Unaccompanied Children: HHS Can Improve Monitoring of Their Care
Published: 2016-02-23T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: ORR is responsible for coordinating and implementing the care and placement of unaccompanied children. The number of children placed in ORR's care rose from nearly 6,600 in fiscal year 2011 to nearly 57,500 in fiscal year 2014. GAO was asked to review how ORR managed their care.
This testimony is based on GAO’s February 2016 report and addresses (1) ORR's response to the increase in unaccompanied children, (2) how ORR cares for children in its custody and monitors their care, (3) how ORR identifies and screens sponsors for children, and (4) what is known about services, challenges, and the status of removal proceedings for children after they leave ORR custody.
For its February 2016 report, GAO reviewed relevant federal laws and regulations, ORR policies, and ORR and Executive Office for Immigration Review data. GAO also visited nine ORR grantee facilities in three states selected to vary in the type of care provided, shelter size, and location, and conducted a random, non-generalizable case file review of 27 case files of children released from these facilities. GAO interviewed agency officials and community stakeholders in six counties that received unaccompanied children, representing diversity in geographic location, size, and demographics.
section_title: What GAO Found
paragraphs: In fiscal year 2014, nearly 57,500 children traveling without their parents or guardians (referred to as unaccompanied children) were apprehended and transferred to the care of the Department of Health and Human Services' Office of Refugee Resettlement (ORR). Most of these children were from Central America. GAO found that ORR was initially unprepared to care for that many children; however, the agency increased its bed capacity. Given the unprecedented demand for capacity in 2014, ORR developed a plan to help prepare it to meet fiscal year 2015 needs. The number of children needing ORR's care declined significantly through most of fiscal year 2015, but began increasing again toward the end of the summer. Given the inherent uncertainties associated with planning for capacity needs, ORR's lack of a process for annually updating and documenting its plan inhibits its ability to balance preparations for anticipated needs while minimizing excess capacity.
ORR relies on grantees to provide care for unaccompanied children, including housing and educational, medical, and therapeutic services. GAO's review of a sample of children's case files found that they often did not contain required documents, making it difficult to verify that all required services were provided. ORR revised its on-site monitoring program in 2014 to ensure better coverage of grantees. However, ORR was not able to complete all the visits it planned for fiscal years 2014 and 2015, citing lack of resources. By not monitoring its grantees consistently, ORR may not be able to identify areas where children's care is not provided in accordance with ORR policies and the agreements with grantees.
ORR grantees conduct various background checks on potential sponsors prior to releasing children to them. These potential sponsors are identified and screened by the grantees as part of their responsibilities for the unaccompanied children in their care. The extent of the checks conducted depends on the relationship of the sponsor to the child. Between January 2014 and April 2015, ORR released nearly 52,000 children from El Salvador, Guatemala, or Honduras to sponsors. In nearly 90 percent of these cases, the sponsors were a parent or other close relative already residing in the United States. Sponsors do not need to have legal U.S. residency status.
There is limited information available on post-release services provided to children after they leave ORR care. In part, this is because ORR is only required to provide services to a small percentage of children, such as those who were victims of trafficking. In May 2015, ORR established a National Call Center to assist children who may be facing placement disruptions, making post-release services available to some of them. Also, in August 2015, ORR began requiring well-being follow-up calls to all children 30 days after their release. ORR is collecting information through these new initiatives, but does not currently have a process to ensure that the data are reliable, systematically collected, or compiled in summary form. Service providers GAO spoke with also noted that some of these children may have difficultly accessing services due to the lack of bilingual services in the community, lack of health insurance, or other barriers.
section_title: What GAO Recommends
paragraphs: In its February 2016 report, GAO recommended that HHS (1) develop a process to regularly update its capacity plan, (2) improve its monitoring of grantees, and (3) develop processes to ensure its post-release activities provide reliable and useful summary data. HHS agreed with GAO's recommendations.

