Emergency SSA_0970-0554_Placement and Transfer_011_2025 09 25 CLEAN

Placement and Transfer of

Unaccompanied [Alien] Children

into ORR Care Provider Facilities

OMB Information Collection Request

0970 - 0554

Supporting Statement Part A - Justification

September 2025

Type of Request: Emergency 

Submitted By:

Office of Refugee Resettlement

Administration for Children and Families

U.S. Department of Health and Human Services

Summary

ACF is requesting emergency review and approval by OMB to update two forms approved under the Placement and Transfer of Unaccompanied [Alien] Children into ORR Care Provider Facilities information collection (OMB #0970-0554), as authorized under 5 CFR 1320.13.  ACF is requesting approval as soon as possible due to secure beds becoming available on September 15, 2025 and requests 180 days of approval, during which time a full revision request will be submitted under normal procedures under the Paperwork Reduction Act.

The information collection is essential to the mission of the agency, the use of normal clearance procedures is reasonably likely to prevent or disrupt the collection of information, and public harm is reasonably likely to result if normal clearance procedures are followed. For additional information see Attachment A.

1. Circumstances Making the Collection of Information Necessary

The Office of Refugee Resettlement (ORR) Unaccompanied Alien Children (UAC) Bureau provides care and custody for unaccompanied alien children until they can be safely released to a sponsor, repatriated to their home country, or obtain legal status. ORR funds residential care provider facilities that provide temporary housing and other services to children in ORR custody. Generally, care provider facilities are State licensed (with the exception of those located in states unwilling to license them and temporary influx care facilities) and must meet ORR requirements to ensure a high-level quality of care. Services provided at care provider facilities include, but are not limited to, education, recreation, vocational training, acculturation, nutrition, medical, mental health, legal, and case management.

ORR uses several forms directly related to the care of unaccompanied alien children. The forms in this information collection allow ORR to place unaccompanied alien children referred to ORR by federal agencies into care provider facilities and to transfer children within the ORR care provider network.

Legal Authorities

Homeland Security Act (HSA), 6 U.S.C. 279 – Transferred responsibilities for the care and placement of unaccompanied alien children from the Commissioner of the former Immigration and Naturalization Service (INS) to the Director of ORR. The HSA requires ORR to make placement determinations that ensure unaccompanied alien children are likely to appear for all hearings or proceedings; are protected from smugglers, traffickers, or others who might seek to victimize or otherwise engage them in criminal, harmful, or exploitive activity; and are placed in a setting in which they are not likely to pose a danger to themselves or others. In addition, ORR is required to ensure that the interests of the child are considered in decisions and actions relating to the care and custody of an unaccompanied alien child. Finally, ORR is required to maintain specific data on unaccompanied alien children, including but not limited to information related to the child’s placement, transfer, or release from each facility; an explanation in cases where the child is placed in a restrictive setting; and the disposition of any actions in which the child is the subject.

William Wilberforce Trafficking Victims Protection Reauthorization Act of 2008 (TVPRA), 8 U.S.C. 1232 – Creates additional requirements for the placement, services, and discharge of unaccompanied alien children in federal custody. The TVPRA directs ORR to create policies to ensure children are protected from traffickers and others seeking to victimize them or otherwise engage them in criminal, harmful, or exploitative activity. In addition, the TVPRA requires that children be promptly placed in the least restrictive setting that is in the best interest of the child; children must not be placed in a secure facility absent a determination that the child poses a danger to self or others or has been charged with having committed a criminal offense; and placement of a child in a secure facility must be reviewed, at a minimum, on a monthly basis.

Unaccompanied Children Program Foundational Rule, 45 C.F.R. Part 410 – Establishes a uniform set of standards and procedures concerning the placement, care, and services provided to unaccompanied alien children in ORR care that is consistent with ORR’s statutory duties. Subpart B sets forth the process by which ORR receives referrals of unaccompanied alien children from other Federal agencies and the factors ORR considers when placing a child in a particular care provider facility. Subpart C provides guidelines for the transfer of an unaccompanied alien child.

