Supporting Statement for Sponsorship Review Procedures (06.24.19) clean

Sponsorship Review Procedures for

Unaccompanied Alien Children

OMB Information Collection Request

0970 - 0278

Supporting Statement Part A - Justification

JUNE 2019

Submitted By:

Office of Refugee Resettlement

Administration for Children and Families

U.S. Department of Health and Human Services

SUPPORTING STATEMENT A – JUSTIFICATION

1. Circumstances Making the Collection of Information Necessary

The Department of Health and Human Services (HHS), Administration for Children and Families (ACF), Office of Refugee Resettlement (ORR) is submitting several instruments directly related to the care and placement of unaccompanied alien children in Federal custody for processing pursuant to the Paperwork Reduction Act (PRA). The proposed instruments are the following:

1. Family Reunification Application (ORR UAC/FRP-3 & ORR UAC/FRP-3s)

2. Authorization for Release of Information (ORR UAC/FRP-2 & ORR UAC/FRP-2s)

3. Fingerprinting Instructions (ORR UAC/FRP-7& ORR UAC/FRP-7s)

4. Letter of Designation for Care of a Minor (ORR UAC/FRP-9 & ORR UAC/FRP-9s)

ORR functions related to the care and placement of unaccompanied alien children (UAC) were transferred from the former Immigration and Naturalization Service (INS) pursuant to § 462 of the Homeland Security Act, 6 U.S.C. 279. HHS also complies with the Flores v. Reno Settlement Agreement, No. CV85-4544-RJK (C.D. Cal. 1996). The Department of Homeland Security (DHS) retains the responsibility of immigration benefits and enforcement. Flores provides that ORR is to release UAC for whom ORR determines continued custody is not necessary to ensure the minor’s safety or that of others, when appropriate, to custodial sponsors who agree to provide for their mental, physical, and financial well­being, to ensure their attendance at immigration hearings, and to comply with removal proceedings if so ordered. Flores also provides that a positive suitability assessment may be required prior to release, and may include investigation of the living conditions in which the minor would be placed and the standard of care he or she would receive, verification of identity and employment of the individuals offering support, interviews of members of the household, and a home visit.

Under the Homeland Security Act, the consideration for children’s safety from smugglers, traffickers, or others who might seek to victimize or otherwise engage them in criminal, harmful, or exploitive activity is taken into account when making a placement determination.¹ In 2008 Congress passed, and the President signed, the William Wilberforce Trafficking Victims Protection Reauthorization Act (“TVPRA of 2008”), §235 of the TVPRA of 2008, 8 U.SC. 1232, which creates additional requirements for the placement, care, and release of UAC in federal custody. The TVPRA also contains language stating that there should be policies to ensure UAC are protected from traffickers and others seeking to victimize them or otherwise engage them in criminal, harmful, or exploitative activity. 8 U.S.C. § 1232(c)(1).

The former INS performed investigative background checks on the potential sponsor requesting release of a UAC during the sponsorship review process. During the transition period, DHS performed these checks on these sponsors. As of August 2, 2004, DHS ceased its performance of background checks on sponsors and the physical release from custody.² ORR conducts public records background checks on all adults requesting the release of unaccompanied alien children (potential sponsors) in ORR custody to their custody, their adult household members, and adult caregivers identified in a sponsor care plan (hereinafter “adult caregivers”). ORR conducts fingerprint-based background checks on potential sponsors, adult household members, and adult caregivers under certain circumstances. ORR also sends information to other agencies and entities, such as FBI, to conduct parts of the fingerprint-based background checks in ORR’s suitability process. ORR retains primary responsibility for conducting suitability determinations for sponsors and, as appropriate, adult members of their household and adult caregivers. ORR coordinates and works with its federal partners, including the Office of Personnel Management (OPM), Federal Bureau of Investigation (FBI), in this effort. In June 2018, DHS resumed performing some aspects of background checks for those individuals that ORR requires fingerprints from, pursuant to a joint Memorandum of Agreement signed by ORR and DHS in April 2018 (MOA). ORR subsequently issued four operational directives (December 2018, March 2019, and two in June 2019) that reduced the number of individuals requiring fingerprint checks and discontinued using DHS ICE to obtain immigration status.

