ORR Unaccompanied Children Bureau Policy Guide: Section 6

6.1 Overview of Post-Release Services

After the Office of Refugee Resettlement (ORR) releases an unaccompanied child¹from its care and custody to a sponsor, ORR offers post-release services (PRS). PRS provide support for children transitioning into their new communities. ORR’s PRS program is governed by the William Wilberforce Trafficking Victims Protection Reauthorization Act of 2008 (TVPRA) (PDF) (8 USC § 1232(c)(3)(B)), the Homeland Security Act of 2002 (6 U.S.C. § 279), and the Unaccompanied Children Program Foundational Rule (45 C.F.R. § 410.1210). To the extent that ORR determines appropriations are available, and in its discretion, ORR may offer PRS for all children released to a sponsor. ORR is legally mandated to offer PRS in cases where the child’s sponsor was subject to a mandatory home study by the Trafficking Victims Protection Reauthorization Act of 2008 (TVPRA) (PDF).² In addition to TVPRA legally-mandated PRS, the Unaccompanied Children Program Foundational Rule (45 C.F.R. § 410.1204(b)) and ORR policy further require ORR to offer PRS for all children released following home studies (see Section 2.4.2 Home Study Requirement).

ORR provides three (3) levels of PRS:

• Level One (1) — Virtual Check-ins;
• Level Two (2) — Case Management Services - referrals and connection to community resources; and
• Level Three (3) — Intensive Engagements — intensive services for specific challenges or special circumstances (e.g., medically or psychologically vulnerable children, family conflict or crisis, education-related issues, etc.).

These services are offered by a network of ORR-funded providers across the United States. ORR requires the use of evidence-based child welfare best practices that are culturally- and linguistically- appropriate to the unique needs of each child and are grounded in a trauma-informed approach. PRS providers may help released children find and access legal services, education and English language classes, health services, positive youth programming, and more.

Children released from the care and custody of ORR into the community need physical and emotional safety; access to services and support that meet their individual needs and allow them to cultivate and preserve family and community relationships; and protection from abuse, abandonment, neglect, and other harm.

PRS providers are responsible for assessing for safety and providing psychoeducation to released children and their sponsor families on the impact of prolonged separation from their families, significant changes to family composition and functioning, trauma from community or family violence, and more in order to maintain a safe and stable home.

At each level of PRS, the PRS provider must ensure that all required contacts with the released child and sponsor are conducted both individually and together, unless the child’s Category 2A, 2B, or 3 sponsor chooses to disengage from these services (see Section 2.2.1 Identification of Qualified Sponsors). Once a child is released to a sponsor, they are no longer in ORR custody; as such, their participation in PRS is not mandatory. If a child’s Category 2A, 2B, or 3 sponsor chooses to disengage from PRS and the child wishes to continue receiving PRS, ORR may continue to make PRS available to the child through coordination between the PRS provider and the ORR/Project Officer (ORR/PO). Similarly, if a child does not wish to engage with PRS and their sponsor wishes to continue receiving these services to support the child’s transition into their new community, ORR may continue to make PRS available. In any circumstance where a released child is at risk of harm or there is a present safety concern, the PRS provider must submit a Notification of Concern to ORR (see Section 6.8.6 Notifications of Concern). Additional details on types of harm, including human trafficking, abuse, disappearance, organized crime, and special circumstances, that warrant a Notification of Concern can be found in Section 6.8.6.

In all cases, PRS may be provided for the pendency of the released child’s immigration case but must end when the child turns 18 years of age, is granted voluntary departure or lawful immigration status, or leaves the United States pursuant to a final order of removal, whichever occurs first.

Revised 01/13/2025

 

6.2 PRS Service Provision Policies

This section details eligibility requirements and the levels of post-release services (PRS), as well as policies for PRS Providers. “PRS” encompasses three (3) levels of support:

1. Level One (1) - Virtual Check-ins (see Section 6.3)
2. Level Two (2) - Case Management Services (see Section 6.4)
3. Level Three (3) - Intensive Engagements (see Section 6.5)

A released child may move between levels of PRS depending on the needs and circumstances of the child and their sponsor family, as determined by the PRS provider through regular and repeated assessments. If the PRS provider determines, after a thorough assessment, that a child and their sponsor should receive a higher or lower level of PRS than they are receiving, the PRS provider must make the referral internally within its own organization. If the PRS provider lacks capacity to accept a higher or lower referral, the PRS provider facilitates the transfer of the case to another provider within the PRS network with capacity to accept the higher or lower referral to avoid service disruption.

Revised 01/13/2025

 

6.2.1 Referrals and Eligibility

ORR may fund post-release services for any child released from the care and custody of ORR to a sponsor. The ORR care provider makes referrals to PRS while the child is still in ORR’s custody. ORR will determine the appropriate level for which to refer all children to PRS ( i.e., Level One (1), Two (2), and/or Three (3)) depending on the needs and the circumstances of the case—and makes PRS referrals accordingly. United States citizens are ineligible for PRS. Therefore, if an unaccompanied child in ORR custody has a child born in the United States, the parenting unaccompanied child may be offered PRS, including to assist them with providing support for their child as they transition into their new community, but ORR will not make a separate PRS referral for their United States citizen child.  

For cases where ORR is TVPRA legally-mandated to offer PRS, children will be referred automatically for Level Two (2) — Case Management Services or Level Three (3) — Intensive Engagements. In addition, all children described in Section 6.2.11 Services for Children Requiring Special Consideration require special consideration of their case-specific needs and will be referred for Level Two (2) — Case Management Services or possibly Level Three (3) — Intensive Engagements. 

ORR will not delay the release of the child if there is a referral delay or a waitlist for PRS, unless there is a determination that the sponsor requires support from PRS to suitably care for identified needs of the child at the time of release. If there is a waitlist for referrals of TVPRA legally-mandated PRS for children to receive Level Two (2) and/or Level Three (3) PRS, ORR will release the affected children and the PRS provider will offer the children Level One (1) PRS — Virtual Check-ins until the PRS provider has capacity to provide Level Two (2) and/or Three (3) PRS (see Section 6.2.2 Prioritization of Services).

ORR may, at its discretion, also refer a released child to PRS at any point during the pendency of the child’s immigration case and while the child is under age 18, if ORR becomes aware (e.g., through a Notification of Concern (NOC), or a call to the ORR National Call Center) of a situation warranting such referral. In such an event, ORR requires the relevant PRS provider to follow up with the child and assess what level of PRS would be appropriate.

Revised 01/13/2025
 

6.2.2 Prioritization of Services

In times where there is a high volume of referrals (including but not limited to times of influx) for post-release services (PRS) and ORR has created a waitlist as a result, providers will prioritize accepting PRS referrals in the following order: 

1. Tender-age children (0-12 years of age) who meet criteria to receive TVPRA legally-mandated PRS;
2. Children turning 18 years of age within two (2) months who meet criteria to receive TVPRA legally-mandated PRS;
3. Children 13-17 years of age who meet criteria to receive TVPRA legally-mandated PRS;
4. All other tender-age children (0-12 years of age);
5. All other children turning 18 years of age within two (2) months; and
6. All other children (13-17 years of age).

ORR reserves the right to direct providers to accept PRS referrals outside of the order listed above, and/or to offer children Level One (1) PRS — Virtual Check-ins, based on emergent needs, unique circumstances, or identified issues.

If there is a waitlist for referrals of TVPRA legally-mandated PRS for children to receive Level Two (2) PRS, children will be offered Level One (1) PRS — Virtual Check-ins while they are pending referral acceptance for Level Two (2). If there is a waitlist for referrals of TVPRA legally-mandated PRS for children to receive Level Three (3) PRS, children will be offered the highest available level of PRS, either Level One (1) or Level Two (2), while they are pending referral acceptance for Level Three (3).

Revised 01/13/2025

 

6.2.3 Assessments

ORR determines the appropriate level for which to refer children to post-release services (PRS) depending on the needs and the circumstances of the case. PRS providers are then responsible for conducting regular and repeated assessments of the released child and sponsor to affirm the level and intensity of PRS that should be provided in direct response to the released child’s and sponsor’s needs. For Level One (1) PRS, the PRS provider assesses whether the child is healthy and safe and whether the child needs a higher level of PRS. For Level Two (2) and Level Three (3) PRS, the PRS provider must conduct an age-appropriate comprehensive assessment to understand the levels of need for the following: sponsor family functioning, legal services, education, medical care, behavioral healthcare (including services for substance use disorder prevention and treatment, mental health, and overall well-being), support appropriate for a child’s personal belief system, healthy relationships, food and material goods security (e.g., adequate clothing for each season), transportation, housing, and any special circumstance.

If the PRS provider determines, after a thorough assessment, that a child and their sponsor should receive a higher or lower level of PRS than they are receiving, the PRS provider must make the referral internally within its own organization, so children and their sponsors seamlessly scale the different PRS levels after each assessment. If the PRS provider lacks capacity to accept a higher or lower referral, the PRS provider facilitates the transfer of the case to another provider within the PRS network with capacity to accept the higher or lower referral to avoid service disruption.

