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2.0

ORR proposes changes to forms regarding unaccompanied children placement

  1. Original Date Announced

    September 30, 2025

    The Office of Refugee Resettlement (ORR) published a notice requesting comments on proposed revisions to two forms related to placement and transfer of unaccompanied children into ORR facilities. The two forms are the "Notice of Placement in a Restrictive Setting" (Form P-4), which is used to inform unaccompanied children of the reason they have been placed in a restrictive setting; and the "Unaccompanied [Alien] Child Referral" (Form P-7), used by federal agencies to transfer unaccompanied children to ORR custody or by ORR intake staff to place children in an ORR care provider facility. ORR has two versions of Form P-7: one, titled "Unaccompanied [Alien] Child Referral," is not in use; the second, titled "Intake Placement Checklist," is a PDF version that is currently in use. ORR is only proposing revisions to the latter PDF.

    The following are substantive changes to Form P-4:

    • Adds a "Disability Considerations" subsection in "Section B: Placement Information" to meet requirements found in the Lucas R. Disabilities Settlement Agreement
    • Removes "Section B: ORR’s Determination Related to Safety" to align with ORR policies and regulations
    • Updates the criteria under "Section C: Reasons for Restrictive Placement" for each type of restrictive placement and adds a new subsection for "Out-of-Network Hospital" to comply with Flores litigation requirements
    • Adds "Translation’’ subsection to "Section E: Acknowledgement and Certification" to help ORR monitor form compliance with translation requirements in its regulation

    The following are substantive changes to Form P-7:

    • Changes form title from "Intakes Placement Checklist" to "Intakes Restrictive Placement Checklist" to better align the form’s title with its purpose
    • Reorganizes "Section B: Heightened Supervision Facility Criteria" and "Section C: Secure Facility Criteria" to include definitions of each type of facility, criterion, and the standard for decisions
    • Updates criteria and supporting factors in Sections B and C to align with ORR policies and regulations
    • Adds follow-up questions in Sections B and C to document what information was relied on the make the placement determination and clarify whether each placement criterion was met
    • Rewords field labels and adds a field to document the reason for the recommended level of care in "Section D: Placement Determination"

    The following are proposed changes to terminology in both forms:

    • Changes "staff secure” to “heightened supervision facility"
    • Changes “gender” to “sex"
    • Changes “country of Birth” to “Country of Origin"
    • Changes “unaccompanied child” to “child” or “unaccompanied alien child"

    HHS requested a 180-day approval for this request under procedures for expedited processing due to secure beds becoming available on September 15, 2025. Comments are due by December 1, 2025.

    Trump 2.0 [ID #2103]

    2025.09.25 ORR - Supporting Statement 2025.09.25 ORR - Emergency Justification 2025.09.30 HHS - Notice of Revision of ORR Forms Regarding Unaccompanied Children Placement

Current Status

None

To provide information, corrections, or feedback, please email IPTP.feedback@gmail.com