Flores v. Reno Settlement Agreement, No. CV85-4544-RJK (C.D. Cal. 1996)¹ – Establishes an order of priority for sponsors with whom unaccompanied alien children should be placed and sets minimum standards for the release, housing, services, transportation, and discharge of unaccompanied alien children.

Lucas R. et al v. Becerra et al, No. 2:18-CV-05741 DMG PLA – Includes three settlement agreements that establish standards and practices for the administration of psychotropic medication to children in ORR custody, services for children in ORR custody with disabilities, and access to legal assistance for children in ORR custody. The Disabilities Settlement Agreement sets forth requirements for the placement of children with disabilities in ORR care, including documentation requirements specific to the child’s initial notice of placement and 30-day placement review.

2. Purpose and Use of the Information Collection

• Placement Authorization (Form P-1): This form is used by ORR to authorize a care provider to provide care and services to unaccompanied alien children placed in their facility. Care providers sign the form to acknowledge certain responsibilities related to the care of the children.

• Authorization for Medical, Dental, and Mental Health Care (Form P-2): This form is used by ORR to authorize a care provider to provide medical, dental, and mental health care services to unaccompanied alien children placed in their facility. Care providers sign the form to acknowledge certain responsibilities related to the care of the children.

• Notice of Placement in a Restrictive Setting (Form P-4): This form is used by care providers to document and inform unaccompanied alien children of the reason they have been placed in a restrictive setting. This form is available in English and Spanish. See 45 CFR 410.1105, 45 CFR 410.1901, UAC Policy Guide Section 1.2.4 Secure and Staff Secure Care Provider Facilities, and Section 1.4.2 30-Day Restrictive Placement Case Review for related for related agency guidance.

• Foster Care Placement Memo (Form P-5): This form is used by care providers to ensure placement in a foster home that meets the child’s needs and continuity of services. See UAC Policy Guide Section 1.2.6 ORR Long Term Foster Care for related agency guidance.

• Unaccompanied [Alien] Child Referral ( aka Intakes Restrictive Placement Checklist) (Form P-7): This form is used by Federal agencies to refer unaccompanied alien children to ORR custody and by ORR Intakes staff to place children in an ORR care provider facility. It also contains a checklist that is used by ORR Intakes staff to determine whether initial placement in a restrictive setting is appropriate for the child. See 45 CFR 410.1101, 45 CFR 410.1105, UAC Policy Guide Section 1.3 Referrals to ORR and Initial Placement, and Section 1.2.4 Secure and Staff Secure Care Provider Facilities for related agency guidance.

• Care Provider Checklist for Transfers to Influx Care Facilities (Form P-8): This form is used by care providers to ensure that all criteria for transfer of a child to an influx care facility have been met. See 45 CFR 410.1802 and UAC Policy Guide Section 7.2 Placement into Influx Care Facilities for related agency guidance.

• Medical Checklist for Non-Influx Transfers (Form P-9A): This form is used by care providers to ensure that children are medically cleared for transfer within the ORR care provider network, excluding transfer to an influx care facility. See 45 CFR 410.1601 and UAC Policy Guide Section 1.4 Transfers within the ORR Care Provider Network for related agency guidance.

• Medical Checklist for Transfers to Influx Care Facilities (Form P-9B): This form is used by care providers to ensure that children are medically cleared for transfer to an influx care facility. See 45 CFR 410.1802 and UAC Policy Guide Section 7.2 Placement into Influx Care Facilities for related agency guidance.

• Transfer Request (Form P-10A): This form is used by care provider facilities, ORR contractor staff, and ORR Federal staff to process recommendations and decisions for transfer of a child within the ORR care provider network. See 45 CFR 410.1601 and UAC Policy Guide Section 1.4 Transfers within the ORR Care Provider Network for related agency guidance.