Typically, the assessment is started during the first virtual check-in or in-person visit and then at periodic intervals as determined by the PRS provider’s policies. The assessment must be developmentally appropriate, trauma-informed, and focused on the needs of the child and sponsor. The assessment must be documented in the released child’s PRS case file.

PRS providers must also assess the sponsors’ ability to access community resources and review the Sponsor Care Agreement with them to ensure their understanding and commitment to its provisions.

Revised 01/13/2025

 

6.2.4 Assessing Risk and Protective Factors in Children

After ORR’s determination of the appropriate level for which to refer children to post-release services (PRS), PRS providers are responsible for regularly and repeatedly assessing risk and protective factors in released children to inform their service provision. PRS providers educate children and their sponsor families on identifying risks and red flags that may lead to child exploitation; sex trafficking and labor trafficking; substance use disorder; physical, emotional, or sexual abuse³; neglect; coercion by gangs or gang affiliation; or other situations where the child would be in danger or at risk of harm. PRS providers must also work with the child and sponsor to identify their unique protective factors and tailor PRS accordingly, with the goals of building up the child’s resilience, fostering well-being, and promoting healthy development.

In any circumstance where a released child is at risk of harm or there is a present safety concern, the PRS provider must submit a Notification of Concern (NOC) to ORR (see Section 6.8.6 Notifications of Concern). Additional details on types of harm, including human trafficking, abuse, neglect, disappearance, organized crime, fraud, and special circumstances, that warrant a NOC, can be found in Section 6.8.6.

In the event that the PRS provider cannot reach the child or sponsor family, and there is a safety concern related to potential child abuse, maltreatment, or neglect, the PRS provider must follow the mandated reporter guidelines for the locality in which they are providing services, which may involve contacting local law enforcement and requesting a well-being check on the child, in addition to submitting a NOC.

For Level Two (2) and Level Three (3) PRS, PRS providers assist released children in accessing and connecting with the core community-based services listed below (see Section 6.2.5-6.2.13). If the PRS providers identify a need for these services at Level One (1) PRS, they refer the child for Level Two (2) or Level Three (3) PRS.

Revised 01/13/2025

 

6.2.5 Finding and Accessing Legal Services

Post-release services (PRS) case managers ensure the sponsor has a plan for the child to attend all immigration proceedings and educate the child and sponsor family on compliance with DHS requirements.

PRS case managers also assist sponsors and released children in accessing legal services, including for immigration matters and/or juvenile justice issues, if needed.

For sponsors who do not have legal guardianship of the children in their care, the PRS case manager shall provide information about the benefits of obtaining legal guardianship. If the sponsor is interested in becoming the child’s legal guardian, the PRS case manager refers them to legal services that can assist with the process of establishing legal guardianship with a local court in a reasonable timeframe, according to the Sponsor Care Agreement (see Section 2.8.1 After Care Planning). Legal guardianship establishes a legal relationship between sponsor (who is not the parent or legal guardian) and the released child and allows for the sponsor to make certain decisions for the child under their care.

ORR may fund legal service providers to provide direct immigration legal representation and other related legal services for unaccompanied children, including children released to a sponsor, subject to the availability of appropriations and insofar as it is not practicable for ORR to secure pro bono representation (see Section 3.7.2 Direct Legal Representation).

Revised 01/13/2025

 

6.2.6 Education and English Language Classes

Post release service (PRS) case managers work with unaccompanied children, their sponsors, and community stakeholders to create a seamless transition into local schools and non-formal education programs. The PRS case manager assesses the child’s education-related needs and addresses any challenges to their academic goals and right to a free public education.

PRS case managers support unaccompanied children’s continuity of education by:

1. Liaising between the school and family to assist sponsors with school enrollment and other administrative procedures.
2. Educating the child and their sponsor on the child’s rights to education.
3. Ensuring the child, sponsor, and school have access to the required documentation for enrollment including vaccination records, ORR records (e.g., Verification of Release (VOR) form), and prior education records (if needed and available), including from home country schools and education records generated while in ORR care.
4. Reviewing the child’s educational progress and psychosocial well-being in school and connecting the child and their sponsor to school and community resources to address specific learning needs (e.g., English as a Second Language programs, high school equivalency/GED courses, community college, after-school tutoring, school counselor or social worker, etc.).
5. Obtaining evaluations for children reasonably suspected of having a disability to determine their eligibility for special education and/or reasonable modifications, accommodations, auxiliary aids, and related services.

Revised 01/13/2025

 

6.2.7 Health Services

Released children may require healthcare services including primary pediatric care, physical therapy, dental services, mental or behavioral health services, services for substance use disorder prevention and treatment, individual or family counseling, treatment for behavior disorders, or other specialized services, such as pre- or postnatal care. Post-release services (PRS) case managers must assess for the health needs of released children by applying understanding of the physical and psychological impacts of forced displacement, migration, and childhood trauma, as well as the stages of child and adolescent development.

PRS case managers must inform released children and sponsor families of medical insurance options, including supplemental coverage, and assist the sponsor in obtaining medical insurance for the child, if available, so that the family is able to effectively manage the child’s health-related needs.

PRS case managers must assist the sponsor in locating healthcare providers that meet the individual needs of the child and the sponsor (e.g., medical, dental, behavioral health, and mental health service providers). PRS case managers do this by providing information, resources, and referrals to services relevant to the individual needs and health-related considerations for the child, including community health centers and healthcare providers. If the child requires specialized assistance, the PRS case manager shall assist the sponsor in making and keeping appointments and monitoring the child's health requirements. The PRS case manager, when appropriate and as needed, acts as a liaison between the healthcare provider, facilitating communication about the child’s prescribed treatment plan and appointments.

Trauma

Released children require special consideration as children with a history of adverse childhood experiences,⁴  that may include separation from family, exposure to household and community violence, torture,⁵ neglect, sexual abuse, and other traumatic experiences. PRS case managers may need to connect them, along with their sponsor family, with specialized services and provide psychoeducation on trauma and on the short- and long-term effects of ACEs on the child and family.

Pregnant or Parenting Children

PRS case managers must assist released children who are pregnant or parenting with enrollment in medical insurance, as eligible and applicable under State statute, and provide referrals to community-based resources to support the released child with birthing, parenting, breastfeeding, childcare, early childhood development, Head Start or other appropriate school enrollment, and early intervention planning, as applicable, based on their assessed needs. If the child is eligible, the PRS case manager must also assist with enrollment in the Special Supplemental Nutrition Program for Women, Infants and Children (WIC). The PRS case manager may also assist with applying for a passport for the released child’s baby.

Revised 01/13/2025

 

6.2.8 Youth Programming 

Post-release services (PRS) case managers assist released children in accessing youth activities in their schools, places of worship, or in the community to help them create connections in their new communities and learn how to build safe and healthy relationships with others.

PRS case managers may refer and connect released children to youth mentoring, tutoring, afterschool and vocational programs, sports clubs, STEM (science, technology, engineering, math) clubs, art and drama classes, volunteer opportunities, and other programming as appropriate to the child’s age, needs, and interests.

Revised 01/13/2025

 

6.2.9 Services Related to Cultural and Other Traditions

Released children represent a rich array of cultures, traditions, practices, and beliefs. Post-release services (PRS) case managers may help connect children with communities, social groups, and activities that foster the growth of their personal beliefs and practices and that celebrate their cultural heritage.

Revised 01/13/2025
 

6.2.10 Supporting Integration and Independence

Post-release services (PRS) case managers must provide a comprehensive orientation to released children on their new communities, including providing information to help them navigate their new communities safely (e.g., using public transportation, how and when to contact the police, where to find the nearest emergency room, how to access community spaces, safety laws and rules, etc.).

For released adolescents who are approaching or at the minimum age for employment and have legal authorization to work in the United States, PRS case managers must provide guidance on employment rights and laws, job readiness (e.g., applying for jobs and filling out job applications), workforce development trainings, and basic financial literacy.

For those who will soon age out of ORR’s PRS program when they turn 18 years, PRS case managers will work cooperatively with the child on a post-18 transition plan and help to educate them on the rights, responsibilities, and opportunities of adulthood in the United States.

Revised 01/13/2025
 

6.2.11 Services for Children Requiring Special Consideration

All children described below require special consideration of their case-specific needs and will be referred for Level Two (2) and possibly Level Three (3) post-release services (PRS). Children described below should be presumed to require Level Two (2) or Level Three (3) PRS, and that presumption can only be overcome following a case-by-case review and determination that such a child only needs Level One (1) PRS. PRS providers should clearly document their reasoning in these instances and never provide only Level One (1) PRS due to lack of resources.

Children with Individualized Needs

A child with individualized needs is a child whose mental and/or physical condition requires special services and/or treatment by PRS providers. A released child’s individualized needs may be due to drug or alcohol use, serious behavioral or emotional impairments, mental illness, intellectual disability, or a physical condition or chronic illness that requires special services or treatment. A released child who has suffered serious neglect, abuse, or other harm may also be considered to have individualized needs if the child requires specialized services or treatment as a result of long-term impacts of trauma.

