FR 2021-03261

Overview

Title

Proposed Information Collection Activity; Legal Services for Unaccompanied Alien Children (New Collection)

Agencies

ELI5 AI

The government wants ideas from people on how to help kids who are in the country without their parents. They plan to use forms to provide these kids with lawyers who can help them with their paperwork, and they want to make sure the forms are easy to understand and use.

Summary AI

The Office of Refugee Resettlement (ORR), under the Administration for Children and Families (ACF) and part of the U.S. Department of Health and Human Services, is seeking public feedback on a proposed information collection effort to aid Unaccompanied Alien Children (UAC) with legal services. Several forms are involved, intended to ensure that UACs can access legal service providers and navigate their immigration proceedings. The ACF is specifically collecting comments on aspects such as the necessity, clarity, and practicality of the information collected. Interested parties can submit their opinions within 60 days of the publication, in line with the Paperwork Reduction Act of 1995.

Abstract

The Office of Refugee Resettlement (ORR), Administration for Children and Families (ACF), U.S. Department of Health and Human Services (HHS), is inviting public comment on the proposed collection. The request consists of several forms that allow the Unaccompanied Alien Children (UAC) Program to provide legal services to UAC.

Type: Notice
Citation: 86 FR 10082
Document #: 2021-03261
Date:
Volume: 86
Pages: 10082-10084

AnalysisAI

The document, published by the Office of Refugee Resettlement (ORR) under the U.S. Department of Health and Human Services, seeks public input on a proposed project aimed at providing legal services to Unaccompanied Alien Children (UAC). This proposal involves a series of specific forms to help these children access necessary legal resources and support their immigration proceedings.

General Summary

The proposed collection includes various forms designed to facilitate legal services for Unaccompanied Alien Children. Each form has a distinct purpose, ranging from ensuring the delivery of legal service provider lists to the children, enabling requests for bond hearings, outlining procedures for seeking Special Immigrant Juvenile legal relief, and documenting legal interactions and changes to court locations. The initiative emphasizes compliance with the Paperwork Reduction Act of 1995, which mandates seeking public comment on such collections.

Significant Issues or Concerns

While the intention behind the collection is commendable, the document presents some issues that merit attention:

  • Clarity and Implementation Strategy: Although the document outlines the forms in detail, it falls short of providing a comprehensive implementation strategy. Without clear explanations of how these forms contribute to legal services, stakeholders may find it challenging to understand the practical outcomes of the initiative.

  • Guidelines and Examples: Forms like the "Request for a Flores Bond Hearing" may benefit from explicit guidelines or examples to ensure that case managers apply the procedures consistently and correctly.

  • Public Feedback Integration: The document does not specify how the ORR plans to incorporate public comments into its process, potentially leaving a gap in transparency and stakeholder engagement.

  • Roles and Responsibilities: There is a lack of clarity regarding how different respondent types, such as attorneys, case managers, and UACs, are expected to engage with the forms. This could lead to confusion and miscommunication.

  • Complex Terminology: The use of legal and immigration-specific expressions, such as "bond hearing" or "restrictive setting," may be difficult for non-specialist audiences to grasp.

  • Data Privacy Concerns: There is no mention of measures to protect the sensitive data of UACs, which could be a significant concern given the vulnerable status of these children.

Impact on the Public and Stakeholders

The proposal's potential impacts on the public and specific stakeholders are multifaceted:

  • Broad Public Impact: Generally, the initiative aims to streamline legal access for unaccompanied children in the U.S., a socially important goal. Enhancing legal support for vulnerable populations can lead to better societal outcomes and support community integration efforts.

  • Positive Stakeholder Impact: Entities such as legal service providers and child advocates may find the structured approach beneficial, as it clarifies communication channels and legal processes for children in ORR care.

  • Potential Challenges for Case Managers and Legal Teams: The lack of clear implementation guidelines and potential misunderstandings regarding roles could place additional administrative burdens on case managers and legal teams, affecting efficiency and the timely provision of services.

Overall, while the proposed information collection activity represents a step forward in supporting unaccompanied children with legal services, it necessitates further refinement to address ambiguities and enhance clarity for its successful implementation and acceptance by stakeholders.

Issues

  • • The document provides detailed descriptions of forms related to the UAC program, but it lacks clarity on the overall implementation strategy and how these forms contribute to the legal services provided to UAC.

  • • Some forms such as 'Request for a Flores Bond Hearing' and 'Motion for Change of Venue' might require clear guidelines or examples to ensure consistent application by case managers.

  • • The document does not provide specific details on how the feedback from public comments will be incorporated into the information collection process.

  • • There is a lack of clarity on the roles and responsibilities of each respondent type mentioned, which might lead to misunderstandings or miscommunications.

  • • The language used in the descriptions of the forms, such as 'bond hearing' or 'restrictive setting', might be complex for audiences not familiar with legal or immigration terminology.

  • • The document does not specify if there are any potential privacy concerns or data protection measures in place when handling UAC information through these forms.

Statistics

Size

Pages: 3
Words: 1,254
Sentences: 53
Entities: 90

Language

Nouns: 469
Verbs: 98
Adjectives: 53
Adverbs: 10
Numbers: 35

Complexity

Average Token Length:
4.92
Average Sentence Length:
23.66
Token Entropy:
5.27
Readability (ARI):
17.26

Reading Time

about 4 minutes