SSA_0970-0643_Disabilities_10.15.25 CLEAN

Services for Unaccompanied Alien Children with Disabilities

OMB Information Collection Request

0970 – 0643

Supporting Statement Part A - Justification

February 2025; Updated October 2025

Type of Request: New Collection

Submitted By:

Office of Refugee Resettlement

Administration for Children and Families

U.S. Department of Health and Human Services

Summary

This request is for a nonsubstantive change request, which adds an appendix to the Individualized Section 504 Service Plan (Form S-25). This version updates the most recent revision request (February 2025) to add references to the appendix. Otherwise, this document covers the most recent request for OMB #0970-0643.

1. Circumstances Making the Collection of Information Necessary

The ORR 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 consider them for licensure and temporary emergency and 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 instruments directly related to the care of unaccompanied alien children. The instruments in this information collection allow ORR to provide individualized care to children identified as having a disability.

Legal Authorities

Homeland Security Act (HSA), 6 U.S.C. 279 – Transferred responsibilities for the care and placement of unaccompanied children from the Commissioner of the former Immigration and Naturalization Service (INS) to the Director of ORR.

William Wilberforce Trafficking Victims Protection Reauthorization Act of 2008 (TVPRA), 8 U.S.C. 1232 – Creates additional requirements for the placement, care, and release of unaccompanied alien children in federal custody. The TVPRA also directs ORR to create policies to ensure unaccompanied alien children are protected from traffickers and others seeking to victimize them or otherwise engage them in criminal, harmful, or exploitative activity.

Unaccompanied Children Program Foundational Rule, 45 C.F.R. 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 and implements minimum standards for the care of unaccompanied alien children. Specifically, 45 C.F.R. 410.1311 requires ORR to administer the UAC Program in the most integrated setting appropriate to the needs of unaccompanied alien children with disabilities in accordance with 45 CFR 85.21(d), unless ORR can demonstrate that this would fundamentally alter the nature of its UAC Program. ORR must also make reasonable modifications to its programs, including the provision of services, equipment, and treatment, so that an unaccompanied child with one or more disabilities can have equal access to the UAC Program in the most integrated setting appropriate to their needs.

Lucas R. et al v. Becerra et al (Case No. 2:18-CV-05741 DMG PLA) Disabilities Settlement Agreement – Requires that ORR implement an Individualized Section 504 Service Plan for children with disabilities who need them as is consistent with Section 504 of the Rehabilitation Act of 1973, which will assist ORR in placing children with disabilities in the most integrated setting appropriate for their needs. The Individualized Section 504 Service Plan will document any services, supports and reasonable accommodations and modifications necessary to meet the child’s identified disability-based needs, as well as specific triggers of disability-related behaviors (as applicable), and will include a transition plan to ensure to the best extent practicable that they are released from ORR custody without unnecessary delay due to their disability.

2. Purpose and Use of the Information Collection

This information collection consists of one form, the Individualized Section 504 Service Plan (Form S-25), which is used to gather information that will allow ORR to develop and implement Individualized Section 504 Service Plans for any child identified as having a disability. This form is completed by care providers alongside a qualified assessment team who collaboratively develop an individualized plan for the child. In addition, care providers must continuously update this form to reflect any changes in the service plan and to provide updates on the progress of the home study and post-release services planning. The form also includes an appendix that is used to satisfy reporting requirements under the Lucas R. Disabilities Settlement Agreement. For related policies, see UAC Policy Guide Section 3.8 Children with Disabilities in ORR Care and Custody.

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.

Information requested in the primary form will be collected in PDF format until such time as ORR is able to incorporate it into a web-based case management application.

Information requested in the appendix will be collected using a web-based format (Microsoft Forms) to allow for a more streamlined compilation of data for producing reports.

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 on this form would impede ORR from performing its charged duty of developing and implementing an Individualized Section 504 Service Plan for any child in ORR custody identified as having one or more disabilities. Furthermore, all grantees and contractors funded to provide services to these children are required in writing to comply with all ORR regulations, policies, procedures, and other guidance, which includes collecting the information in this instrument.

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

This form may be completed more than quarterly under circumstances specified in the settlement (Section II (B)(11)(A) Lucas R. et al v. Becerra et al (Case No. 2:18-CV-05741 DMG PLA), UAC Policy Guide Section 1.4.2 30-Day Restrictive Placement Care Review, and UAC Policy Guide Section 3.8.3 Individualized Section 504 Service Plan.

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 July 25, 2024, Volume 89, Number 143, pages 60428-60429, and provided a sixty-day period for public comment. During the notice and comment period, a response was received from one commenter, containing multiple comments. Attachment A provides a summary of those comments and ORR’s responses. 

9. Explanation of Any Payment or Gift to Respondents

No payment or gift will be provided to the respondents.

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 modified system of records notice, titled 09-80-0321 ORR Unaccompanied Children Bureau (UCB) Administrative Program Records, was published on December 12, 2024, at 89 FR 100500.

11. Justification for Sensitive Questions

Sensitive information may be collected in the Individual 504 Service Plan (Form S-25) in order for ORR to develop individualized care for children with disabilities. ORR does not ask for any information of a sensitive nature beyond what is needed to develop the plan and provide services to the child.

12. Estimates of Annualized Burden Hours and Costs

The following factors were used to estimate burden hours and cost to respondent:

• The actual number of referrals to ORR custody, transfers within the ORR care provider network, and discharges from ORR custody from March 2023 to February 2024.

• ORR funds approximately 300 care provider grantees.

• The cost to respondents was calculated using median hourly wage data from April 2024 (accessed February 2025) for the Bureau of Labor Statistics (BLS) job code 21-1021 Child, Family, and School Social Workers in the industry of Other Residential Care Facilities. The rate was multiplied by two to account for fringe benefits and overhead – $28.46 ´ 2 = $56.92

Form	Annual Number of Respondents	Number of Responses per Respondent	Average Burden Hours per Response	Annual Total Burden Hours	Average Hourly Wage	Total Annual Cost
Individual 504 Service Plan (Form S-25) – Child	2,000	1	2.00	4,000	0.00	0.00
Individual 504 Service Plan (Form S-25) – Care Provider Case Manager	300	7	3.00	6,300	56.92	341,520
Estimated Annual Burden Hours and Costs Total:				10,000	-	341,520.00

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

There are no other costs to respondents and record keepers.

14. Annualized Cost to the Federal Government

The annualized cost estimate for each of these instruments considers the time of a step 1 GS-12 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 instruments as those systems are already in place. The hourly rate was multiplied by two to account for fringe benefits and overhead.

Form	Annual Number of Federal Staff	Number of Reviews per Federal Staff	Average Federal Staff Burden Hours per Review	Annual Total Federal Staff Burden Hours		Average Federal Staff Hourly Wage	Annual Total Federal Staff Cost
Individual 504 Service Plan (Form S-25)	110	18	3.0	5,940		97.18	577,249.20
Estimated Annual Burden Hours and Costs Total:				5,940	-		577,249.20

15. Explanation for Program Changes or Adjustments

This is a new information collection.

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.