These proposed information collections will allow ORR to achieve compliance with the Homeland Security Act, the TVPRA of 2008, and Flores in regards to the sponsorship review procedures of unaccompanied alien children. The cited statutes and documents are included with this package.

2. Purpose and Use of the Information Collection

Family Reunification Application (ORR UAC/FRP-3 & UAC/FRP-3s)

The Family Reunification Application collects information related to the potential sponsor’s ability to provide for the UAC’s mental and physical well­being. ORR uses the information collected to determine the suitability of a potential sponsor as a custodian of a UAC. After the information is collected, it is transmitted electronically to the ORR official responsible for approving the release. The expected respondents of this instrument are potential sponsors. The form is available in both English and Spanish.

Authorization for Release of Information (ORR UAC/FRP-2 & ORR UAC/FRP-2s)

The Authorization for Release of Information collects respondents’ written consent to background investigations with Federal, state or local law enforcement and/or child welfare agencies, and information to allow ORR to make a determination of whether the UAC will be safe in the custody of the potential sponsor, as well as other adult household members. After the information is collected, it is sent electronically to HHS/Program Support Center (PSC) for review and processing. The expected respondents of this instrument are, under certain circumstances, potential sponsors, adult household members, and adult caregivers. The form is available in both English and Spanish.

Fingerprinting Instructions (ORR UAC/FRP-7 & ORR UAC/FRP-7s)

The Fingerprinting Instructions inform, as appropriate, potential sponsors, adult household members, and adult caregivers of the steps they must take to be fingerprinted. Fingerprints are collected electronically at grantee-operated digital fingerprinting sites or submitted via mail using FBI fingerprint cards (form FD-258, OMB Ctrl. No. 1110-0046). The expected respondents of this instrument are, under certain circumstances, potential sponsors, adult household members, and adult caregivers. The instrument is available in both English and a Spanish.

Letter of Designation for Care of a Minor (ORR UAC/FRP-9 & ORR UAC/FRP-9s)

The Letter of Designation for Care of a Minor (Letter of Designation) is filed by a UAC’s parent(s) or legal guardian(s) to specify a potential sponsor to whom they wish to grant care giving authority for their child. The form is optional (not required for release) but helps non-parent sponsors access community resources or answer questions from government authorities about the nature of their relationship with a UAC in their care. The form is available in both English and Spanish.

Information collected from potential sponsors, adult household members, and adult caregivers using these instruments may be shared with HHS’ contractors; Federal, state or local law enforcement and/or child welfare agencies; and federal partners, including OPM, FBI, and DHS, for the purpose of conducting background checks to determine the potential sponsor’s and their home’s suitability, and as otherwise permitted under the Privacy Act.

3. Use of Improved Information Technology and Burden Reduction

Electronic means of collecting this information were considered during the development of these proposed instruments. However, the access to adequate information technology to collect the information could not be assumed, hence the general reliance on paper-based formats for most forms. The forms have been converted to form-fillable PDFs to the extent respondents have computer access connected to the internet. To the extent possible, biometric information is collected electronically and in all cases it is converted to an electronic format for transmission to federal partners. Generally, the individuals who will be completing these instruments lack access to computers and they may not be computer literate, therefore ORR has determined that filing the forms by hand is the best method.

4. Efforts to Identify Duplication and Use of Similar Information

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

5. Impact on Small Businesses or Other Small Entities

The proposed information collections will not burden or impact small businesses. In the event that an entity comes forward to request a UAC as the custodial sponsor, the requested information is at the minimum for intended use.

6. Consequences of Collecting the Information Less Frequently

The lack of these instruments would impede ORR from performing its charged duty of making care and placement determinations for UAC in its care. In order to make a determination regarding the suitability of a potential sponsor, ORR needs to collect the information requested in the Family Reunification Application, Authorization for Release of Information, and Fingerprinting Instructions. These proposed instruments are necessary for the continuous function of the sponsorship review process for releasing unaccompanied alien children from ORR custody.