section_title: Letter
paragraphs: I am pleased to be here today to discuss the results of our work on how  the Department of Health and Human Services’ (HHS) Office of Refugee  Resettlement (ORR) has responded to the rapid increase in  unaccompanied children in its care. The number of unaccompanied  children apprehended by Department of Homeland Security (DHS)  officials and subsequently placed in ORR’s care increased from nearly  6,600 in fiscal year 2011 to nearly 57,500 in fiscal year 2014, the highest  number of children on record. In particular, the number of unaccompanied  children from three countries–El Salvador, Guatemala, and Honduras– increased dramatically over this time. While the number of children  needing ORR’s care declined through much of fiscal year 2015, it began  increasing again toward the end of the summer and remained well above  historical levels.
Under the William Wilberforce Trafficking Victims Protection  Reauthorization Act of 2008 (Trafficking Victims Protection  Reauthorization Act), unaccompanied children in the custody of any  federal department or agency, including DHS, must be transferred to  ORR within 72 hours after determining that they are unaccompanied  children, except in the case of exceptional circumstances.The Homeland  Security Act of 2002 gives ORR responsibility for coordinating and  implementing the care and placement of unaccompanied children. ORR  has cooperative agreements with residential care providers to house and  care for unaccompanied children in the least restrictive environment  commensurate with their safety and emotional and physical needs, while  the children are in ORR custody. In addition, these residential care  providers, referred to here as grantees, are also responsible for  identifying and assessing the suitability of potential sponsors – generally  a parent or other relative in the country–who can care for the child after  they leave ORR custody. To do this, grantees collect information from  potential sponsors and run various background checks. In cases in which  there are questions about the ability of the sponsor to meet the child’s  needs and provide a safe environment, and for children included in  specified categories under the Trafficking Victims Protection  Reauthorization Act, a home study is also conducted. In certain  circumstances ORR may also arrange for post-release services for the  child. Release to a sponsor does not grant these children legal  immigration status. Children are scheduled for removal proceedings in  immigration courts to determine whether they will be ordered removed  from the United States or granted immigration relief. There are several  types of immigration relief that may be available to these children, for  example, asylum or Special Immigrant Juvenile status.
My statement summarizes the findings from our February 2016 report,  which addresses (1) how ORR has responded to the increased number of  unaccompanied children, (2) how these children are cared for while in  ORR custody and how ORR monitors their care, (3) how ORR identifies  and screens sponsors before children are transferred to their care, and  (4) what is known about services, challenges, and the status of removal  proceedings for children after they leave ORR custody.
To address these objectives, we analyzed data from ORR’s web-based  portal, a database that contains intake, placement, and sponsor  information, as well as individual service plans for these children. We also  visited nine ORR facilities run by care providers in three states; reviewed  a nongeneralizable random sample of 27 case files of children released in  fiscal year 2014 or 2015 from the nine shelters we visited; and reviewed  relevant ORR policies and other documents, including monitoring  schedules and reports, and funding opportunity announcements. In  addition, we reviewed a plan that was developed by an interagency  group, called the Unified Coordination Group, led by DHS’s Federal  Emergency Management Agency that was established to coordinate the  federal response to the increase in unaccompanied children apprehended  at the southwest border. We also conducted phone interviews with  individuals representing local entities such as school districts and human  services agencies and organizations in six counties where 50 or more  children were released to sponsors in fiscal year 2014. These counties  were selected to represent a diversity of size, geographic location, and  demographics. In addition, we analyzed Department of Justice’s (DOJ)
Executive Office for Immigration Review (EOIR) data. We assessed the  reliability of ORR data by conducting electronic testing, reviewing ORR  business rules, and interviewing ORR officials and contractors  knowledgeable about the data. We assessed the reliability of EOIR data  by reviewing related documentation and interviewing officials  knowledgeable about the data. We determined that the data were  sufficiently reliable for our purposes. We also conducted interviews with  officials from HHS, DHS, and DOJ. A more detailed explanation of our  methodology is available in our full report. We conducted the work upon  which this testimony is based in accordance with generally accepted  government auditing standards.
subsections: section_title: ORR Responded to the Increase in Unaccompanied Children by Expanding Its Capacity, but Has Not Yet Updated Its Plans to Meet Future Needs
paragraphs: From fiscal years 2003 through 2011, ORR cared for fewer than 10,000  unaccompanied children per year. Beginning in fiscal year 2012, the  number of unaccompanied children apprehended at the southwest border  by DHS and transferred to ORR custody rose to unprecedented levels  and peaked in fiscal year 2014 at nearly 57,500 (see fig. 1). While the  number of children served by ORR in fiscal year 2015 was less than the  number served in fiscal year 2014, it was still higher than in previous  years. Further, DHS data show that the number of unaccompanied  children apprehended at the southwest border in fiscal 2016 through  January is more than double the number apprehended during the same  time period in fiscal year 2015.
