NonSub Change - Form P-2

To: Kelsi Feltz

Office of Information and Regulatory Affairs (OIRA)

Office of Management and Budget (OMB)

From: Kristie Ross

Office of Refugee Resettlement (ORR) 

Administration for Children and Families (ACF)

Date: January 12, 2026

Subject: Non-Substantive Change Request – Placement and Transfer of Unaccompanied Children into ORR Care Provider Facilities (OMB #0970-0554)

This memo requests approval of non-substantive changes to the approved information collection, Placement and Transfer of Unaccompanied Children into ORR Care Provider Facilities (OMB #0970-0554).  

Background

The “Placement and Transfer of Unaccompanied Children into ORR Care Provider Facilities” information collection contains 20 instruments that 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 as required by the Homeland Security Act (6 U.S.C. 279) and the Trafficking Victims Protection Reauthorization Act of 2008 (8 U.S.C. 1232). The collection was last approved by OMB on June 12, 2023, with an emergency request related to two forms approved in September 2025. The current expiration date is February 28, 2026.   

 

ORR is proposing revisions to one form in this collection, the Authorization for Medical, Dental, and Mental Health Care (Form P-2).

The purpose of the Authorization for Medical, Dental and Mental Health Care (Form P-2) is to inform the treating healthcare provider that the care provider program has the authority, on behalf of ORR, to provide consent for certain healthcare services for unaccompanied alien children and to collect the child’s health records for these services. In addition, the form explains the reimbursement procedure for the submission of healthcare claims.

The approved version of the Authorization for Medical, Dental and Mental Health Care (Form P-2) is not consistent with ORR’s current consent policies, guidance on required healthcare services, and reimbursement processes. The lack of alignment has caused confusion in the healthcare community and a delay in reimbursement of services.

Overview of Requested Changes

There were no changes to information requested. All changes were made to clarify intent and purpose of the form. Changes include the following:

• Headers have been renamed,

• Language regarding consent for various healthcare services has been simplified and consolidated into one section to ease readability,

• Outdated content regarding required healthcare services has been removed,

• Background and procedural information about financial responsibility and claims submission have been added, and

• Content specific to care provider programs has been removed as the audience for this form is the treating healthcare provider.

Time Sensitivities

To ensure children receive timely services and that treating healthcare providers are aware of ORR’s expectations for release of health records and claims reimbursement, ORR must replace the form as soon as possible.