Most potential sponsors only sponsor one child, but some may apply to sponsor multiple children at the same time (e.g., sibling groups). These instruments are collected once per sponsorship attempt, which includes attempts to sponsor multiple children at the same time. In the event that a child transfers to another care facility, the new care facility would have access to the file. In some cases, the care facility conducts concurrent planning and investigates more than one potential sponsor per child in order to meet the goal of releasing a child to a sponsor in a timely and safe manner. In those cases, each potential sponsor would complete the family reunification package. Though exact figures are hard to come by, overwhelmingly most sponsors only apply to sponsor a child(ren) one time. Therefore, most sponsors are completing and signing the forms only once.

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

ORR is submitting this request for emergency processing pursuant to 5 CFR 1320.13. The use of normal clearance procedures is reasonably likely to prevent or disrupt the collection of information needed for background investigations, which would risk potential harm to children requiring placement with suitable sponsors.

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 OMB review of this information collection activity. This notice was published on May 15, 2018, Volume 83, Number 94, page 22490, and provided a sixty-day period for public comment. During the notice and comment period, five comments were received. Below is a summary of those comments and ORR’s responses.

Comment 1: The proposed information collection is in opposition to ORR’s mission of placing children with appropriate caregivers because it will deter caregivers from coming forward.

ORR Response: ORR is required by statue to perform suitability assessments of potential sponsors and to safeguard minors from traffickers and others seeking to victimize them or otherwise engage them in criminal, harmful, or exploitative activity. This information collection directly supports that requirement. The scope of individuals required to be fingerprinted was expanded in June 2018. As part of its ongoing review of program and operations, ORR evaluated the effect expanded fingerprint-based background checks had on its mission of safe and timely release of UAC. After weighing child welfare considerations, ORR determined that it was in the best interest of children in its care and custody to allow for a more individualized suitability assessment of sponsors. Therefore, ORR issued four operational directives (December 2018, March 2019, and two in June 2019) to enable completion of individualized suitability assessments of potential sponsors without obtaining fingerprints from all household members, in appropriate cases. The third operational directive issued in June 2019 discontinued the use of immigration status obtained by DHS ICE. It should be noted that, historically and during the period of time in which the scope of individuals required to be fingerprinted was expanded, fingerprint-based background checks have not deterred a significant enough number of caregivers from coming forward to sponsor a minor to the point where deterrence outweighs the benefit fingerprint-based background checks provide in ensuring that minors are released into a safe environment. Additionally, the 2019 appropriation act³ prohibits DHS ICE from using information obtained from ORR for immigration enforcement actions except under certain circumstances.

Comment 2: The proposed information collection forces social work staff to violate their code of ethics in regards to avoiding conflicts of interest, protecting confidentiality, and informing clients about disclosure of information. It will also cause delays in the reunification of children with their families and deterring sponsors from coming forward.

ORR Response: Social work staff employed by ORR grantees are expected to make paramount the safety and well-being of minors in ORR care. Increased scrutiny of potential sponsors and their adult household members supports this goal and does not present a conflict of interest. Personal information of minors, potential sponsors, and their adult household members are only disclosed to other parties when necessary to enable ORR to meet its legal and statutory obligations. Individuals are notified by the instruments and verbally by grantee staff that their information may be shared. The June 2018 policy change, which increased the scope of individuals required to be fingerprinted, caused delays in ORR’s reunification process. However, this was expected and ORR actively worked to expand capacity to support the expanded scope and was able to decrease the initial delays. As part of its ongoing review of program and operations, ORR evaluated the effect expanded fingerprint-based background checks had on its mission of safe and timely release of UAC. After weighing child welfare considerations, ORR determined that it was in the best interest of children in its care and custody to allow for a more individualized suitability assessment of sponsors. Therefore, ORR issued four operational directives (December 2018 , March 2019, and two in June 2019) to enable completion of individualized suitability assessments of potential sponsors without obtaining fingerprints from all household members, in appropriate cases, which also assisted in reducing delays in ORR’s reunification process. The third operational directive issued in June 2019 discontinued the use of immigration status obtained by DHS ICE, which is expected to further reduce delays. It should be noted that, historically and during the period of time in which the scope of individuals required to be fingerprinted was expanded, the number of individuals coming forward to sponsor minors has not decreased in a statistically meaningful way to outweigh the benefit that fingerprint-based background checks provide in ensuring that minors are released into a safe environment.

Comment 3: ICE involvement in background checks for sponsor and household members is unnecessary, as immigration status is not a useful metric of the availability to care for a child. Also, ICE involvement deters family reunification and causes extended detention of children in federal facilities.