In response to the increased number of unaccompanied children in recent  years, particularly in fiscal year 2014, ORR increased its shelter capacity  (the number of beds it has available). We found that ORR was initially  unprepared to care for the rapid increase in children needing services;  however, ORR solicited new grantees to provide shelter services in both  2013 and 2014 and awarded additional cooperative agreements. From  fiscal year 2011 through June of fiscal year 2015, the number of ORR  grantees increased from 27 that operated 59 facilities to 57 that operated  140 facilities, and the number of beds available to serve unaccompanied  children increased from almost 1,900 to nearly 7,800.
The number of beds ORR needs depends on the number of  unaccompanied children in its custody and how long these children stay  in grantee facilities before they can be placed with sponsors. To further  manage its capacity to care for the increased number of children, ORR  updated policies and procedures to reduce the number of days children  spend in its custody and expedite their release to sponsors. Specifically,  ORR simplified documentation requirements for sponsors by eliminating  notarization requirements and allowing photocopies (rather than original  copies) of supporting documentation, such as birth certificates. ORR also  removed the fingerprinting component of background checks for parents  and legal guardians with no criminal or child abuse history, reduced the  maximum number of days between approval of a child’s release and  actual discharge, and in some cases paid for a child’s travel to the  sponsor. According to shelter staff, these changes were feasible, in part,  because most children come with contact information for a relative who  can serve as a sponsor. Agency officials also noted that they can now  more quickly release children to their parents or other relatives.
We also found that ORR is taking other actions to ensure it has the  capacity to meet demand caused by increases in the number of  unaccompanied children and to minimize the risks of not being able to  provide care and services to these children. Specifically, ORR developed  a framework for fiscal year 2015 that included plans and steps to manage  its capacity, based in part on the record levels of children needing care in  2014. This framework outlines its plans to continually monitor data on the  referrals of unaccompanied children and other indicators, such as  apprehensions and releases, to help it assess its capacity needs. It also  includes key information ORR should have and mechanisms that should  be in place to meet its needs, such as an inventory of available beds,  timelines and decision points for determining if and when bed capacity  should be increased, and ways to operationalize these decisions. ORR’s  bed capacity framework for fiscal year 2015 was based on the number of  children served in fiscal year 2014. The number of children referred to  ORR through most of fiscal year 2015, while high by historical standards,  was less than expected, and ORR grantees had many unoccupied beds.  However, the number of referrals began increasing toward the end of the  summer and has remained relatively high through the beginning of fiscal  year 2016.
While developing the framework was a positive step and ORR officials  said they continue to use the capacity framework as a “roadmap,” we  found that they have not updated this framework for fiscal year 2016 and  have not established a systematic approach to update the framework on  an annual basis to account for new information so that it remains current  and relevant to changing conditions. According to federal standards for  internal control, an agency’s processes for decision making should be  relevant to changing conditions and completely and accurately  documented. We concluded that not having a documented and  continually updated process for capacity planning may hinder ORR’s  ability to be prepared for an increase in unaccompanied children while at  the same time minimizing excess capacity to conserve federal resources.  We recommended in our February 2016 report that the Secretary of HHS  direct ORR to develop a process to update this bed capacity framework  on an annual basis. HHS concurred with our recommendation.
section_title: Grantees Provided Education, Medical, and Therapeutic Services to Unaccompanied Children in ORR Custody, but ORR’s Monitoring of Grantees Is Inconsistent
paragraphs: ORR relies on grantees to provide care for unaccompanied children, such  as housing and educational, medical, and therapeutic services, and to  document in children’s case files the services they provide. However,  in our February 2016 report we found that documents were often missing  from the 27 randomly selected case files we reviewed. Specifically, 14  case files were missing a legal presentation acknowledgement form, 10  were missing a record of group counseling sessions, and 5 were missing  clinical progress notes. Grantees are required to provide these services  and document that they did so. In addition, we identified several cases in  which forms that were present in the files were not signed or dated.  Although ORR uses its web-based data system to track some information  about the services children receive, and grantees report on the services  they provide in their annual reports, the documents contained in case files  are the primary source of information about the services provided to  individual children. Without all of the documents included in the case files,  it is difficult for ORR to verify that required services were actually provided  in accordance with ORR policy and cooperative agreements.