• Placement Confirmation (Form P-10B): This form is used by care provider facilities, ORR contractor staff, and ORR Federal staff to recommend and approve placement into a specific care provider program once a transfer request is approved. See 45 CFR 410.1601 and UAC Policy Guide Section 1.4 Transfers within the ORR Care Provider Network for related agency guidance.

• Transfer Summary and Tracking (formerly titled Transfer Request and Tracking Form) (Form P-11): This form is used by care providers to track the physical transfer of the child and their belongings. See 45 CFR 410.1601 and UAC Policy Guide Section 1.4 Transfers within the ORR Care Provider Network for related agency guidance.

• Bed Configuration Module (Form P-12A): This form is used by care providers to create a digital representation of their facility, set rules for beds, and specify the status of beds.

• Bed Assignment and Capacity Overview Module (Form P-12B): This form is used by care providers to assign children to beds and track program capacity.

• Program Entity (formerly titled UAC Portal Capacity Report) (Form P-12C): This form is used by care providers and ORR to track certain information related to care provider programs, such as location, contact information, state licensure, grant information, and monitoring.

• Unaccompanied [Alien] Child Profile (formerly titled Add New Unaccompanied [Alien] Child) (Form P-13): This form is used by referring Federal agencies and care providers to create a profile for an unaccompanied alien child from which all information related to their case can be accessed.

• ORR Transfer Notice – Notice of Transfer to ICE Chief Counsel – Change of Address/Change of Venue (Form P-14): This form is used by care providers to notify DHS of the transfer of a child within the ORR care provider network so that DHS may file a Motion for Change of Venue and/or Change of Address with the Executive Office for Immigration Review to ensure the child’s immigration case is transferred to the local immigration court, if applicable.

• Family Group Entity (Form P-15): This form is used by the ORR Intakes Team to associate children who are members of the same family with each other.

• Influx Transfer Manifest (Form P-16): This form is used by designated care provider staff and ORR staff to plan, track, and notify stakeholders of group transfers to an influx care facility. See 45 CFR 410.1802 and UAC Policy Guide Section 7.2 Placement into Influx Care Facilities for related agency guidance.

• Influx Transfer Manual and Prescreen Review (Form P-17): This form is used by designated care provider staff to evaluate each child’s eligibility to be transferred to an influx care facility. Care provider staff review and update information on daily during times of influx. See 45 CFR 410.1802 and UAC Policy Guide Section 7.2 Placement into Influx Care Facilities for related agency guidance.

• Notice of Administrative Review (Form P-18): This form is serves as written notice of receipt of a Placement Review Panel request, provides the child with information on next steps to take when requesting a review and reconsideration of the child's placement in a restrictive setting, and requests information needed by ORR to conduct the placement review from the child or their representative. This form is available in English, Spanish, Dari, and Pashto. See 45 CFR 410.1902 and UAC Policy Guide Section 1.4.7 Requesting Reconsideration of a Restrictive Placement.

3. Use of Improved Information Technology and Burden Reduction

ORR is in the process of streamlining information management by consolidating unaccompanied alien children information from disparate storage locations, reducing manual paperwork processing conducted outside of the system (e.g., spreadsheets, PDFs, Word documents), maximizing the use of auto-population so that information is not entered more than once, enforcing business rules through automated workflow management, and improving business intelligence capabilities by automating reporting and data analytics.

4. Efforts to Identify Duplication and Use of Similar Information

The information being collected by these forms are not obtainable from other sources.

5. Impact on Small Businesses or Other Small Entities

The proposed information collections will not burden or impact small businesses.

6. Consequences of Collecting the Information Less Frequently

Not collecting the information requested in these forms would impede ORR from performing its charged duty of accepting referrals from Federal agencies within 72 hours and placing children in the least restrictive setting. Furthermore, all grantees funded to provide services to these children are required in writing to comply with all of ORR’s program policies, procedures, and guidance, which includes collecting the information in these forms.