ORR Response: ORR uses immigration check results to determine how likely it is that a potential sponsor may have to depart the United States and to determine if a Sponsor Care Plan, in which an alternate caregiver is identified to care for the minor, if needed. This is an important part of ensuring the safety and well-being of the minor after release from ORR care. The June 2018 policy change, which increased the scope of individuals required to be fingerprinted, caused delays in ORR’s reunification process. However, this was expected and ORR actively worked to expand capacity to support the expanded scope and was able to decrease the initial delays. As part of its ongoing review of program and operations, ORR evaluated the effect expanded fingerprint-based background checks had on its mission of safe and timely release of UAC. After weighing child welfare considerations, ORR determined that it was in the best interest of children in its care and custody to allow for a more individualized suitability assessment of sponsors. Therefore, ORR issued four operational directives (December 2018, March 2019, and two in June 2019) to enable completion of individualized suitability assessments of potential sponsors without obtaining fingerprints from all household members, in appropriate cases, which also assisted in reducing delays in ORR’s reunification process. The third operational directive issued in June 2019 discontinued the use of immigration status obtained by DHS ICE; instead, immigration status is obtained directly from the sponsors. This directive is expected to further reduce delays. Additionally, the 2019 appropriation act⁴ prohibits DHS ICE from using information obtained from ORR for immigration enforcement actions except under certain circumstances. It should be noted that, historically and during the period of time in which the scope of individuals required to be fingerprinted was expanded, the number of individuals coming forward to sponsor minors has not decreased in a statistically meaningful way to outweigh the benefit that fingerprint-based background checks provide in ensuring that minors are released into a safe environment.

Comment 4: The proposed information collection will deter sponsorship of children and increase releases to unrelated sponsors, thus putting children at greater risk for trafficking or other harm. Additionally, the information collection does not adequately inform sponsors of the sharing of their data with DHS ICE and compromise the welfare of unaccompanied children.

ORR Response: Historically and during the period of time in which scope of individuals required to be fingerprinted was expanded, the number of individuals coming forward to sponsor minors has not decreased in a statistically meaningful way to outweigh the benefit that fingerprint-based background checks provide in ensuring that minors are released into a safe environment. ORR has not seen a significant shift in the number of minors being released to relatives versus unrelated sponsors. Additionally, ORR conducts fingerprint-based background checks specifically to decrease the risk of trafficking and other harm to minors. The Authorization for Release of Information clearly informs potential sponsors, their adult household members, and adult caregivers that their information will be shared with DHS. This is also verbally explained to potential sponsors by ORR grantee staff and potential sponsors may ask follow up questions at any time. It should be noted that the 2019 appropriation act⁵ prohibits DHS ICE from using information obtained from ORR for immigration enforcement actions except under certain circumstances.

Comment 5: The proposed information collection will allow ICE to expand its enforcement activities against sponsors and household members, delaying the reunification process for children, cause long-term harm to the children’s health, allow placement with less appropriate caregivers, and obstruction children’s ability to pursue legal claims. It will also cause the agency to incur costs for the prolonged detention of the children and additional individuals that will need to be evaluated. The collection instruments are not clear and the information to be collected will not increase the safety and wellbeing of unaccompanied children.

