Immigration officials are seeking public comment on a proposed overhaul of the health forms used for unaccompanied children in the custody of the Office of Refugee Resettlement.
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Immigration Update
The Administration for Children and Families published the notice on October 26, 2026, asking the public to comment on revisions to the Medical Assessment Form, Dental Assessment Form and Serious Medical Procedure Request Form used in the immigration system.
The proposal would consolidate the serious-procedure form under the existing Office of Management and Budget collection for medical and dental assessments, without changing immigration eligibility rules.
It would also update the collection’s title to “Office of Refugee Resettlement Unaccompanied Alien Child Health Forms.”
Comments are due by November 25, 2026.
What ORR is proposing
The proposal concerns information collection and recordkeeping requirements rather than a new immigration status, admission rule or removal policy.
ORR said the changes are intended to reduce duplicate documentation, improve the quality of health information and better align the forms with the agency’s care requirements in an immigration custody setting.
The forms are completed by health care professionals and care-provider staff while children are in ORR custody during the immigration process.
Information from the paper or worksheet forms is then entered into ORR’s secure electronic system of record for use in the children’s immigration-related care.
The Medical Assessment Form is used for medical evaluations, while the Dental Assessment Form captures information from dental assessments connected to the immigration case.
The Serious Medical Procedure Request Form is used when ORR approval is required before a non-emergency procedure involving anesthesia or intravenous sedation.
ORR said the serious-procedure form is currently approved under OMB control number 0970-0561, which expires December 31, 2026.
The medical and dental forms are covered by OMB control number 0970-0466, which is listed with an October 31, 2026, expiration date in the notice.
Changes to medical and dental documentation
The proposed revisions would change how information is collected during different types of visits, including visits involving children in immigration custody.
For dental assessments, the history section would generally be required only during the initial dental examination.
For medical assessments, providers could summarize critical health information on the first two pages instead of completing a third page for every scheduled visit in an immigration care program.
The proposed exception would cover the initial medical examination and routine well-child visits, which would continue to require the more detailed process described by ORR.
The medical form would also receive a stronger field for disabilities and accommodations relevant to a child’s immigration-related care.
Another proposed field would capture laboratory tests and imaging that are ordered or completed.
ORR also plans clearer instructions based on the type of visit, a provider acknowledgment and signature section, broader field reformatting and changes to diagnosis fields.
The notice says fixed diagnosis choices would be replaced with free-text fields to improve the description of a child’s condition.
The related Dear Colleague Letters for health care providers would be revised to reflect the form changes without altering immigration decisions.
Limited health information could go to DHS in repatriation cases
The most consequential privacy-related change involves limited health information sharing with the Department of Homeland Security, an agency involved in immigration administration.
Under the proposal, ORR could share relevant information with the DHS Field Office Juvenile Coordinator when a child with ongoing health needs leaves ORR custody for DHS-led repatriation during the immigration process.
The stated purpose is continuity of care during travel and after the child departs ORR custody, rather than a change to the child’s immigration case.
ORR said the information would not be shared for immigration enforcement purposes.
The proposed data set could include the child’s name, alien number and date of birth for the limited immigration transfer described in the notice.
It could also include active diagnoses or health concerns that require management during travel.
Other listed information includes allergies, current medications and dosages, isolation or quarantine requirements, health-related accommodations and durable medical equipment needs.
The information could also identify health-related travel restrictions affecting the immigration repatriation process.
The notice describes the disclosure as limited to information needed to help ensure that treatment, medication and accommodations recommended by health care providers continue during the child’s transfer or repatriation process.
The proposal does not describe a general transfer of every medical record to DHS or a broader immigration record disclosure.
Instead, the notice ties the disclosure to children with health care needs who are leaving ORR custody through a DHS-led repatriation process.
How medical procedures are handled under the proposal
ORR care providers are expected to arrange routine, emergency, dental and mental health services for children in their programs, including children involved in the immigration system.
They are also expected to implement treatment plans recommended by evaluating health care professionals.