ORR’s most comprehensive monitoring of grantees occurs during on-site  monitoring visits. However, we found that onsite visits to facilities has  been inconsistent. According to ORR documents, during on-site  monitoring visits, ORR project officers spend a week at facilities touring,  reviewing children’s case files and personnel files, and interviewing  children and staff. Prior to fiscal year 2014, project officers were  supposed to conduct on-site monitoring of facilities at least once a year.
However, our review of agency data found that many facilities went  several years without receiving a monitoring visit. For example, ORR did  not visit 15 facilities for as many as 7 years. In 2014, ORR revised its on- site monitoring program to ensure better coverage of grantees and  implemented a biennial on-site monitoring schedule. Nevertheless, ORR  did not meet its goal to visit all of its facilities by the end of fiscal year  2015, citing lack of resources.
Monitoring visits are intended to provide an opportunity to identify  program deficiencies or areas where programs are failing to comply with  ORR policies. According to standards for internal control, management  should establish and operate monitoring activities to monitor the internal  control system and evaluate the results. Monitoring generally should be  designed to assure that it is ongoing and occurs in the course of normal  operations, is performed continually, and is ingrained in the agency’s  operations. We concluded that without consistently monitoring its  grantees, ORR cannot know whether they are complying with their  agreements and that children are receiving needed services. We  recommended in our February 2016 report that the Secretary of HHS  direct ORR to review its monitoring program to ensure that onsite visits  are conducted in a timely manner, case files are systematically reviewed  as part of or separate from onsite visits, and that grantees properly  document the services they provide to children. HHS concurred, and in its  response to the report described several of its other monitoring efforts,  and stated that it has created a new monitoring initiative workgroup to  examine opportunities for further improvement.
section_title: ORR Grantees Identified and Screened Sponsors before Placing Children with Them
paragraphs: ORR grantees that provide day-to-day care of unaccompanied children  are responsible for identifying and screening sponsors prior to releasing  children to them. During children’s initial intake process, case managers  ask them about potential sponsors with whom they hope to reunite. Within  24 hours of identifying potential sponsors, case managers are required to  send them a Family Reunification Application to complete. The  application includes questions about the sponsor and other people living  in the sponsor’s home, including whether anyone in the household has a  contagious disease or criminal history.  Additionally, the application asks  for information about who will care for the child if the sponsor is required  to leave the United States or becomes unable to provide care. Sponsors  are also asked to provide documents to establish their identity and  relationship to the child. Grantees conduct background checks on  potential sponsors. The types of background checks conducted depend  on the sponsor’s relationship to the child (see table 1). In certain  circumstances prescribed by the Trafficking Victims Protection  Reauthorization Act or ORR policy, a home study must also be conducted  before the child is released to the sponsor. Additionally, in certain  situations, such as where there is a documented risk to the safety of the  unaccompanied child, the child is especially vulnerable, and/or the case is  being referred for a mandatory home study, other household members  are also subjected to background checks.
In our February 2016 report, we found that between January 7, 2014, and  April 17, 2015, nearly 52,000 children from El Salvador, Guatemala, or  Honduras were released to sponsors by ORR. Of these children, nearly  60 percent were released to a parent. Fewer than 9 percent of these  children were released to a non-familial sponsor, such as a family friend,  and less than 1 percent of these children were released to a sponsor to  whom their family had no previous connection (see table 2).