ORR Response: The June 2018 policy change, which increased the scope of individuals required to be fingerprinted, caused delays in ORR’s reunification process. However, this was expected and ORR actively worked to expand capacity to support the expanded scope and was able to decrease the initial delays. As part of its ongoing review of program and operations, ORR evaluated the effect expanded fingerprint-based background checks had on its mission of safe and timely release of UAC. After weighing child welfare considerations, ORR determined that it was in the best interest of children in its care and custody to allow for a more individualized suitability assessment of sponsors. Therefore, ORR issued four operational directives (December 2018, March 2019, and two in June 2019) to enable completion of individualized suitability assessments of potential sponsors without obtaining fingerprints from all household members, in appropriate cases, which also assisted in reducing delays in ORR’s reunification process. The third operational directive issued in June 2019 discontinued the use of immigration status obtained by DHS ICE; instead, immigration status is obtained directly from the sponsors. This directive is expected to further reduce delays. Additionally, the 2019 appropriation act⁶ prohibits DHS ICE from using information obtained from ORR for immigration enforcement actions except under certain circumstances. It should be noted that, historically and during the period of time in which the scope of individuals required to be fingerprinted was expanded, the number of individuals coming forward to sponsor minors has not decreased in a statistically meaningful way to outweigh the benefit that fingerprint-based background checks provide in ensuring that minors are released into a safe environment. ORR will incur some additional costs, but initial increases in expenditures will decrease as operations normalize. ORR continues to follow statue and release minors to the most appropriate caregiver. Also, ORR has not seen a significant shift in the number of minors being released to relatives versus unrelated sponsors. The proposed information collection will not affect a minor’s ability to pursue a legal claim. The proposed information collection instruments are clearly written. Additionally, the instruments are verbally explained to potential sponsors by ORR grantee staff and potential sponsors may ask follow up questions at any time. The instruments are available in both English and Spanish (the primary language of most potential sponsors). If the potential sponsor’s primary language is not English or Spanish, ORR will engage an interpretation service to assist in explaining the instruments to the potential sponsor in their primary language.

9. Explanation of Any Payment or Gift to Respondents

No provision or gift to the respondent will be provided.

10. Assurance of Confidentiality Provided to Respondents

ORR has 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 was published on July 18, 2016 at 81 FR 46682. A Privacy Act statement describing the authority for collecting the information, the principal uses, the routine uses that may be made of the information, and the effect of not providing all or some of the requested information, is provided to potential sponsors and, as appropriate, adult members of their households and adult caregivers. Under published routine uses, information may be shared with federal partners, including OPM and FBI, where it will be managed and used in accordance with their policies.

Official copies of the information collections reside at ORR grantee facilities and electronic copies are circulated between the facilities and ORR offices. The completed forms/instruments are stored in a secure database (UAC Portal) that requires two factor authentication for ALL users and is available at this hyperlink: https://ucportal.acf.hhs.gov.

Biometric information collected by ORR is used specifically for background check purposes utilizing Federal databases.

11. Justification for Sensitive Questions

The Family Reunification Application asks potential sponsors whether individuals in their households have contagious medical conditions, whether the minor has any health conditions, and whether they or any individual in their household have criminal history. Under certain circumstances, ORR also collects the fingerprints of the potential sponsor, adults in the potential sponsor’s household, and adult caregivers. ORR informs the potential sponsor that this information is necessary for to make a suitability determination. The potential sponsor signs the Family Reunification Application. Individuals from whom ORR collects fingerprints provide consent by signing the Authorization for Release of Information.

12. Estimates of Annualized Burden Hours and Costs

Each potential sponsor must complete the Family Reunification Application, Authorization for Release of Information, and, under certain circumstances, have their fingerprints collected. Adult household members and adult caregivers must complete the Authorization for Release of Information and have their fingerprints collected in certain circumstances. The Letter of Designation is completed by parents and legal guardians when applicable. Estimates for the number of respondents are drawn from data in the ORR database (UAC Portal) and estimates for the average burden hours are drawn from observed times of completion.

Estimated Burden Hours and Opportunity Costs for Respondents

Information Collection Title	Number of Respondents	Number of Responses per Respondent	Average Burden Hours per Response	Total Burden Hours	Average Hourly Wage	Total Annual Cost
Family Reunification Application	72,100	1	0.75	54,075	$7.25	$392,043.75
Authorization for Release of Information	45,300	1	0.5	22,650	$7.25	$164,212.50
Fingerprint Instructions	45,300	1	1.25	56,625	$7.25	$410,531.25
Letter of Designation	31,700	1	0.5	15,850	$7.25	$114,912.50
			Estimated Annual Burden Total:	149,200	Estimated Annual Cost Total:	$1,081,700.00

Calculating a wage for the respondent is difficult. However, most respondents make minimum wage and this wage is used to determine the estimated annual cost.

