsibilities that occurs in ORR care via the Sexual 

Abuse Significant Incident Report (SA/SIR). For comprehensive 

information for reporting CPS, the state licensing agency, and/or local law 

enforcement, and in some cases to the FBI and HHS/OIG, refer to ORR 

policy. ORR Policy Guide, sections 4.10.2, 5.8.3. 

c. Operational Requirements: 

i. Allegations of abuse in DHS custody made while in ORR custody: 

1. SIR with allegation of abuse. 

2. Allegations of abuse while in DHS custody should be reported to CRCL 

and the JIC. 

3. Allegations of abuse are to be reported using one of the following 

methods:

i) Call the toll-free JIC Hotline at 1-877-2INTAKE or send a fax to 

(202) 344-3390; 

ii) Send an e-mail message to Joint.Intake@dhs.gov; 

iii) Call the OIG at 1-800-323-8603; 

iv) Access the online DHS OIG Complaint/Allegation Form at 

http://www.oig.dhs.gov/hotline/hotline.php; or 

v) Write to DHS OIG:

 DHS Office of Inspector General/MAIL STOP 0305 

 Attn: Office of Investigations - Hotline

 245 Murray Lane SW

 Washington, DC 20528-0305 

ii. Allegations of abuse in ORR custody made while in ORR custody. Follow 

ORR reporting policies. See ORR Policy Guide, sections 4.10.2; 5.8.1-

5.8.2. 

C. NOTIFICATIONS AND ACCESS

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1. Notification and Approved Contacts in DHS Custody 

a. Responsible Agency: 

i. CBP or ICE (i.e. the apprehending agency). 

b. Timeframe/Deadline: 

i. UAC are advised of their rights during case processing through the provision 

of Form I-770. This process involves informing the UAC that he or she may 

have access to a telephone to call the UAC’s mother/father/any other adult 

relative/adult friend. UAC are advised of their right to communicate with a 

lawyer and are provided a list of free and low cost legal services. UAC are 

also advised of their right to a hearing before an immigration judge. UAC 

will be offered a phone call upon apprehension and may also decline to make 

any calls.

c. Operational Requirements: 

i. Form I-770, Notice of Rights and Disposition for Minor, if the UAC is 

younger than 14 years of age or unable to understand the notice, the form 

must be read and explained in a language and manner the UAC understands. 

ii. Attorney-client and consulate visits/interviews are permitted, where 

applicable. 

2. Notification and Contact of UAC Family in HHS Custody 

a. Responsible Agency: 

i. ORR is responsible for the notification and contact of a UAC’s family and 

other stakeholders while the UAC is in HHS custody. ORR care provider 

Case Managers make notifications and contacts, after assessing the UAC’s 

safety. See ORR Policy Guide, sections 2.2.1, 2.3.2. 

b. Timeframe/Deadline: 

i. Within 24 hours of a UAC’s admission into ORR custody the Initial Intakes 

Assessment is completed which includes questions to identify UAC family 

members. The care provider Case Manager will determine if it is safe for the 

UAC to contact family members following relevant policy and procedures.

See ORR Policy Guide, section 3.2.1. 

ii. Within 5 days of a UAC’s admission into ORR custody the UAC Assessment

is administered. The UAC Assessment includes a section that includes family 

information. Any additional information later gathered in family contacts can 

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be included on a subsequent UAC Case Review. See ORR Policy Guide, 

section 3.3.2. 

c. Operational Requirements: 

i. Identification of familial contacts is obtained in the Initial Intakes Assessment

and/or UAC Assessment/UAC Case Review. See ORR Policy Guide, sections 

3.2.1; 3.2.2. 

ii. ORR care providers follow internal program protocols for guaranteeing safe 

contacts for the UAC to communicate with family. 

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5. CONCLUSION

Cooperation between DHS and HHS regarding the transport, processing, placement, care, and 

discharge of UAC is essential. Both departments take their roles seriously and work closely with 

interagency and foreign counterparts on a daily basis to ensure the humane treatment of UAC 

while simultaneously enforcing federal laws. 

The JCO will be made available to all applicable staff within each department, as appropriate. 

Updates, amendments, and expansions will occur as needed with agreement from both 

departments. Suggestions for changes and additions are to be referred to each department’s 

respective chain of command for consideration; however, all additions or alterations must be 

submitted to and approved by headquarters-level policy and counsel offices. 

Nothing in this document shall be construed to impair or otherwise affect the authority granted 

by law to an executive department or agency and to the extent this JCO contradicts any existing 

statute or regulation, the conflict should be resolved in favor of the statute or regulation. 

This document is not intended to, and does not, create any right or benefit, substantive or 

procedural, enforceable at law or in equity by any party against the United States, its 

departments, agencies, or entities, its officers, employees, or agents, or any other person. 

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