Children with Disabilities

Children with disabilities, as defined by section 3 of the Americans with Disabilities Act of 1990 (42 U.S.C. 12102), must have an equal opportunity to participate in PRS so that they may receive referrals and connection to appropriate services in their communities. All PRS providers who serve children with disabilities must make reasonable modifications in their policies, practices, and procedures if needed to enable released children with disabilities to access PRS services, as is consistent with Section 504 of the Rehabilitation Act of 1973.⁶ 

LGBTQI+ Children

ORR recognizes that lesbian, gay, bisexual, transgender, queer, questioning, intersex (LGBTQI+) and gender non-conforming or nonbinary children may have unique needs and concerns or require access to specialized services, all of which should be addressed as part of their PRS care. PRS providers must treat released children who identify as LGBTQI+ and/or gender non-conforming or nonbinary fairly and provide inclusive, safe, and nondiscriminatory services. PRS providers may not refer LGBTQI+ and gender non-conforming or nonbinary children in their caseload to sexual orientation and gender identity (SOGI) change efforts. (See Section 3.5.6 Prohibition on Sexual Orientation and Gender Identity Change Efforts.) PRS providers must maintain the privacy and confidentiality of information concerning the sexual orientation and the gender identity of children in their caseload. (See Section 5.10 Information Sharing) ORR requires PRS providers to use the child’s chosen name and pronouns in accordance with the child’s self-determined gender identity.

Adjudicated Children and Children at High Risk of Involvement with the Juvenile Justice System

An adjudicated child is one who has been found guilty by a judge in a State juvenile court of committing an act that would be considered a crime if performed by an adult. (Please refer to the U.S. Department of Justice’s Office of Juvenile Justice and Delinquency Prevention for more information on the juvenile justice system and its definitions).

PRS providers must ensure adjudicated children receiving PRS receive a specialized case management approach that focuses on the following protective factors: building supportive family relationships, healthy friendships, academic achievement, self-esteem, and empathy. In addition to community-based services, PRS providers, if appropriate, must refer and attempt to connect adjudicated children, and those at risk of entering the juvenile justice system, to organizations that use evidence-based practices aimed at the following: delinquency prevention, gang prevention or intervention, substance abuse prevention or treatment, mentoring, anger management, stress reduction, conflict resolution, family counseling, recovery from childhood trauma, rehabilitation services, if available, and/or other similar services.

PRS case managers should review the terms of any parole or probation, court-ordered services, and any restraining orders or orders of protection so that the child understands what is required to remain in full compliance and to reduce the chances of recidivism. 

Separated Children

Under a Settlement Agreement reached in Ms. L. v. U.S. Immigr. & Customs Enf't ("ICE"), No. 18-cv-00428 (S.D. Cal. filed Feb. 26, 2018), children who were separated from their parents or legal guardians at the U.S. — Mexico border, and eligible family members, as settlement class members, may be eligible to receive federally-funded family reunification services (e.g., mental health treatment and other services) to address the effects of their forced separation. As applicable, ORR’s PRS providers should help separated children and their families connect with the contractor that is coordinating and implementing services for separated children and their families via www.together.gov or www.juntos.gov .

Human Trafficking

Children who are victims of human trafficking are eligible for certain services offered by the Office on Trafficking in Persons (OTIP) authorized by the Trafficking Victims Protection Reauthorization Act of 2008 (TVPRA)   (PDF) (PDF). OTIP issues Eligibility Letters and Interim Assistance Letters (as described in Section 3.3.3 Screening for Child Trafficking and Services for Victims) to eligible children, allowing them to access trafficking-specific case management services, medical services, food assistance, cash assistance, health insurance, and other services available to refugees. PRS providers should assist released children who have already received an eligibility or interim assistance letter with accessing services available to trafficking victims. If a PRS provider suspects a child has been a trafficking victim and they were not already referred to OTIP, the PRS provider should assist the released child with applying for an OTIP Eligibility Letter and accessing the services provided. For more information about the program, please visit www.acf.hhs.gov/otip/victim-assistance/child-eligibility-letters; and the Child Eligibility Handout: https://www.acf.hhs.gov/sites/default/files/documents/otip/child_eligibility_handout.pdf (PDF) .

Parolees

Children who entered the United States following a special operation (such as the Operation Allies Welcome) may have lawful presence in the United States, such as humanitarian parole, without lawful immigration status. PRS may be provided while the child seeks lawful immigration status. The PRS provider must consider the unique needs and eligibility of the released child as a parolee and assist with connecting the child with legal services and other benefits. In some cases, refugee benefits may be extended to these categories of released children. PRS providers should coordinate with their Project Officer to understand the types of services available to such children, in addition to referencing ORR’s policies, procedures, and additional guidance.

Chronically Absent or Retained Children

For unaccompanied children enrolled in school who are chronically absent or retained at the end of their school year, the PRS provider conducts an age-appropriate comprehensive assessment to understand needs and underlying issues impacting school attendance and academic achievement. As applicable, the case manager educates the child and sponsor family on educational supports (e.g., special education services) and school requirements, serves as a liaison between the family and the school, and offers additional referrals and resources to address underlying issues (e.g., after-school tutoring, school counselor, school social worker, transportation, medical and/or behavioral healthcare, etc.) (See Section 6.2.6 Education and English Language Classes).

Revised 01/13/2025

 

6.2.12 Innovative Strategies and Evidence-Based Interventions 

ORR encourages Post-Release Services (PRS) providers to create opportunities to regularly meet with other PRS providers to share emerging, promising, and best practices and innovative strategies for working with released unaccompanied children. ORR requires the use of evidence-based child welfare best practices that are culturally- and linguistically- appropriate to the unique needs of each child and are grounded in a trauma-informed approach. The goal of evidence-based PRS service provision is to improve outcomes for children across all life domains as they form new relationships and settle into their new homes and communities. 

Revised 01/13/2025
 

6.2.13 Interpretation

Interpretation refers to the oral exchange of information and communication between two (2) or more parties from one language into another.

Post-Release Services (PRS) providers must make every effort to conduct PRS in the preferred language of the released child. If the PRS provider is not highly proficient in the child’s preferred language, they must use a qualified interpreter. The PRS provider must refrain from having the child, sponsor, or a family member interpret for them.

Revised 01/13/2025
 

6.3 Level One (1) PRS — Virtual Check-ins

All children released from ORR custody to a sponsor will be referred for Level One (1) post-release services (PRS), except for cases where ORR is TVPRA legally-mandated to offer PRS, for children described in Section 6.2.11 Services for Children Requiring Special Consideration, and for other children determined to need Level Two (2) or Level Three (3) PRS.

For Level One (1) PRS cases, the PRS caseworker conducts three (3) virtual check-ins at seven (7) business days, fourteen (14) business days, and thirty (30) business days after the child’s release from ORR custody to a sponsor. During these three (3) virtual check-ins, the PRS caseworker confirms that the child is residing with the sponsor, is enrolled in and attending school, is aware of upcoming court dates, and is healthy and safe.

PRS caseworkers must document the outcome of each virtual check-in in the child’s PRS case file, including if the PRS caseworker is unable to contact the sponsor or child after reasonable efforts have been exhausted.

If the PRS caseworker discovers that the released child’s placement has been disrupted or is at risk for disruption, or if the child and/or sponsor would benefit from additional support or services, the PRS provider will refer the case internally within its own organization, as appropriate, for Level Two (2) and/or Level Three (3) PRS. If the PRS provider lacks capacity to accept a higher referral, the PRS provider facilitates the transfer of the case to another provider within the PRS network with capacity to accept the higher referral to avoid service disruption.

If the PRS provider believes that the child is unsafe, the PRS provider must comply with mandatory reporting laws, State licensing requirements, and Federal laws and regulations for reporting to local child protective agencies and/or law enforcement. The PRS provider must also submit a Notification of Concern, according to Section 6.8.6 Notifications of Concern.

Case Closure

PRS for Level One (1) cases are terminated under the following conditions:

• the released child turns 18 years of age, is granted voluntary departure or lawful immigration status, or leaves the United States pursuant to a final order of removal; or
• the three (3) virtual check-ins (7-day, 14-day and 30-day) are completed and documented in the child’s PRS case file, and the PRS provider determines that no further PRS are needed; or
• the sponsor of the released child chooses to disengage from these services. If a child’s Category 2A, 2B, or 3 sponsor chooses to disengage from PRS and the child wishes to continue receiving PRS, ORR may continue to make PRS available to the child through coordination between the PRS provider and the assigned ORR Project Officer (PO). In any circumstance where a released child is at risk of harm or there is a present safety concern, the PRS provider must submit a Notification of Concernto ORR (see Section 6.8.6 Notifications of Concern). Additional details on types of harm, including human trafficking, abuse, disappearance, organized crime, and special circumstances, that warrant a Notification of Concern, can be found in Section 6.8.6.

Revised 01/13/2025
 

6.4 Level Two (2) PRS — Case Management Services

For Level Two (2) post-release services (PRS), the PRS case manager provides referrals and connections to community resources for the child and sponsor for six (6) months following referral acceptance or until the PRS case is closed as detailed below. PRS case managers are responsible for conducting assessments, creating strengths-based case management plans, assessing for progress and adherence to their case plan, writing case notes, record-keeping, and referring and connecting children to services in the community, based on the individual needs of the child.