7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

None of the characteristics outlined in 5 CFR 1320.5(d)(2) apply to the forms in this collection.

8. Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency

In accordance with the Paperwork Reduction Act of 1995 (Pub. L. 104-13) and Office of Management and Budget (OMB) regulations at 5 CFR Part 1320 (60 FR 44978, August 29, 1995), ACF published a notice in the Federal Register announcing the agency’s intention to request an expedited OMB review of this information collection activity. This notice alerted the public to a request for emergency approval for six months of data collection and provided a sixty-day comment period related to the full request that will be submitted to continue data collection beyond six months. A full request will document any comments received and how ACF has considered the comments.

9. Explanation of Any Payment or Gift to Respondents

No payment or gift to the respondents will be provided.

10. Assurance of Confidentiality Provided to Respondents

ORR established a system of records to ensure the level of confidentiality pursuant to the Privacy Act. 5 U.S.C. 552a. ORR’s system of records notice, titled 09-80-0321 ORR Unaccompanied Children Bureau Administrative Program Records, was published on December 12, 2024 at 89 FR 100500.

11. Justification for Sensitive Questions

Sensitive information may be collected in these forms in order for ORR to make informed placement decisions that ensure all children are placed in the least restrictive setting that meets their individual needs. ORR does not ask for any information of a sensitive nature beyond what is needed to make appropriate placement decisions.

12. Estimates of Annualized Burden Hours and Costs

Estimates used to calculate burden are based on the following factors:

• Number of referrals to ORR custody and transfers within the ORR care provider network in FY2024.

• ORR funds approximately 220 care provider grantees, including approximately 50 long term foster care programs and 6 restrictive placement programs.

• The cost to respondents was calculated using median hourly wage data from May 2024 for the following Bureau of Labor Statistics (BLS) job codes. The rates were multiplied by two to account for fringe benefits and overhead.

  • 21-1021 Child, Family, and School Social Workers in the industry of Other Residential Care Facilities – $23.53 ´ 2 = $47.06

  • 23-2011 Paralegals and Legal Assistants in the industry of Legal Services – $30.76 x 2 = $61.52

Information Collection Title	Annual Number of Respondents	Annual Number of Responses per Respondent	Average Burden Hours per Response	Annual Total Burden Hours	Average Hourly Wage	Annual Total Cost
Placement Authorization (Form P-1)	220	446	0.08	7,850	$47.06	$369,421.00
Authorization for Medical, Dental, and Mental Health Care (Form P-2)	220	446	0.08	7,850	$47.06	$369,421.00
Notice of Placement in a Restrictive Setting (Form P-4)	6	83	0.50	249	$47.06	$11,717.94
Long Term Foster Care Placement Memo (Form P-5)	115	7	0.25	201	$47.06	$9,459.06
Unaccompanied [Alien] Child Referral (aka Intakes Restrictive Placement Checklist) (Form P-7)	40	2,394	1.00	95,760	$47.06	$4,506,465.60
Care Provider Checklist for Transfers to Influx Care Facilities (Form P-8)	220	2	0.25	110	$47.06	$5,176.60
Medical Checklist for Non-Influx Transfers (Form P-9A)	220	8	0.08	141	$47.06	$6,635.46
Medical Checklist for Transfers to Influx Care Facilities (Form P-9B)	220	5	0.17	187	$47.06	$8,800.22
Transfer Request (Form P-10A) - Grantee Case Manager	220	11	0.25	605	$47.06	$28,471.30
Transfer Request (Form P-10A) – Contractor Case Coordinator	275	11	0.17	514	$47.06	$24,188.84
Placement Confirmation (Form P-10B) - Grantee Case Manager	220	11	0.17	411	$47.06	$19,341.66
Placement Confirmation (Form P-10B) – Contractor Case Coordinator	275	11	0.17	514	$47.06	$24,188.84
Transfer Summary and Tracking (Form P-11)	220	11	0.17	411	$47.06	$19,341.66
Bed Configuration Module (Form P-12A)	220	12	0.17	449	$47.06	$21,129.94
Bed Assignment and Capacity Overview Module (Form P-12B)	220	435	0.17	16,269	$47.06	$765,619.14
Program Entity (Form P-12C)	220	12	0.50	1,320	$47.06	$62,119.20
Unaccompanied [Aline] Child Profile (Form P-13)	220	435	0.75	71,775	$47.06	$3,377,731.50
ORR Transfer Notification - ORR Notification to ICE Chief Counsel of Transfer of UC and Request to Change Address/Venue (Form P-14)	220	11	0.17	411	$47.06	$19,341.66
Family Group Entity (Form P-15)	40	75	0.08	240	$47.06	$11,294.40
Influx Transfer Manifest (Form P-16)	3	12	0.33	12	$47.06	$564.72
Influx Transfer Manual and Prescreen Criteria Review (Form P-17)	220	52,232	0.50	5,745,520	$47.06	$270,384,171.20
Notice of Administrative Review (Form P-18)	200	1	0.83	166	$61.52	$10,212.32
			Estimated Annual Burden Hours Total:	5,950,965	Estimated Annual Cost Total:	$280,054,813.26

13. Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers

Respondents will not incur any direct monetary costs, other than their time, in the completion of these forms.

14. Annualized Cost to the Federal Government

The annualized cost estimate for each of these forms considers the time of a GS-12 Step 1 federal employee in the Washington, DC locality to review information following submittal. No additional costs will be incurred by the Federal government for developing computer systems or storing the forms as those systems are already in place. The hourly rate was multiplied by two to account for fringe benefits and overhead.

Information Collection Title	Annual Number of Respondents	Annual Number of Responses per Respondent	Average Federal Staff Burden Hours per Response	Annual Total Federal Staff Burden Hours	Average Federal Staff Hourly Wage	Annual Total Federal Staff Cost
Long Term Foster Care Placement Memo (Form P-5)	85	0	0.17	0	$97.18	$0.00
Unaccompanied [Alien] Child Referral (aka Intakes Restrictive Placement Checklist) (Form P-7) – ORR Federal Staff	85	9	0.17	130	$97.18	$12,633.40
Unaccompanied [Alien] Child Referral (aka Intakes Restrictive Placement Checklist) (Form P-7) – Referring Federal Agency	50	1,915	0.25	23,938	$97.18	$2,326,294.84
Care Provider Checklist for Transfers to Influx Care Facilities (Form P-8)	85	6	0.17	87	$97.18	$8,454.66
Medical Checklist for Non-Influx Transfers (Form P-9A)	85	22	0.08	150	$97.18	$14,577.00
Medical Checklist for Transfers to Influx Care Facilities (Form P-9B)	85	12	0.08	82	$97.18	$7,968.76
Transfer Request (Form P-10A)	85	28	0.17	405	$97.18	$39,357.90
Placement Confirmation (Form P-10B)	85	28	0.17	405	$97.18	$39,357.90
Transfer Summary and Tracking (Form P-11)	85	28	0.08	190	$97.18	$18,464.20
Bed Assignment and Capacity Overview Module (Form P-12B)	160	52	0.17	1,414	$97.18	$137,412.52
Program Entity (Form P-12C)	35	12	0.50	210	$97.18	$20,407.80
Unaccompanied [Alien] Child Profile (Form P-13)	85	1,127	0.50	47,898	$97.18	$4,654,727.64
Unaccompanied [Alien] Child Profile (Form P-13)	50	1,915	0.17	16,278	$97.18	$1,581,896.04
ORR Transfer Notification - ORR Notification to ICE Chief Counsel of Transfer of UC and Request to Change Address/Venue (Form P-14)	85	28	0.08	190	$97.18	$18,464.20
Influx Transfer Manifest (Form P-16)	85	1	0.25	21	$97.18	$2,040.78
Influx Transfer Manual and Prescreen Criteria Review (Form P-17)	85	12	0.25	255	$97.18	$24,780.90
Notice of Administrative Review (Form P-18)	5	40	0.50	100	$97.18	$9,718.00
			Estimated Annual Burden Hours Total:	91,753	Estimated Annual Cost Total:	$8,916,556.54