In the fall of 2014, ORR officials told us that they had not seen evidence  that adults are fraudulently sponsoring unaccompanied children.  Nonetheless, ORR officials told us that ORR has been monitoring the  number of children it releases to sponsors, through its web-based portal,  to help ensure that individuals are not sponsoring too many children  unrelated to them. In August 2015, two individuals pleaded guilty to  charges related to luring Guatemalan children into the United States on  false pretenses in 2014. According to the indictment, one of the  individuals submitted fraudulent information to ORR officials to obtain  custody of six children, among other things.
section_title: Limited Information Is Available on Services Provided and the Status of Children Once Released from ORR Care
subsections: section_title: Limited Information Currently Exists on Post- Release Status of Children
paragraphs: There is limited information available about the services provided to  unaccompanied children after they leave ORR custody. According to  ORR officials, a relatively small percentage of unaccompanied children  received post-release services, and they said ORR’s responsibility for the  other children typically ended once it transferred custody of the children to  their sponsors. The Trafficking Victims Protection Reauthorization Act  requires ORR to provide post-release services to children if a home study  was conducted, and authorizes ORR to provide these services to some  additional children. According to ORR data, in fiscal year 2014, slightly  less than 10 percent of unaccompanied children received post-release  services, including those for whom a home study was conducted. Post- release services are limited in nature and typically last a relatively short  time. These services include direct assistance to the child and sponsor by  ORR grantees in the form of guidance to the sponsor to ensure the safest  environment possible for the child, as well as assistance accessing legal,  medical, mental health, and educational services, and initiating steps to  establish guardianship, if necessary. These services can also include  providing information about resources available in the community and  referrals to such resources.
Recently, ORR has taken steps to expand eligibility criteria for post- release services to additional children. According to ORR officials, all  children released to a non-relative or distant relative are now eligible for  such services. In addition, in May 2015, ORR began operating a National  Call Center help-line. Children who contact ORR’s National Call Center  within 180 days of release who have experienced or are at risk of  experiencing a placement disruption are also now eligible for post-release  services according to ORR officials. And in August 2015, ORR instituted a  new policy requiring grantee facility staff to place follow-up calls, referred  to as Safety and Well Being follow up calls, to all children and their  sponsors 30 days after the children are placed to determine whether they  are still living with their sponsors, enrolled in or attending school, aware of  upcoming removal proceedings, and safe. ORR policy requires grantees  to attempt to contact the sponsor and child at least three times.
Although there is limited post-release information for unaccompanied  children, ORR is in a position to compile and share the data it collects  internally and with other federal and state agencies to help them better  understand the circumstances these children face when they are released  to their sponsors. This is because ORR already has some information  from its post-release grantees on services provided to children after they  leave ORR custody, and its newly instituted well-being calls and National  Call Center allow it to collect additional information about these children.  However, ORR does not have processes to ensure that all of these data  are reliable, systematically collected, and compiled in summary form to  provide useful information about this population for its use and for other  government agencies, such as state child welfare services. Federal  internal control standards require that an agency have relevant, reliable,  and timely information to enable it to carry out its responsibilities. As a  result, in our February 2016 report, we recommended that the Secretary  of HHS direct ORR to develop a process to ensure all information  collected through its existing post-release efforts are reliable and  systematically collected so that the information can be compiled in  summary form and provide useful information to other entities internally  and externally. HHS concurred and stated that ORR will implement an  approved data collection process that will provide more systematic and  standardized information on post-release services and that it would make  this information available to other entities internally and externally.
section_title: Challenges and Barriers Identified By Local Service Providers
paragraphs: We found that services available to unaccompanied children through local  service providers are typically the same as those available to other  children without lawful immigration status. For example, children without  lawful immigration status are generally not eligible for federal benefits,  such as the Supplemental Nutrition Assistance Program, Medicaid, and  Temporary Assistance for Needy Families; however, they are eligible for  other federal benefits such as emergency medical assistance, some  public health assistance, and school meals. Local service providers we  spoke with in six counties told us that the children’s status would have no  effect on eligibility for many of the services they provide. For example,  school districts are required to educate students regardless of their  immigration status. Similarly, unaccompanied children were not precluded  from receiving services at health clinics we spoke with.
Some local service providers expressed concerns that unaccompanied  children might have unmet needs or face barriers to receiving some  necessary services. For example, representatives we spoke with in four  of the six school districts, as well as representatives from a county office  of education, discussed the mental and behavioral health needs of these  children. Similarly, local services providers told us these children had  previous exposure to violence and trauma and in some cases  experienced challenges related to reunification with parents they had not  seen for many years. Six service providers said that these factors could  contribute to behavioral and mental health needs or make the children  more susceptible to gang recruitment and trafficking. Some school district  and other service providers reported challenges such as attracting  bilingual professionals, such as mental health providers, making it difficult  for these children to obtain needed services. In addition, unaccompanied  children also face barriers similar to those faced by other children without  lawful immigration status such as lack of health insurance, lack of  knowledge about where to seek services, fear of disclosing their  immigration status, and language barriers.