Initial Contact

PRS case managers must make initial contact with the child and/or sponsor for Level Two (2) PRS within two (2) business days of a referral being accepted by the PRS provider. At the point of initial contact, the PRS case manager inquires about the welfare and whereabouts of the released child and sets a time and date for the first in-person visit.

First In-Person Visit

PRS case managers are required to make an in-person visit for Level Two (2) PRS within fourteen (14) business days of referral acceptance. The purpose of this visit is to conduct the initial comprehensive assessment of needs, assess for safety concerns and provide psychoeducation tailored to the child and sponsor’s needs; assess the sponsor’s ability to access community resources; review the Sponsor Care Agreement; and provide an overview of PRS, community-based services, and other resources. The PRS case manager must also inform the child and sponsor that PRS are not mandatory and that their participation in these services is voluntary.

Ongoing Check-Ins and In-Person Visits

Ongoing contact with the released child and sponsor should be determined by the level of need and support required, in consultation with the released child and sponsor. PRS case managers must make monthly visits for six (6) months following referral acceptance or until the case is closed as detailed below. After the first in-person visit, monthly visits may occur in-person or if there are no safety concerns, virtually. At minimum, in-person contact must be established every 90 calendar days.

For engagements that are otherwise required to be in-person, PRS providers may request approval on a case-by-case basis from the ORR/Project Officer (PO) to conduct the engagement virtually in the event of exceptional circumstances where conducting the engagement virtually would be in the best interests of the child.

It is preferrable for in-person visits to be conducted in the child’s home; however, in-person visits may also occur in the PRS provider’s office or a community setting where the child feels comfortable and safe (such as a library, park, eatery, etc.) depending on the circumstances and needs of the family. PRS case managers must document all check-ins and in-person visits, as well as document progress and outcomes of their engagements in the child’s PRS case file.

If the PRS case manager is unable to reach the child or sponsor by phone through reasonable attempts or if the child or sponsor declines an in-person visit, the PRS case manager should document all attempts made and the reasons, if known, for why contact was not made or services were declined (e.g., child is safe and secure and no longer requires services, sponsor’s working schedule conflicts with case manager’s schedule for an in-person visit, etc.).

Referrals to Community Resources

Successful referrals depend on strong communication among the PRS case manager, the service provider, and the released child and their sponsor to establish trust, provide culturally responsive case coordination and care, and resolve barriers.

A PRS case manager must also work with released children and their sponsors so that they will be able to contact the service provider directly; make appointments; communicate effectively with their provider; ask for interpretation services, if needed; and understand the service’s costs, if applicable.

Referrals and their outcomes must be documented in the released child’s PRS case file.

In some Level Two (2) PRS cases, PRS case managers will determine that more targeted intensive case management services are needed and make referrals for Level Three (3) PRS (see Section 6.5 Level Three (3) PRS — Intensive Engagements).

Case Closure

PRS for Level Two (2) cases are terminated under the following conditions:

• the released child turns 18 years of age, is granted voluntary departure or lawful immigration status, or leaves the United States pursuant to a final order of removal; or
• PRS have been provided for six (6) months following referral acceptance (see additional timeframes and requirements for termination of PRS in Section 6.6 TVPRA Legally-Mandated Cases for cases legally mandated by the Trafficking Victims Protection Reauthorization Act of 2008 (TVPRA) (PDF)(PDF)) and a PRS case manager assesses that Level Two (2) PRS are no longer needed; or
• the sponsor of the released child chooses to disengage from these services. If a child’s Category 2A, 2B, or 3 sponsor chooses to disengage from PRS and the child wishes to continue receiving PRS, ORR may continue to make PRS available to the child through coordination between the PRS provider and the assigned ORR Project Officer (PO). In any circumstance where a released child is at risk of harm or there is a present safety concern, the PRS provider must submit a Notification of Concernto ORR (see Section 6.8.6 Notifications of Concern). Additional details on types of harm, including human trafficking, abuse, disappearance, organized crime, and special circumstances, that warrant a Notification of Concern can be found in Section 6.8.6.

Thirty-day extensions of PRS beyond the termination conditions listed above are considered on a case-by-case basis by the PO.

Revised 01/13/2025

 

6.5 Level Three (3) PRS — Intensive In-Home Engagements

Level Three (3) post-release services (PRS) is a high level of intensive services and engagement. Level Three (3) PRS is provided by PRS clinicians to released children and their sponsor families through a trauma-informed, intensive case management approach if a thorough assessment determines that the family needs additional support for specific challenges or special circumstances (e.g., medically or psychologically vulnerable children, family conflict or crisis, education-related issues, etc.). The intent of Level Three (3) PRS is to focus on stabilizing the family unit and the clinical intervention(s) utilized should be tailored to the needs of the family and connect the released child and sponsor family with community-based services to address concerns that require long-term care (such as a mental health diagnosis). While PRS clinicians will generally provide Level Three (3) clinical services, PRS case managers may also provide some Level Three (3) PRS, depending on the needs of the case. Assignment of Level Three (3) PRS at the time of discharge is approved by the ORR/Federal Field Specialist (ORR/FFS). PRS providers should not make a referral to Level Three (3) internally within its own organization prior to completing a thorough assessment.

Initial Contact

A PRS clinician or case manager must make initial contact with the child and/or sponsor for Level Three (3) PRS within two (2) business days of a referral being accepted by the PRS provider or an internal referral to Level Three (3). At the point of initial contact, the PRS clinician or case manager inquires about the welfare and whereabouts of the released child and sets a time and date for the first in-person visit.

Level Three (3) In-Person Visits

The PRS clinician or case manager conducts an initial in-person assessment within seven (7) business days of referral acceptance, followed by weekly in-person contacts for the first 45 to 60 calendar days, depending on the presenting needs of the released child and sponsor family. It is preferrable for in-person visits to be conducted in the child’s home; however, in-person visits may also occur in the PRS provider’s office or a community setting where the child feels comfortable and safe (such as a library, park, eatery, etc.) depending on the circumstances and needs of the family.

Level Three (3) PRS is a targeted clinical intervention for released children and sponsor families in crisis. It involves crisis intervention, safety planning, a focus on family preservation, intensive case management and additional therapeutic support. Trauma-Focused Cognitive Behavioral Therapy (TF-CBT) is the most well-supported and effective treatment for children who have been abused or traumatized, and therefore may be the most appropriate treatment for released children receiving Level Three services. TF-CBT helps children and caregivers process traumatic events and learn skills to promote emotional and behavioral stability.

Children and their sponsor families who need intensive support may be living in uncertain and overwhelming circumstances and may not be aware of or have access to critical services to address their needs. PRS clinicians and case managers must have some expertise in areas where child welfare, immigration, and childhood trauma intersect in order to effectively address issues with the released child and their sponsor family (see Section 6.7.3 Core Competencies and Training Requirements).

Level Three (3) PRS interventions and outcomes must be documented in the released child’s PRS case file.

Additional Contacts

Following the initial period of weekly in-person visits, the PRS clinician or case manager will determine whether the released child and the sponsor can be moved to monthly in-person or virtual contacts, conducted either by the PRS clinician or a PRS case manager. Once monthly contacts begin, they will continue until PRS have been provided for six (6) months from the original PRS referral acceptance. While Level Three (3) PRS is intended to be short-term, it may continue as long as necessary to stabilize the placement and ensure the safety of the child. Thirty-day extensions of PRS beyond the six-month term are considered on a case-by-case basis by the Project Officer.

For Level Three (3) PRS engagements that are required to be in-person, PRS providers may request ORR’s case-by-case approval to conduct the engagement virtually in the event of exceptional circumstances, where conducting the engagement virtually would be in the best interests of the child.

Case Closure

PRS for Level Three (3) cases are terminated under the following conditions:

1) the released child turns 18 years of age, is granted voluntary departure or lawful immigration status, or leaves the United States pursuant to a final order of removal;

2) PRS have been provided for six (6) months following referral acceptance (see additional timeframes and requirements for termination of PRS for Trafficking Victims Protection Reauthorization Act of 2008 (TVPRA) (PDF) (PDF) legally-mandated cases in Section 6.6 TVPRA Legally-Mandated Cases) and a PRS clinician or case manager assesses that Level Three (3) PRS are no longer needed; or

3) the sponsor of the released child chooses to disengage from these services. If a child’s Category 2A, 2B, or 3 sponsor chooses to disengage from PRS and the child wishes to continue receiving PRS, ORR may continue to make PRS available to the child through coordination between the PRS provider and the ORR Project Officer (PO). In any circumstance where a released child is at risk of harm or there is a present safety concern, the PRS provider must submit a Notification of Concern to ORR (see Section 6.8.6 Notifications of Concern). Additional details on types of harm, including human trafficking, abuse, disappearance, organized crime, and special circumstances, that warrant a Notification of Concern, can be found in Section 6.8.6.

Thirty-day extensions of PRS beyond the termination conditions listed above are considered on a case-by-case basis by the Project Officer.