15. Explanation for Program Changes or Adjustments

ORR is proposing changes to the Notice of Placement in a Restrictive Setting (Form P-4) and Unaccompanied [Alien] Child Referral (aka Intakes Placement Checklist) (Form P-7). The proposed changes are related to current administration priorities, to align the placement criteria in forms with the criteria found in 45 CFR 410.1105 and UAC Policy Guide Sections 1.2.4 and 1.4.6 and to meet requirements in the Lucas R. Disabilities Settlement Agreement (Case No. 2:18-CV-05741 DMG PLA), and Flores litigation (Case No. CV85-4544-RJK (C.D. Cal. 1996)).

Notice of Placement in a Restrictive Setting (Form P-4)

Proposed Change	Details	Context
Update terminology to align with ORR regulations and to comply with guidance from the current Administration	Change “staff secure” to “heightened supervision facility” Change “gender” to “sex” Change “country of Birth” to “Country of Origin” Change “unaccompanied child” to “child” or “unaccompanied alien child”	To align with ORR’s Foundational Rule (45 CFR 410.1001) and to comply with Executive Order 14168 Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government, as well as other guidance from the current Administration
Reorganize where some information/fields appear in the form	Move information regarding the child’s right to challenge their placement to the top of the form Move fields related to placement into their own “Placement Information” section	For clarification
Add a “Disability Considerations” subsection in “Section B: Placement Information”	Questions for the new subsection are: Does the child have a disability or disabilities? If yes, what is the disability or disabilities? If yes, when was the child referred for an evaluation based on their presenting symptoms? If yes, what accommodations or services are currently being offered to meet the child’s disability-related needs? If yes, describe the services or care that will be provided at the restrictive placement, why they are necessary, and why they cannot be provided in a more integrated and less restrictive setting with additional services, supports, and/or accommodations.	To meet requirements found in the Lucas R. Disabilities Settlement Agreement. First two questions are asked in Psychotropic Medication Informed Consent (Form MMH-1), which underwent public comment and is approved under OMB# 0970-0641. They are also needed in this form to ensure children with an identified disability are placed in least restrictive setting as required under the Settlement. Third question is a follow-up question to ensure children have been appropriately evaluated so their needs may be considered when making placement determinations. Fourth question is documented in the Individualized Section 504 Service Plan (Form S-25), approved under OMB# 0970-0643. User will summarize what is in the child’s 504 Service Plan in this field. Final question is a follow-up question to ensure children with an identified disability are placed in least restrictive setting as required under the Settlement.
Remove “Section B: ORR’s Determination Related to Safety”	Section contains the following checkbox options: Child presents a danger to self or community Child poses a risk of escape	To align with ORR’s Foundational Rule (45 CFR 410.1105) and UAC Policy Guide Sections 1.2.4 and 1.4.6.
Update “Section C: Reasons for Restrictive Placement”	Update the criteria for each type of restrictive placement (heightened supervision facility, secure facility, and residential treatment center) Add a new subsection for “Out-of-Network Hospital”	First set of changes are to align the criteria with ORR’ Foundational Rule (45 CFR 410.1105) and UAC Policy Guide Sections 1.2.4 and 1.4.6. Second change is to comply with Flores litigation (Case No. CV85-4544-RJK (C.D. Cal. 1996)).
Add “Translation” subsection to “Section E: Acknowledgement and Certification”	Information requested in subsection includes: Language form was translated into Who translated the form The translators ID# (if applicable)	To help ORR monitor for compliance with its regulations, which requires that all documents be translated into the child’s native or preferred language for step ups and step downs from restrictive placements (45 CFR 410.1306(c)(4)).

