NonSub Change - S-19 and S-26

To: Kelsi Feltz

Office of Information and Regulatory Affairs (OIRA)

Office of Management and Budget (OMB)

From: Shannon Herboldsheimer

Office of Refugee Resettlement (ORR)

Administration for Children and Families (ACF)

Date: August 21, 2024

Subject: Non-Substantive Change Request – Services Provided to Unaccompanied Children (OMB #0970-0553)

This memo requests approval of non-substantive changes to the approved information collection, Services Provided to Unaccompanied Children (OMB #0970-0553).

Background

The Services Provided to Unaccompanied Children information collection contains 22 instruments that allow the Office of Refugee Resettlement (ORR) to collect information necessary to provide services to unaccompanied children as required by the Homeland Security Act (6 U.S.C. 279), the Trafficking Victims Protection Reauthorization Act of 2008 (8 U.S.C. 1232), and the Flores Settlement Agreement (No. CV85-4544-RJK (C.D. Cal. 1996)).  The collection was last approved by OMB on April 21, 2022, and expires on April 30, 2025.

 

ORR is proposing changes to one form in this collection, the Home Study/Post-Release Service (HS/PRS) Referral (Form S-19). The currently approved version of the HS/PRS Referral (Form S-19) was developed for UC Path, an alternative case management system that ORR has not rolled out and therefore does not align with existing forms in the UC Portal, its current case management system. Approval of a UC Portal version will allow ORR to come into compliance with Paperwork Reduction Act (PRA) requirements. Additionally, ORR solicited feedback and completed testing activities, as approved under the “Feedback for Post-Release Service (PRS) Solution Development and Iteration” information collection (0970-0401) and has identified improvements to improve user experience.

Overview of Requested Changes

ORR is proposing changes that will 1) align the HS/PRS Referral with the existing version in the UC Portal, and 2) create an appendix to the form that will improve user experience and create efficiencies for completing administrative actions needed to process PRS cases.

1. Aligning HS/PRS Referral Form with Existing UC Portal Version

ORR proposes revising the currently approved UC Path version of Form S-19 to align with the existing forms in the UC Portal, its current case management system. This includes splitting the form into two separate forms – PRS Referral (Form S-19) and Home Study Referral (Form S-26). Please refer to Appendix A for additional details about how information will be rearranged or changed.

2. Appendix to the PRS Referral (Form S-19)

PROPOSED REVISIONS:

ORR proposes creating an appendix to the PRS Referral that will allow users to perform administrative actions needed to process PRS cases. The appendix will be accessible via a new interactive, web-based application (PRS system) that helps facilitate responses and emphasizes clear calls to action, visual distinctions of the different actions, and required documentation for the actions. These actions include:

• Accept Case – This action allows PRS providers to accept cases referred for PRS. Currently, referrals are entered using the PRS Referral in the UC Portal, and the UC Portal system adds the referral to a queue. PRS providers may select one or more cases to accept from the queue. ORR proposes moving the queue into the new PRS system so that all administrative actions are collocated in the new system. Care providers will continue to enter referrals using the UC Portal PRS Referral, and the data will be imported into the queue in the new system.

• Assign Case Manager – This action allows PRS providers to assign a case manager to cases they have accepted. This functionality is present in the HS/PRS Referral developed for UC Path but is not currently available in the UC Portal system. ORR proposes moving this functionality into the new PRS system.

• Request Extension – This action allows PRS providers to request that PRS continue to be provided past the closure date. This action is not present in UC Portal and is currently performed over email. This action could be performed in the HS/PRS Referral developed for UC Path by entering the details of the extension request in the “Referral Notes” open text field and updating the “Expected Closure Date” field. ORR proposes maintaining the abilities to enter notes/details in an open text field and update the close date, as well as add the following follow-up questions/fields: a dropdown field to capture the reason for extension that will allow ORR to track why extensions are requested, and an area to upload documentation (currently sent via email) that supports the PRS provider’s request for an extension.

• Transfer Case – This action allows PRS providers to transfer a case to a different PRS provider. This action is not present in the UC Portal and is currently performed using a combination of virtual meetings and emails. This action could be performed in the HS/PRS Referral developed for UC Path by selecting the "Transferred to Another PRS Provider" option in the "Reason for Closure" field. ORR proposes moving this action into the new PRS system and adding follow-up questions/fields that better support the administrative actions needed to transfer a case, such as determining whether a new provider has already been identified, collecting the reason for transfer using standardized options, entering an updated address for the new provider in cases where the child moved, and allowing providers to simultaneously transfer cases that are part of the same family group.

• Change PRS Level – This action allows PRS providers to change the level of PRS when a change is needed to better meet the needs of the child and their sponsor. Currently, the PRS level is initially captured in the PRS Referral in the UC Portal, requests to change the level are made using a combination of virtual meetings and emails, and there is no way to update the level in the UC Portal after it has been changed. ORR proposes moving this action into the new PRS system, which would include the ability to change the PRS level, document the reason for the change using standardized options, add an explanation, and upload documentation that support the request.

• Close Case – This action allows PRS providers to close a case. This function is currently performed in the UC Portal by clicking the “Close Case Referral” button in the PRS Referral form and uploading the final PRS Report (Form S-22, currently approved under this information collection). ORR proposes moving this action into the new PRS system so that all administrative actions are collocated in the new system. In addition, ORR proposes moving the dropdown field for reason for case closure found in the HS/PRS Referral developed for UC Path into the new system, along with new follow-up questions/fields that allow the PRS provider to enter the actual close date, whether the child agrees to be contacted after case closure, and add details/notes about the case.

Please refer to Appendix A for additional details.

HOW THIS IMPROVES USER EXPERIENCE:

Currently, there is no single place where PRS providers can go to perform administrative actions for PRS cases. Some administrative actions are performed in the UC Portal, but most are processed over email or in virtual meetings. Actions performed over email or virtual meetings lack standardization and make it difficult for ORR to track actions and outcomes for PRS cases.

The proposed revisions will collocate all administrative actions in a system that clearly distinguishes the different actions along with their required documentation, which will help users perform these actions with greater confidence, ease, and efficiency. The interactive, web-based system will also help improve responsiveness and accuracy and create efficiencies in the following ways:

• PRS Providers will be able to find and complete the actions, while providing the required documentation more quickly.

• ORR Program Staff will be able to review, assess, and adjudicate cases more accurately, due to the information provided for the administrative actions.

• The data collected will also be standardized against each action, making the data more valuable for identifying patterns and tailoring support to ORR programs that need it.

• This will lessen the cognitive load for all users involved, so they can focus on their primary responsibilities with regard to case management or adjudication, and spend less time finding, assessing, or filling out the applicable fields to complete or review the administrative actions.

• ORR will also be able to track the outcome of PRS referrals, including whether the sponsor and child accepted and received services or declined services.