Revised 01/13/2025

6.6 TVPRA Legally-Mandated Cases

The Trafficking Victims Protection Reauthorization Act of 2008 (TVPRA) (PDF) requires ORR to provide post-release services (PRS), during the pendency of removal proceedings, to children for whom a home study was conducted (i.e., where the child is a victim of a severe form of trafficking in persons; the child has a disability as defined by the Americans with Disabilities Act of 1990, as amended (42 U.S.C. § 12102) and requires particularized services or treatment; the child has been a victim of physical or sexual abuse under circumstances that indicate that the child’s health or welfare has been significantly harmed or threatened; or the child’s sponsor clearly presents a risk of abuse, maltreatment, exploitation, or trafficking, to the child based on all available objective evidence.). See Section 2.4.2 Home Study Requirement.

For these cases, the PRS provider must start services within two (2) days of the child’s release from ORR custody. However, ORR does not delay the release of a child if PRS is not immediately available, unless there is a determination that the sponsor requires support from PRS to suitably care for identified needs of the child at the time of release.   

For cases where ORR is legally mandated by TVPRA to offer PRS (see Section 6.2.1), Level Two (2) and/or Three (3) PRS may continue beyond the timeframes noted in Sections 6.4 and 6.5.

For TVPRA -mandated cases, TVPRA requires PRS to be provided during the pendency of an unaccompanied child’s removal proceedings. Based on the needs of the child and case circumstances, PRS will be provided for a portion of or the entirety of the pendency of the immigration proceedings.

For TVPRA legally-mandated cases receiving Level Two (2) or Three (3) PRS, PRS case managers and/or clinicians may request approval on a case-by-case basis from ORR to conduct the engagement virtually in the event of exceptional circumstances where conducting the engagement virtually would be in the best interests of the child. If this approval is granted, after the first in-person visit following referral acceptance, the PRS case manager and/or clinician must nevertheless make at least two (2) additional in-person visits within the first year of the child’s release, at or near six (6) months and one (1) year following release. If a TVPRA legally-mandated case has been active and engaged in services for more than a year and the PRS case manager and/or clinician has assessed that the risk levels with respect to concerns identified at 8 U.S.C. § 1232I(3)(B) are low and there are no other safety concerns (e.g., no concerns related to trafficking, disability-related needs, abuse, maltreatment, or exploitation, acute mental health crisis, placement disruption, etc.), the PRS case manager and/or clinician may limit their check-ins to a quarterly or biannual basis, based on the circumstances of the individual child and sponsor family.

Case Closure

PRS for TVPRA -mandated cases must end if:

1) the released child turns 18 years of age, is granted voluntary departure or lawful immigration status, or leaves the United States pursuant to a final order of removal;

2) after receiving PRS for one (1) year, a PRS provider determines that PRS are no longer needed; or

3) the sponsor of the released child chooses to disengage from these services. If a child’s Category 2A, 2B, or 3 sponsor chooses to disengage from PRS and the child wishes to continue receiving PRS, ORR may continue to make PRS available to the child through coordination between the PRS provider and the ORR Project Officer (PO). In any circumstance where a released child is at risk of harm or there is a present safety concern, the PRS provider must submit a Notification of Concern to ORR (see Section 6.8.6 Notifications of Concern). Additional details on types of harm, including human trafficking, abuse, disappearance, organized crime, and special circumstances, that warrant a Notification of Concern, can be found in Section 6.8.6.

Revised 01/13/2025

 

6.7 Personnel Requirements for Post-Release Providers

6.7.1 Qualifications and Licensure

Post-Release Services (PRS) caseworkers who have direct contact with released children must be at least 21 years of age, highly proficient in the native or preferred language of children in their caseload or have access to qualified interpreters, and have at least one year of experience working with children.

PRS case managers must have at least a bachelor’s degree, ideally in the behavioral sciences, human services or social services fields, and be highly proficient in the native or preferred language of children in their caseload or have access to qualified interpreters. PRS case managers must have knowledge of local community social services and should have specialized experience working with immigrant populations and be knowledgeable about family preservation, kinship care, and/or general child welfare.

PRS case manager supervisors must have a master’s degree in the behavioral sciences, human services or social services fields; or a bachelor’s degree with at least three (3) years of progressive employment experience that demonstrates supervisory and case management experience.

PRS clinicians are responsible for intensive case management and must have a master’s or doctoral degree in social work, psychology, sociology, or other relevant behavioral science in which direct clinical experience is a program requirement; or a bachelor’s degree with at least five (5) years of clinical experience. They may be licensed, or eligible for licensure, and must be highly proficient in the native or preferred language of children in their caseload or have access to qualified interpreters.

Clinical supervisors must have a master’s or doctoral degree in social work, psychology, sociology, or other relevant behavioral science in which clinical experience is a program requirement, plus at least two (2) years of postgraduate direct service experience; or a bachelor’s degree with at least six (6) years of clinical employment experience in the behavioral sciences. Clinical supervisors must have prior supervisory experience and be licensed to provide clinical supervision.

Revised 01/13/2025

 

6.7.2 Background Checks

Post-Release Services (PRS) providers must complete background investigations on all of their staff, contractors, and volunteers. They must successfully complete the following checks with favorable results prior to an offer of employment as a PRS provider or as a volunteer who has direct access to released children:

• An FBI fingerprint check of national and state criminal history repositories;
• A child protective services check with the staff’s State(s) of U.S. residence for the last five (5) years;
• Driver’s record and clearance (if the individual will be transporting children); and
• Background investigation updates at a minimum of every five (5) years of the staff, contractor, or volunteer’s start date or last background investigation update.

Background investigation updates must be favorably adjudicated for the PRS provider to continue direct service provision. ORR and PRS providers may require the updated background investigation more frequently at their discretion.

All results must be kept in the employee’s personnel file.

Revised 01/13/2025
 

6.7.2.1 ORR Required Background Investigations for PRS Providers

Q1: At a minimum, what must the ORR required background investigation for PRS providers include?  
A1: ORR background investigations for PRS providers must include:   

• An FBI fingerprint check of national and state criminal history repositories;  
• A child abuse and neglect registry check (aka child protective services check) with the staff’s State(s) of U.S. residence for the last five (5) years;  
• Sex offender registry check conducted through the U.S. Department of Justice National Sex Offender Public Website;   
• Driver’s record and clearance (if the individual will be transporting children)
• All State required background check criteria; and  
• Background investigation updates at a minimum of every five (5) years of the staff/contractor/volunteer’s start date or last background investigation update. ORR and PRS providers may require the updated background investigation more frequently at their discretion.    

ORR recognizes that in some instances PRS provider staff, contractors, and volunteers may support different care providers and PRS providers within the same state. If an individual has already completed and passed the relevant State background checks and begins to work or volunteer at another care provider or PRS provider in that same state within five (5) years, then that individual can request that a copy of the previously completed background checks be provided to the subsequent care provider or PRS provider at which the individual is going to work. PRS providers are still expected to conduct reference checks with the previous provider(s) with which the individual worked as part of their screening process before onboarding the individual.    

PRS providers must notify ORR’s Prevention of Sexual Abuse Coordinator (PSAC) in writing if they are unable to complete all the required background investigation components. ORR will work with the PRS provider to ensure that background checks are completed.  

If State law or licensing requirements do not require a national criminal history fingerprint check, the PRS provider must complete the fingerprint check using a public or private vendor or the U.S. Department of Health and Human Services’ Program Support Center (HHS/PSC). PRS providers should contact their ORR/Project Officer (PO) or Contract Officer Representative for additional information regarding HHS/PSC capacity to support fingerprint checks. If there is an additional cost associated with this fingerprint check process, the PRS provider may include the cost in its budget plan.  

Q2: Who must undergo an ORR required background investigation?  
A2: PRS providers must ensure candidates for employment undergo a background investigation prior to hiring to determine whether the applicant is eligible to work with children. If State law or licensing regulations prohibit a PRS provider from conducting background checks before hiring an applicant, the PRS provider must notify ORR’s Prevention of Sexual Abuse Coordinator and provide documentation of the State law or licensing requirement.  
  
The following individuals must complete ORR required background checks before they are hired and gain access to children:  

• All executive, program management, and administrative staff with direct access to children;  
• All of the PRS provider’s temporary, part-time, or full-time employees, contractors, and sub-contractors with direct access to children;  
• Anyone who has unsupervised, direct access to children, including volunteers;  

Posted 01/13/2025

6.7.2.2 Considerations Regarding Child Abuse and Neglect Background Checks for PRS Providers

ORR has procedures in place to help PRS providers navigate circumstances in which child abuse/neglect (CA/N) check results are delayed or impossible to obtain.