Unaccompanied [Alien] Child Referral (aka Intakes Placement Checklist) (Form P-7)

ORR has two versions of Form P-7 approved under this information collection. The first version, titled Unaccompanied [Alien] Child Referral, was created for the UAC Path system, which was never implemented. The second version, titled Intakes Placement Checklist, is a PDF version that is currently in use. ORR is only proposing revisions to the PDF version of this form.

Proposed Change	Details	Context
Change form title	Change from “Intakes Placement Checklist” to “Intakes Restrictive Placement Checklist”	To better align the form’s title with its purpose
Update terminology to align with ORR regulations and to comply with guidance from the current Administration	Change “staff secure” to “heightened supervision facility” Change “gender” to “sex” Change “unaccompanied child” to “child” or “unaccompanied alien child”	To align with ORR’s Foundational Rule (45 CFR 410.1001) and to comply with Executive Order 14168 Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government, as well as other guidance from the current Administration
Reorganize “Section B: Heightened Supervision Facility Criteria” and “Section C: Secure Facility Criteria”	Each section will include: A brief definition of the type of facility A reminder that placement decisions must be made based on clear and convincing evidence along with the definition for clear and convincing evidence A subsection for each criterion that includes: The criterion, as written in ORR regulations and policy A list of supporting factors that may be used to help determine whether the child meets the criterion A final determination on whether the criterion is met	For clarity
Update criteria and supporting factors in Sections B and C	Criteria and supporting factors will be updated to mirror language used in the Foundational Rule, and any language that contradicts or does not align with the Rule will be removed	To align the criteria with ORR’ Foundational Rule (45 CFR 410.1105) and UAC Policy Guide Sections 1.2.4 and 1.4.6.
Add follow-up questions in Sections B and C	Users are asked to: List the evidence used to determine whether the child meets the criteria for placement Confirm whether there is clear and convincing evidence that the child meets the criteria for placement	First question is asked so that there is a record of what information/documents were relied upon to make the placement determination. Second question is asked to remove any ambiguity regarding whether each criterion was met.
Update “Section D: Placement Determination”	Add subheadings to separate fields related to the “Intakes Specialist Recommended Level of Care” from the “Placements Supervisor Level of Care Determination” Replace the “Recommended Placement” radio buttons with a “Recommended Level of Care” dropdown field Update field labels to reflect that the responsibility for making a final level of care determination has moved from the Federal Field Specialist (FFS) to the Placements Supervisor Reword “Reason for Override” to “Explain reason for placement in a different level of care than the initial recommended level of care” Replace the “Final Placement Determination” radio buttons with a “Level of Care” dropdown field Reword “Designated Placement” to “Care Provider Name” Add field for “Reason for Recommended Level of Care”	For clarity. Last item is a follow-up question added to ensure ORR’s decision making is appropriately documented.

Burden Hours and Costs

ORR updated the burden hours for all forms to reflect a decrease in the number of children referred to ORR and a decrease in the number of care provider facilities. ORR also updated the estimated costs for all forms to reflect more recent wage data from the Bureau of Labor Statistics. Finally, ORR updated the average burden hours per response for the Notice of Placement in a Restrictive Setting (Form P-4) from 0.33 hours to 0.5 hours.

16. Plans for Tabulation and Publication and Project Time Schedule

ORR does not plan to publish the information provided by the respondents.

17. Reason(s) Display of OMB Expiration Date is Inappropriate

ORR plans to display the expiration date of clearance as set by OMB.

18. Exceptions to Certification for Paperwork Reduction Act Submissions

No exceptions are necessary for this information collection.

1 Flores was partially and conditionally terminated per Flores v. Garland, No. CV 85-4544-DMG (AGRX), 2024 WL 3467715 (C.D. Cal. June 28, 2024). However, provisions governing secure, heightened supervision, and out-of-network facilities were not terminated and remain in effect.