Family Reunification Application (ORR UAC/FRP-3 & UAC/FRP-3s)

The estimated time for the completion of the Family Reunification Application by sponsors is approximately 45 minutes. Several of the items request the provision of nominal information, such as names, contact information, addresses and telephone numbers. The more substantive items request information on how the respondent plans to financially support the UAC and the UAC’s potential exposure to communicable diseases within the household where he/she will reside. This information is necessary to determine sponsor suitability and ensure the safety of the child. Additionally, ORR notes that the Family Reunification Application Checklist for Sponsors, which was previously a separate information collection, was merged into the application. The Family Reunification Application requires sponsors to provide certain identity documents for identity verification purposes for both the sponsor and child; proof of immigration status or U.S. citizenship; proof of address; and proof of relationship with the UAC they are seeking to sponsor. ORR based acceptable identity documents on DHS’s I-9 form. The application also solicits information from sponsors regarding pending or closed criminal history and/or other legal matters to which the sponsor was a subject. Criminal history information is used only for purposes of making sponsor suitability decisions under ORR policies.

Authorization for Release of Information (ORR UAC/FRP-2 & ORR UAC/FRP-2s)

The estimated time for completion of the Authorization for Release of Information is approximately 30 minutes. Several of the items request the provision of nominal information, such as names and places of residence. Other items require disclosure of the respondent’s citizenship information.

Fingerprint Instructions (ORR UAC/FRP-7 & ORR UAC/FRP-7s)

The estimated amount of time for a respondent to read the instructions, wait to have their fingerprints taken at a digital site, have their identity documents inspected at the site, and have those results transmitted will vary but is reasonably calculated to be approximately 1 hour and 15 minutes.

Letter of Designation for Care of a Minor (ORR UAC/FRP-9 & ORR/FRP-9s)

The estimated time for completion of the Letter of Designation is approximately 15 minutes. Several of the items request the provision of nominal information, such as names and places of residence.

Estimated Burden Hours and Opportunity Costs for Record Keepers

Information Collection Title	Number of Respondents	Number of Responses per Respondent	Average Burden Hours per Response	Total Burden Hours	Average Hourly Wage	Total Annual Cost
Family Reunification Application	72,100	1	0.25	18,025	$14.00	$252,350.00
Authorization for Release of Information	45,300	1	0.25	11,325	$14.00	$158,550.00
Fingerprint Instructions	45,300	1	1	45,300	$14.00	$634,200.00
Letter of Designation	31,700	1	0.25	7,925	$14.00	$110,950.00
			Estimated Annual Burden Total:	82,575	Estimated Annual Cost Total:	$1,156,050.00

The average hourly rate of an ORR grantee case manager is $14.00 per hour.

Family Reunification Application (ORR UAC/FRP-3 & UAC/FRP-3s)

ORR estimates that an ORR grantee case manager (record keeper) would need about 15 minutes to explain the form to the potential sponsor and to coordinate the collection and the subsequent transmission of the form to ORR headquarters.

Authorization for Release of Information (ORR UAC/FRP-2 & ORR UAC/FRP-2s)

ORR estimates that an ORR grantee case manager would need about 15 minutes to explain the form to the respondent and to coordinate the collection and the subsequent transmission of information to ORR headquarters.

Fingerprint Instructions (ORR UAC/FRP-7 & ORR UAC/FRP-7s)

ORR estimates that an ORR grantee case manager would need about 15 minutes to explain the fingerprint collection process to the respondent and to set up a fingerprinting appointment. ORR estimates that it would take an additional 45 minutes for the ORR grantee fingerprinting specialist to inspect identity documents and collect the respondent’s fingerprints.

Letter of Designation for Care of a Minor (ORR UAC/FRP-9 & ORR/FRP-9s)

ORR estimates that an ORR grantee case manager would need about 15 minutes to explain the form to the respondent and to coordinate the collection and the subsequent transmission of information to ORR headquarters.

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 instruments. The instruments will be completed by the potential sponsors (respondents) themselves and the hiring of a service provider to complete the instruments is not required. The technology employed for the electronic transmission of the instruments to the ORR grantee case manager (record keeper), such as fingerprinting machines, personal computers with internet access, fax machines, scanners, and copiers, is expected to be readily accessible to the respondent at no cost.