ORR PRS providers are permitted to onboard prospective personnel (staff, contractors, and volunteers) on a provisional basis—and subsequently transition them off of their supervision plan—during the pendency of CA/N checks when, and only when, the following conditions are met: 

1. The individual whose CA/N checks have been requested has already completed and passed an FBI fingerprint background check and the PRS provider furnishes to ORR documented, unsuccessful attempts to obtain the required CA/N checks from any and all relevant states of residence (where possible/applicable) over the previous five (5) years for a period of 30 calendar days;   
2. The prospective candidate also furnishes documented, unsuccessful attempts to obtain the required CA/N check on their own behalf from the relevant states of residence (where possible/applicable) over the previous five (5) years, for a period of 30 calendar days; this includes instances where the State furnishes CA/N check results that indicate the results may not be used for employment purposes; 
3. There is no reasonable basis to believe that the individual will have background check history that would make them ineligible to work with children (note, however, that individuals who refuse to initiate background checks are ineligible for any access to children);
4. The hiring need is urgent because the PRS provider has been unable to meet its fully funded case capacity; there is an emergency or influx; or because, in ORR’s judgment, the position has been vacant for a prolonged period of time; 
5. The PRS provider furnishes ORR with a detailed plan on how the prospective candidate will work for 30 calendar days on a provisional basis. For candidates requiring direct access to children, the plan will describe how the prospective candidate will work under the direct, line-of-sight supervision and control of another staff member who has completed all background checks, subject to the restrictions of 45 C.F.R. 411.14(d), has at least one (1) year of experience in child welfare, is not in a position subordinate to the candidate, and is not subject to any serious or pending personnel infractions that compromise their ability to safely supervise others. The PRS provider explains how the provisional personnel will be prevented from unsupervised direct access to children in the supervision plan, obtains ORR’s approval for the supervision plan, and maintains the approved supervision plan in the relevant personnel files;
6. If the provisional personnel has successfully worked under the approved supervision plan for a period of 30 calendar days without any allegations of child abuse or code of ethics violations—and has not otherwise shown any indication of unsuitability for working with children—the provisional personnel may transition to working at the PRS provider on a permanent, unsupervised basis;
   1. The PRS provider must check in with ORR at the conclusion of the provisional 30-day period to request explicit approval from ORR to transition the provisional personnel off of their approved supervision plan. The PRS provider must furnish a detailed formal evaluation of the provisional personnel’s performance and basis for recommending transitioning them off of their supervision plan. The decision to transition the provisional personnel will be collaboratively decided by the individual who supervised the provisional personnel, another hiring manager or supervisor who was not involved in overseeing the provisional personnel, and the assigned Project Officer or other relevant ORR staff;
7. The provider requires the provisional personnel to submit a notarized attestation declaring that they are not the subject of any pending investigation or substantiated allegation of child abuse or neglect, sexual abuse, or sexual harassment in any state, and the PRS provider retains the document in the individual’s personnel file;
8. The provisional personnel has otherwise met all other ORR policy requirements, all other applicable federal requirements, and all terms of the Cooperative Agreement applicable to onboarding new staff prior to them having supervised access to children including, but not limited to, completing required training and adhering to the PRS provider code of ethics;
9. The PRS provider updates the personnel file with the completed CA/N check results if they are received;
10. The PRS provider ensures that each and every single element described above has been satisfied and documented in the candidate’s personnel file; and
11. The arrangement is permitted by applicable state licensing requirements.

NOTE: The above process likewise applies to PRS providers seeking to onboard prospective personnel—and subsequently transition them off of their supervision plan—in situations where the relevant state(s) do not provide CA/N check results at all.

Posted 01/13/2025

6.7.2.3 Suitability Determination Investigation for PRS Providers

Q1: What do suitability determination investigations include?   

A1: Suitability determination investigations are an inquiry into a person's identifiable character traits and conduct sufficient to determine whether an individual's employment or continued employment would promote the efficiency and protect the integrity of service to the federal government or federally funded agency. Individual positions are designated at a risk level as determined by the position’s potential for adverse impact on the efficiency and integrity of the service. A suitability determination investigation reviews documentation beyond what is typically included in an FBI background check and CA/N check and is designed to ensure that the hired person is reliable, trustworthy, and of good character.   

The kind of investigation conducted for a suitability determination varies based on the level of sensitivity and risk. The minimum investigation entails a National Agency Check, law enforcement check, records search, credit check, and written inquiries of previous/current employers, education, residence, and references. Suitability determination investigations may also include a childcare background check, when not duplicative to other ORR required background checks.

Adjudication is the evaluation of whether a person is suitable to work for or on behalf of the federal government, resulting in a favorable or unfavorable determination of their employment suitability.    

Q2: Who must undergo a suitability determination investigation?   

A2: Federal, contracted, grantee, and sub-recipient personnel providing services for or on behalf of ORR must undergo a suitability determination investigation commensurate to their position’s risk designation. This is regardless of access to children.  

Contracted, grantee, and subrecipient personnel, as well as Attorneys of Record, who do not serve in roles providing services for or on behalf of ORR’s UC Bureau are not required to undergo suitability determination investigations. ORR is the ultimate authority to determine the level of risk associated with a position.

If staffing shortages result in staff acting in two (2) or more positions simultaneously with different risk designations, PRS providers should notify ORR immediately, and if possible, in advance, in order to establish a supervision plan (e.g., work under the direct, line-of-sight supervision and control of another staff member who has completed all background checks appropriate to their position as described in Section 6.7.2.2).  

Posted 01/13/2025

6.7.3 Core Competencies and Training Requirements

Core Competencies

Core Competencies

All Post-Release Services (PRS) providers should have a foundational knowledge of case management principles and practice, child welfare principles, family preservation, child and adolescent development, trauma-informed care, and issues related to forced migration.

Initial Training Requirements

Following an offer of employment and before providing services to children and sponsors, PRS staff providing direct services must complete 20 hours of training on the following topics (though more topics may be covered within the 20 hours of training, at the discretion of the recipient):

Administration: ORR policies and procedures; other relevant authorities and agency guidance impacting the provision of PRS; writing effective case notes; and current country conditions in the Northern Triangle (or other relevant countries).

Child Welfare: Stages of healthy child and adolescent development; childhood trauma and its long-term effects (i.e., complex PTSD); understanding and responding to risk and protective factors in children; family stabilization and preservation; state child abuse laws and mandatory reporting (see Section 6.7.5 Mandated Reporting).

Direct Service Provision: CLAS standards; core areas of PRS service provision (see Section 6.2 PRS Service Provision Policies); trauma-informed care; making specialized referrals; child-friendly interviewing; client boundaries; and role of the interpreter and best practices in intercultural interpretation.

Staff Wellness: Understanding and responding to compassion fatigue, burnout, vicarious trauma, and secondary traumatic stress; and ethical considerations in serving the PRS population.

Any training completed to meet state requirements or professional licensing standards may also be applied towards ORR’s initial training requirements.

Annual Training Requirements

PRS providers must complete a minimum of 20 hours of training annually on topics most pertinent to their scope of practice or caseload; licensed PRS providers must also meet annual training requirements required by state professional licensing standard for licensed professionals. Any training completed to meet state requirements or professional licensing standards may also be applied towards ORR’s annual training requirements. Annual training records must be kept in the employee’s personnel file.

Revised 01/13/2025

6.7.4 Supervision

Core Competencies

Post-Release Services (PRS) providers must have ongoing supervision and access to the organizational support they need as they work with released children and their sponsor families. Supervision for all positions should include the following four (4) elements:

Administrative Supervision: Administrative supervision includes quality control checks (e.g., reviewing the supervisee’s client case files) and ensures that PRS providers are adhering to Federal and State laws, regulations, policies, and other standards as well as organizational requirements.

Training-Focused Supervision: Training-focused supervision ensures that PRS providers understand what is required of them and have access to the tools needed (e.g., educational material) to effectively carry out their work or scope of practice, and that appropriate and quality services are being provided.

Clinical Supervision: Clinical supervision is appropriate for licensed and non-licensed professionals in the PRS context. Clinical supervision should be client-focused⁷ and used to discuss the clinical elements of PRS service provision, such as containment with clients, boundaries and boundary violations, trauma-informed care, etc.

Supportive Supervision: Supportive supervision creates a space for the PRS provider to reflect on their work with released children and sponsor families. The supervisor and supervisee should be able to constructively discuss their different approaches to case management or clinical care, if present, as well as ethical considerations that may arise during service delivery. Supportive supervision should address issues of compassion fatigue, burnout, vicarious trauma, and secondary traumatic stress.

Posted 10/6/2023, Effective 1/1/2024

6.7.5 Mandated Reporting

Post-Release Services (PRS) providers must train staff on State-specific mandated reporting laws for all states where PRS is being provided and have written procedures for meeting State-mandated reporting requirements (i.e., reporting suspected neglect, maltreatment, abuse and/or sexual abuse).

Posted 10/6/2023, Effective 1/1/2024

6.7.6 Grievances

Grievances concerning the provision of Post-Release Services (PRS) may be made to the ORR National Call Center or directly to the PRS provider, including during quality assurance follow-up calls, by a released child, sponsor, or PRS provider about PRS direct service provision (e.g., case management or intensive engagements). PRS providers must have written procedures for documenting, responding to, and resolving grievances or complaints.

Revised 01/13/2025

 

6.7.7 Code of Ethics

Post-Release Services (PRS) providers should have a code of ethics or an ethical framework for PRS providers that sets the standards for ethical conduct in PRS service provision, including clinical care.

Licensed professionals are required to follow relevant State laws and regulations in their area of practice, and, if applicable, to adhere to the code of ethics relevant to their scope of practice or work (e.g., National Association of Social Workers Code of Ethics).