Those plans can involve specialist referrals, procedures, medication, durable medical equipment or accommodations for physical or mental impairments during immigration custody.
For non-emergency procedures performed under anesthesia or intravenous sedation, the treating provider must generally complete the Serious Medical Procedure Request Form and submit it through the care-provider program before ORR makes a decision.
ORR said the form requirement may be waived when doing so is in the child’s best interest, including during a hospitalization or emergency-department visit connected to a medical emergency.
The proposed change would remove the first page of the serious-procedure form that was completed by care-provider staff.
Instructions would be revised to make the purpose of the form clearer for providers serving children in immigration care.
Other edits would remove redundant fields and seek more complete responses from surgeons and other treating providers.
Estimated paperwork burden would fall
ORR estimates that the total annual response burden for health care providers would be 4,166.6 hours under the proposed collection supporting immigration custody.
The estimate includes 2,090.4 hours for general pediatricians completing medical assessment forms.
It includes another 1,126.1 hours for general medical specialists, 933 hours for dentists and 17.1 hours for surgeons completing serious-procedure requests.
ORR separately estimates 9,613.92 hours of annual recordkeeping time for care-provider staff.
The agency said response burden would decline by 93.2 percent and recordkeeping burden by 90.4 percent compared with the prior estimates.
ORR attributed the reduction partly to a lower census of unaccompanied children in its care.
The agency also cited the removal of unnecessary fields and the use of skip patterns that limit questions to the types of visits where they are needed.
Who is affected by the proposed forms
The direct respondents would be primary care providers, medical specialists, dentists and surgeons who treat children in ORR care under the immigration system.
Care-provider staff would continue to compile information and enter relevant data into ORR’s electronic records system.
The broader operational impact would involve children in ORR custody, the programs that care for them and, in certain cases, DHS personnel arranging DHS-led repatriation travel in immigration cases.
The notice explains that children in ORR custody receive baseline medical and dental examinations, well-child checks, preventive dental care and counseling services.
It also says that information from health records may be used to complete electronic records when a standard medical assessment form is not completed during an emergency visit, hospitalization, out-of-network admission or certain immunization follow-up visits.
How to submit comments
Members of the public may review and comment on the proposed collection through the federal RegInfo system, including on its effects in immigration custody.
The comment deadline is November 25, 2026.
People seeking copies of the proposed collection may email [email protected] and identify the request by the title of the information collection used for immigration health records.
Comments submitted through the federal docket may become publicly available.
People should avoid including unnecessary personal medical information or other sensitive details in a public comment or attachment.
Comments are most useful when they identify a specific form provision, explain a practical effect and propose precise alternative language or procedures.
What happens next
The notice begins a public-comment process for ORR’s request to revise the information collection and obtain continued approval from the Office of Management and Budget.
Publication of the notice does not by itself make all of the proposed form changes final or change immigration policy.
ORR and OMB may consider public comments before deciding whether to approve, modify or otherwise address the collection request.
Until a final decision and implementation instructions are issued, providers and care programs should continue following the forms and procedures currently in effect for children in immigration custody.
Frequently Asked Questions
What is ORR proposing to change?
ORR proposes to combine the Serious Medical Procedure Request Form with the medical and dental assessment collection, revise the forms and update related provider instructions.
When are comments due?
Public comments are due November 25, 2026.
Will ORR share every child’s medical record with DHS?
The notice proposes limited sharing of relevant health information with the DHS Field Office Juvenile Coordinator when a child with health care needs leaves ORR custody for DHS-led repatriation. It does not describe a general transfer of all medical records.
Does the notice create a new immigration rule?
No. It is a request for public comments on an information collection and proposed form revisions, not a new immigration status, admission rule or removal regulation.
Fact-Checked: The article was checked against Federal Register document 2026-21762 and related federal regulatory information sources available on October 25, 2026.
Disclaimer: This article summarizes a proposed federal information collection and does not provide legal or medical advice.
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