We also found that the level of awareness about, and services available  to, unaccompanied children varied across the jurisdictions in which we  spoke with stakeholders, with some jurisdictions appearing to have more  resources than others. For example, in one jurisdiction we visited, the  mayor’s office had established a working group related to unaccompanied  children that included representatives from several city departments and  nonprofits. In this city, representatives from the health and education  departments regularly attended immigration court to screen and enroll  children in the state’s Children’s Health Insurance Program and to help  with school enrollment. Conversely, representatives from two other  mayors’ offices told us that they were unaware that unaccompanied  children were living in their city or had limited knowledge about the issue.
section_title: Immigration Outcomes of Unaccompanied Children
paragraphs: With respect to unaccompanied children’s immigration proceedings, we  found that there are several possible outcomes and that the outcomes for  many children have not yet been determined. An unaccompanied child  who is in removal proceedings can apply for various types of lawful  immigration status with DHS’s U.S. Citizenship and Immigration Services  (USCIS), including asylum and Special Immigration Juvenile status.  USCIS’s asylum officers have initial jurisdiction of any asylum application  filed by an unaccompanied child, even if a child is in removal  proceedings. In July 2015, the Associate Director of the Refugee, Asylum  and International Operations Directorate at USCIS testified that USCIS  has received increasing numbers of asylum applications from  unaccompanied children in recent years. USCIS received 534 such  applications in fiscal year 2011 and 6,990 in fiscal year 2014. The  Associate Director testified that since fiscal year 2009, USCIS has  granted asylum to unaccompanied children at a rate of 42.6 percent,  similar to the overall rate at which all new asylum applications were  approved.
If unaccompanied children have not yet sought, or are not granted,  certain immigration benefits within the jurisdiction of USCIS, there are  several other possible outcomes and various forms of relief that may be  available to them during immigration proceedings. For example, an  immigration judge may order them removed from the United States,  administratively close their case, terminate their case, allow them to  voluntary depart the United States, or grant them relief or protection from  removal. From July 18, 2014, when DOJ’s Executive Office for  Immigration Review began to consistently use a code to identify cases  involving unaccompanied children, to July 14, 2015, DHS initiated more  than 35,000 removal proceedings for unaccompanied children. Of these  35,000 removal proceedings, EOIR data indicate that as of July 14, 2015,  an immigration judge issued an initial decision in nearly 13,000  proceedings (or 36 percent). Of those 13,000 decisions, about 7,000 (or  55 percent) resulted in a removal order for the unaccompanied child.  According to EOIR data, about 6,100 (or 88 percent) of those initial  decisions that resulted in removal orders were issued in absentia, which  is when a child fails to appear in court for their removal proceedings and  the immigration judge conducts the proceeding in the child’s absence.
However, a judge’s initial decision does not necessarily indicate the end  of the removal proceedings. For example, cases that are administratively  closed can be reopened, new charges may be filed in cases that are  terminated, and children may appeal a removal order. In addition, a child  who receives a removal order in absentia, and with respect to whom a  motion to reopen their case has been properly filed, is granted a stay of  removal pending a decision on the motion by the immigration judge.  Overall, according to DHS’s Immigration and Customs Enforcement (ICE)  data, from fiscal year 2010 through August 15, 2015, based on final  orders of removal, ICE removed 10,766 unaccompanied children, 6,751  of whom were from El Salvador, Guatemala, or Honduras.
Chairman Grassley, Ranking Member Leahy, and Members of the  Committee, this concludes my prepared remarks. I would be happy to  answer any questions that you may have.
section_title: GAO Contacts and Staff Acknowledgment
paragraphs: For further information regarding this testimony, please contact Kay E.  Brown at (202) 512-7215 or brownke@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this statement. Individuals who made key contributions to  this testimony include Gale Harris (Assistant Director), David Barish  (Analyst-in-Charge), James Bennett, Ramona Burton, Jamila Jones  Kennedy, Jean McSween, James Rebbe, Almeta Spencer, and Kate van  Gelder.
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