14. Annualized Cost to the Federal Government

Duplication of Paper-based instruments

Information Collection Title	Number of Respondents	Number of Responses per Respondent	Pages per Instrument	Total Pages	Cost per Page	Total Printing Cost
Family Reunification Application	72,100	1	10	721,000	$0.05	$36,050.00
Authorization for Release of Information	45,300	1	5	226,500	$0.05	$11,325.00
Fingerprint Instructions	45,300	1	1	45,300	$0.05	$2,265.00
Letter of Designation	31,700	1	2	63,400	$0.05	$3,170.00
			Estimated Annual Burden Total:	1,056,200	Estimated Annual Cost Total:	$52,810.00

This estimate assumes $0.05 per page for duplication purposes.

Federal Staff Time and Costs

Information Collection Title	Number of Respondents	Number of Responses per Respondent	Average Burden Hours per Response	Total Burden Hours	Average Hourly Wage	Total Annual Cost
Family Reunification Application	72,100	1	0.1667	12,017	$41.07	$493,524.50
Authorization for Release of Information	45,300	1	0.1667	7,550	$41.07	$310,078.50
Fingerprint Instructions	45,300	1	0.1667	7,550	$41.07	$310,078.50
Letter of Designation	31,700	1	0.1667	5,283	$41.07	$216,986.50
			Estimated Annual Burden Total:	32,400	Estimated Annual Cost Total:	$1,330,668.00

The annualized cost estimate for each of these instruments considers the time of a step 5 GS-12 in the Washington, DC locality to review information following the submittal. The estimate assumes the average amount of time expected to review the information as provided.

15. Explanation for Program Changes or Adjustments

Revisions were made to the Family Reunification Application and Authorization for Release of Information reflect changes made to ORR background check policies through four operations directives (December 2018, March 2019, and two in June 2019).

The Family Reunification Application was updated to add the collection of proof of immigration status or U.S. citizenship documentation from potential sponsors. This reflects the change made in the third operational directive (June 2019) in which ORR discontinued using DHS ICE immigration status information and, instead, collects this information directly from the sponsor. ORR uses sponsor immigration status information to determine if a sponsor care plan is required in the event that the sponsor may need to leave the U.S. and for macro-level statistical reporting. Immigration status information may be shared with certain non-HHS parties (e.g., HHS contractors, grantees, or consultants) as described in the Privacy Notice that ORR provides to all sponsors. ORR does not except this collection to increase the total response time for each respondent to complete this instrument. The Family Reunification Application was also updated to clarify that sponsors are not required to provide adult caregiver information in certain situations.

The Authorization for Release of Information was updated to address changes made to how DHS ICE may use information obtained from HHS on sponsors, household members, and adult caregivers. A statement was added to explain that information is shared with DHS ICE but that DHS ICE is prohibited from using this information for immigration enforcement actions, except under certain circumstances⁷, through September 30, 2019.

ORR updated burden estimates to reflect the sharp increase in the number of UAC placed in ORR care over the past year. Burden estimates for all four instruments were calculated using data pulled from ORR’s database for April 2018 through May 2019. Additionally, the burden estimates for the Authorization for Release of Information, and Fingerprint Instructions were updated to reflect the reduction in the number of sponsors, household member, and adult caregivers who are required to submit fingerprints.

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.

Sponsorship Review Procedures for

Unaccompanied Alien Children

OMB Information Collection Request

0970 - 0278

Supporting Statement Part B –

Statistical Methods

JUNE 2019

Submitted By:

Office of Refugee Resettlement

Administration for Children and Families

U.S. Department of Health and Human Services

SUPPORTING STATEMENT B – STATISTICAL METHODS

1. Respondent Universe and Sampling Methods

N/A

2. Procedures for the Collection of Information

N/A

3. Methods to Maximize Response Rates and Deal with Nonresponse

N/A

4. Test of Procedures or Methods to be Undertaken

N/A

5. Individuals Consulted on Statistical Aspects and Individuals Collecting and/or Analyzing Data

N/A

1 6 U.S.C. 279(b)(2)

2 See Immigrations and Customs Enforcement Memo, Dated July 29, 2004

3 Consolidated Appropriations Act 2019, Pub. L. 116-6, § 224, 133 Stat. 13.

4 Id.

5 Consolidated Appropriations Act 2019, Pub. L. 116-6, § 224, 133 Stat. 13.

6 Id.

7 Consolidated Appropriations Act 2019, Pub. L. 116-6, § 224, 133 Stat. 13.