Posted 10/6/2023, Effective 1/1/2024

6.7.8 Social Media

ORR prohibits Post-Release Services (PRS) providers from interacting with children who are, or were previously, in their caseloads on providers’ personal social media accounts (e.g., Instagram, Facebook, etc.), in order to maintain professional boundaries and protect the privacy of the child. However, PRS providers may use PRS provider social media accounts associated with their organization and/or professional email account to facilitate communication regarding PRS engagements with children in their caseloads. Pictures or any identifying information of children who are, or were, in their caseloads must not be posted or shared in any PRS provider social media.

Revised 01/13/2025

6.8 Records and Reporting

This section details policies on reporting to ORR, records management and retention, and information-sharing. Post-Release Services (PRS) providers must maintain adequate case file records and make regular reports as required by ORR that permit ORR to monitor and enforce the requirements and standards of ORR’s regulations and policies.

Revised 01/13/2025

6.8.1 Reporting to ORR

Post-Release Services (PRS) recipients are required to follow quarterly and annual performance and financial reporting requirements, as outlined in cooperative agreements with ORR.

Posted 10/6/2023, Effective 1/1/2024

6.8.2 Case Files

All Post-Release Services (PRS) documentation on individual service provision (e.g., client case notes, referral summaries, assessments, etc.) must be uploaded to ORR’s online case management system within seven (7) calendar days of completion. PRS providers must follow requirements for records management and retention as outlined in Section 6.8.3 Records Management and Retention.

All case file information must be kept together, in the recipient’s physical and electronic files, in addition to ORR’s online case management system.

Revised 01/13/2025

6.8.3 Records Management and Retention

Post-Release Services (PRS) recipients must have written policies and procedures (which must incorporate ORR policies and procedures) for organizing and maintaining the content of active and closed case files.

PRS recipients must have established administrative and physical controls to preserve the confidentiality of case file records and to protect both electronic and paper records from unauthorized access, use, and disclosure. Physical case files that include sensitive health information must be kept in a recipient’s locked cabinets, rooms, or buildings when not in use. The PRS recipient’s policies and procedures must also address preventing the physical damage and destruction of records.

The records included in case files are the property of ORR and PRS providers may not release those records without prior approval from ORR except for limited program administration purposes described by ORR. PRS providers must provide case file records to ORR immediately upon ORR request. If a recipient is no longer providing PRS for ORR, the recipient must provide all active and closed case file records to ORR according to instructions issued by ORR. Recipients must keep PRS case files in the original format.

Subject to applicable whistleblower protection laws, employees, former employees, and contractors of a PRS provider must not disclose case file records or information about unaccompanied children, their sponsors, family, or household members to anyone for any purpose, except for purposes of program administration described by ORR, without first providing advanced notice to ORR to allow ORR to ensure that disclosure of unaccompanied children’s information is compatible with program goals and to ensure the safety and privacy of unaccompanied children. For more information on information sharing and disclosures, see Section 5.9 Protecting the Privacy and Confidentiality of UC Information and Section 5.10 Information Sharing.

Revised 01/13/2025

6.8.4 Records Requests

Released children or other authorized parties (e.g., attorneys of record) may request access to the released child’s post-release services (PRS) case file records according to Section 5.10.1 UC Case File Request Process. 

Posted 10/6/2023, Effective 1/1/2024

6.8.5 Privacy

Post-Release Services (PRS) providers must have a formal process in place that protects the sensitive information of released children from access by unauthorized users. PRS providers must encrypt electronic communication (including, but not limited to, email and text messaging) containing sensitive healthcare or identifying information of released children. PRS providers must explain to released children and their sponsors how, when, and under what circumstances sensitive information may be shared during the course of PRS service provision.

PRS providers must ensure appropriate controls on information-sharing within the PRS provider network, including but not limited to subcontractors, to ensure that sensitive information is not exploited to the detriment of the released child.

Posted 10/6/2023, Effective 1/1/2024

6.8.6 Notifications of Concern

A Notification of Concern (NOC) is an instrument used by home study and Post-Release Services (PRS) providers, ORR care providers, and the ORR National Call Center (ORRNCC) staff to document and notify ORR of certain concerns that arise after a child is released from ORR care and custody (e.g., regarding an unaccompanied child’s safety and well-being)

The NOC also serves as an important mechanism to better understand if the sponsorship assessment and release process were safe and appropriate and whether the sponsor is adhering to the Sponsorship Care Agreement in providing for the released child’s well-being.

Home study and PRS providers, ORR care providers, and ORRNCC staff must submit a NOC when documenting certain reason(s) for concern identified post-release:

• Emergencies (death of a released child, serious medical and/or mental healthcare issue or unplanned hospitalization, etc.);
• Human trafficking (sex trafficking and/or labor trafficking) concerns;
• Abuse (including sexual abuse), abandonment, and neglect;
• Known child abduction, known runaway, or disappearance;
• Alleged criminal activity or charges against released child or against sponsor that directly affect child safety;
• Child protection services involvement;
• Potential fraud, such as document fraud or information fraud or fees charged for services that are to be provided free of charge;
• Released child behavioral incident that raises safety concerns/risk for self or others in home community;
• Media attention;
• Placement disruption with safety concerns;
• Contact by or involvement with organized crime;
• PRS provider unable to make contact with released child within 30 days of release or referral acceptance; and/or,
• PRS provider is providing services on an ongoing case and loses contact with the child and there are safety concerns. 

NOCs must be submitted to ORR as soon as possible or no later than 24 hours of first suspicion or knowledge of the event(s) and, if applicable, documented in the released child’s PRS case file.

PRS providers are required to comply with State mandatory reporting laws for the State(s) in which they provide services, which may require reporting the event(s) to the appropriate authorities, as detailed in Section 6.7.5 Mandated Reporting, Section 6.2.3 Assessments and below.

Human Trafficking

If the PRS provider suspects that the released child may be or is a victim of human trafficking, the PRS provider must also report the concerns to the HHS Office on Trafficking in Persons (OTIP) as well as to other appropriate authorities as required by State law (e.g., child protective services) within 24 hours of first suspicion. The referral to OTIP is appropriate if 1) the PRS provider suspects the child was or may be a victim of human trafficking at any point in the child’s life and in any country, and it was not previously reported by the care provider or 2) the PRS provider receives new or clarifying information related to previously reported concerns.

Abuse, Including Sexual Abuse, and Other Harm

If the released child has been or is at risk of being subjected to abuse, abandonment, neglect or maltreatment, the PRS provider must follow the mandated reporting guidelines for the locality in which they are providing services, which may involve contacting local law enforcement and requesting a well-being check on the child, in addition to submitting  a NOC . The NOC should be given as soon as it is practicable or no later than 24 hours after the event or after becoming aware of the risk or threat or incident.

In addition, if there is an allegation of sexual abuse or sexual harassment that may have occurred while the released child was in ORR’s custody, the PRS provider must complete a NOC and report the allegation to their Project Officer. The Project Officer will elevate the allegation to the Prevention of Child Abuse and Neglect (PCAN) Team in the case of sexual abuse involving care provider staff. The Project Officer will also share the NOC with the implicated care provider program where the incident is alleged to have occurred, including the care provider’s ORR/Federal Field Specialist (ORR/FFS). The FFS directs the implicated care provider program to follow the required reporting procedures that accompany Section 4.10.2 Care Provider Reporting Requirements.

In addition, if there is an allegation of sexual abuse or sexual harassment that may have occurred while the released child was in federal custody (but not ORR custody), the PRS provider must complete a NOC and report the allegation to their Project Officer. The Project Office will elevate the NOC to DHSSIRs@acf.hhs.gov, following procedures in Section 5.8.7 Allegations of Child Abuse in DHS Custody, and the PCAN Team.

Disappearances

If a released child disappears, in addition to submitting a NOC to ORR, the PRS provider will support and encourage the sponsor to notify local law enforcement and the National Center for Missing and Exploited Children (at 1-800-843-5678). Notice should be given as soon as it becomes practicable or no later than 24 hours after learning of the child’s disappearance. (See 2.8.1 After-Care Planning.)

Organized Crime

If the released child is contacted in any way by an individual believed to represent an alien smuggling syndicate, organized crime, or a human trafficking organization, the PRS provider must complete a Notification of Concern and report the allegation to ORR as soon as possible or no later than 24 hours after becoming aware of the information. (See Section 2.8.1).

Fraud

If the sponsor, a household member, released child, or alternate caregiver provides, or is found to have previously provided, fraudulent or inaccurate documents, photographs, and/or written or verbal information to deceive ORR for the purpose of obtaining the release of a child from ORR custody, the PRS provider must complete an NOC and report the allegation to ORR as soon as possible or no later than 24 hours after becoming aware of the information.

Revised 01/13/2025
 

6.8.7 Case Closures

A case must be formally closed when the Post-Release Services (PRS) provider terminates PRS, in accordance with the timeframe for each Level of PRS (see Section 6.3 Level One (1) PRS — Virtual Check-ins; Section 6.4 Level Two (2) PRS - Case Management Services; Section 6.5 Level Three (3) PRS - Intensive Engagements; and Section 6.6 TVPRA Legally-Mandated Cases). PRS providers must upload the closing PRS Report form into ORR’s online case management system within 30 calendar days of a case’s closure.

Revised 01/13/2025

6.9 ORR Monitoring

ORR provides consistent oversight of all components of a Post-Release Services (PRS) provider’s program, including program design, management, safety, child protection, case management, personnel management, and stakeholder relations. The purpose of ORR monitoring of PRS providers is to help ensure that they perform relevant services in accordance with ORR policies and 45 CFR 410.1210. To that end, the monitoring policies addressed in this section are those that create formal accountability standards and check points at regularly scheduled intervals. PRS providers are also subject to monitoring and reporting requirements, as well as remedies for noncompliance applicable to HHS grant recipients and contractors.

This section specifically concerns ORR monitoring of PRS providers’ activities under ORR policies and 45 CFR 410.1210. Under this section, if ORR becomes aware of a risk to the welfare of a child formerly in its custody (e.g., through an interview with a child conducted as part of PRS monitoring activities), ORR would ensure the PRS provider followed mandatory reporting requirements as outlined in Sections 6.7.5 Mandated Reporting and 6.8.6 Notifications of Concern.

Revised 01/13/2025

6.9.1 Monitoring Activities

ORR monitoring activities include the following:

• Desk Monitoring: Ongoing oversight based on the HHS grants management model, which includes monthly check-ins with the Post-Release Services (PRS) provider’s ORR/Project Officer (PO), regular record and report reviews, financial/budget statements analysis, and communications review.
• Monitoring Visits: Week-long monitoring to the PRS provider’s office not less than every two (2) years to conduct a comprehensive review of the program.
• Site Visits in Response to PO or Other Requests: Visits to the PRS provider’s office for a specific purpose or investigation (e.g., in response to a corrective action plan).

Desk Monitoring
Desk monitoring refers to ongoing oversight from ORR Division of Grants Management staff. Desk monitoring includes regular reviews of records and reports, such as annual goals and objectives, quarterly program reports, Notifications of Concern (NOC), grievances, ORR reports about the timely and accurate use of the ORR’s online case management system, and financial reports. It also involves regular calls with PRS provider program directors and others to become knowledgeable about the infrastructure and management systems of the individual programs. Desk monitoring includes reviewing data in required documents and reports to ensure compliance with policies and procedures and to follow-up on NOCs.

Monitoring Visits
The monitoring visit to the PRS provider’s office, conducted not less than every two years, consists of a comprehensive inspection based on information submitted by the PRS provider prior to the visit and during the visit and interviews with staff, children, and stakeholders. The formal monitoring visit utilizes templates, checklists, and other tools that must be completed at each site. The last step in the process is ORR’s submission of a monitoring report to the PRS provider (30 days after the visit) with a list of corrective actions that must be addressed. A corrective action is any finding that indicates noncompliance with explicit policies or procedures defined by ORR or for a serious situation in which the safety of a child is of concern. The recipient has up to 30 days to submit a response to the corrective action plan, indicating how the program has corrected or will remedy any noncompliance. However, ORR may require more immediate action when appropriate and will notify the PRS provider.

Prior to the monitoring visit, the PRS provider must provide to ORR written responses to standardized questions about their operations (the Site Visit Guide), including questions on internal quality assurance practices, child protection, case management, appropriate referrals, and administration. As detailed below, PRS providers also provide documents to ORR prior to the visit and during the visit.

Relevant documents, reports, and files examined prior to and during a monitoring site visit include, but are not limited to:

• Grant application/cooperative agreements;
• Completed answers to the Site Visit Guide;
• Recent organizational chart of PRS and home study staff;
• Geographical areas served;
• Community partnerships with stakeholders;
• Training;
• Quality assurance procedures and internal monitoring resources;
• Most recent Quarterly Report;
• Current approved fiscal year budget;
• Recent NOCs;
• Reports from previous monitoring visits (including corrective action plans);
• Children’s PRS case files;
• PRS provider staff personnel files;
• PRS provider’s internal policies and procedures;
• PRS provider’s grievances policies, copies of children and sponsors’ grievances; and
• Materials and reports about the provider’s timely and accurate use of the online case management system.

The week-long monitoring visit includes, but is not limited to, standardized interviews with PRS and home study staff, as well as the Program Director, stakeholders (such as the local Legal Service Provider, non-HHS Federal agency partners, and others) and released children. As with any monitoring activity, PRS providers must comply with ORR requests for access to the office, program information and case files.

Each monitoring visit generally involves the review of 3-15 randomly chosen case files and related documentation; review of personnel files, review of related documents from the list above; and review of submitted NOC from the PRS provider.

The ORR Monitor consults with the assigned Project Officer and meets with the PO to discuss any findings and any positive or negative trends identified. Trends can include but are not limited to: the quality of case notes, reports, and documentation of in-person visits.

ORR monitoring and compliance responsibilities are divided among the teams noted in the table below. The teams work collaboratively but also independently in order to provide a higher level of scrutiny and focused attention on various tasks.

Roles and Responsibilities in ORR Monitoring and Compliance Model

Revised 01/13/2025

6.9.2 Follow Up and Corrective Actions

If a Post-Release Services (PRS) provider is found to be out of compliance with ORR policies or procedures based on monitoring activities, ORR will communicate the concerns in writing to the Program Director or appropriate person through a written monitoring or site visit report, with corrective actions and child welfare best practice recommendations. The need for a corrective action occurs when the PRS provider is in noncompliance with ORR policy and procedures.

Following the issuance of corrective actions, the ORR/Project Officer (ORR/PO) will request a response to the corrective action findings from the Program Director and determine a timeframe for resolution and the disciplinary consequences for not responding within the required timeframes.

The PRS provider’s corrective action plan must include:

• The cause of noncompliance, because effective corrective action cannot be taken without first making a determination of the cause of noncompliance;
• Clear and concise statements of corrective actions (include person/s responsible and timelines);
• Thorough descriptions of corrective actions that reference specific documents, procedures, etc.;
• The date of completion of the corrective actions; and
• Evidence supporting the claim that the corrective action has been fully and effectively implemented and that the corrective action has been performed in the way that it was described.

PRS providers are also subject to remedies for noncompliance applicable to HHS grant recipients and contracts.

Revised 01/13/2025

6.9.3 Sub-Contract Monitoring

Post-Release Services (PRS) providers who provide services for children through a sub-contract or sub-grant are responsible for conducting monitoring visits of the sub-recipient not less than every two (2) years, as well as site visits, as necessary, and weekly desk monitoring. This includes evaluating the PRS provider’s compliance with applicable Federal, State and local laws. PRS providers must provide findings of such reviews to the designated ORR/Project Officer (ORR/PO).

To assess PRS providers with sub-contracts or sub-grants arrangements, ORR evaluates and monitors the primary PRS provider on-site and through desk monitoring, but may also conduct monitoring at sub-contractors or sub-PRS providers, as necessary.

PRS providers with sub-contracts or sub-grants arrangements are subject to the same monitoring schedule as other PRS providers but the activities are tailored to the sub-contracts or sub-grants arrangement. For example, ORR Monitors, during on site monitoring visits, may schedule a visit with the PRS provider staff of a particular sub-contract or sub-grant to conduct a first-hand assessment of the program and the PRS provider oversight of those programs and services.

PRS providers are responsible for monitoring any sub-contracts consistent with any requirements applicable to HHS grant recipients and contractors.

Revised 01/13/2025

6.9.4 PRS provider Internal Program Monitoring, Evaluation, and Quality Assurance

Pursuant to 45 CFR part 75.342, Post-Release Services (PRS) providers must have their own internal monitoring processes that may be set by the PRS provider’s organization. PRS providers are expected to conduct internal monitoring, evaluation, and continuance quality assurance assessments on a quarterly basis in order to identify areas in need of improvement and/or modification. The PRS provider’s monitoring, evaluation, and quality assessment plan must include measures to evaluate how the program:

• Complies with Federal and applicable State laws and regulations, and ORR policies, procedures, and other ORR guidance.
• Fulfills the program’s Statement of Work with ORR as well as the terms of the cooperative agreement or contract.
• Ensures that an immediate supervisor reviews every PRS and home study report for quality and accuracy prior to submission.
• Identifies issues subject to corrective action plans.

PRS providers are required to evaluate their program’s strengths and weaknesses based on the following performance indicators:

• Number/type of grievances filed by children, sponsors, and
• Surveying/interviewing program participants, (i.e., sponsors and children) to assess the quality of service.
• Allegations and findings of staff misconduct.
• Timeliness of service delivery.
• Regular review and updating of resources list to ensure accuracy.
• Activities related to corrective action plans, if applicable.

PRS providers’ quarterly internal monitoring reports must be made available to ORR upon request.

Revised 01/13/2025

Footnotes

1. As defined in 6 USC § 279(g)

2. 8 USC § 1232(c)(3)(B)

3. 34 USC § 20341 and 45 CFR 411.6

4. Defined by the Centers for Disease Control and Prevention as “all types of abuse, neglect, and other potentially traumatic experiences that occur to people under the age of 18.” Retrieved from: https://www.cdc.gov/violenceprevention/childabuseandneglect/acestudy/aboutace.html

5. 18 USC § 2340(1)

6. 29 U.S.C. 794

7. Harkness, D., & Hensley, H. (1991). Changing the focus of social work supervision: Effects on client satisfaction and generalized contentment. Social Work, 36(6), 506-512.