Unaccompanied Children in Office of Refugee Resettlement custody could soon be covered by revised mental health and onsite medical intervention forms under a proposal submitted for Office of Management and Budget review.
Table of Contents
Unaccompanied Children Update
The Administration for Children and Families published the notice on October 5, 2026, and is accepting public comments through November 4, 2026.
The proposal would extend the information collection for three years while changing how care providers document mental health assessments, communicable illness responses, medication-related interventions and health information that may be shared with the Department of Homeland Security in limited repatriation situations involving unaccompanied children.
What ORR is proposing
The proposal covers two forms used in the care of unaccompanied children: the Mental Health Assessment Form and the Onsite Health Intervention Form.
The existing collection also includes two public health investigation forms addressing active tuberculosis and non-tuberculosis illness.
ORR wants to combine those two forms into one expanded Onsite Health Intervention Form for use with unaccompanied children.
According to the notice, the consolidated form would address quarantine for communicable disease exposure, triage conducted with a licensed health professional and medication-related actions taken under standing orders.
ORR said the restructuring is intended to reduce duplicate work, improve the quality of information collected and bring the forms into closer alignment with program requirements for unaccompanied children.
Changes to mental health documentation
The Mental Health Assessment Form would also receive several revisions affecting how providers document evaluations and follow-up care for unaccompanied children.
For follow-up mental health visits, ORR proposes removing the requirement to repeat the full history section when that information is already available.
The form would strengthen documentation of disabilities and accommodations, including information needed to support a child’s daily functioning while in care.
It would also add a field for laboratory tests and imaging that were ordered or completed during the relevant period.
Other proposed changes include clearer instructions based on the type of visit and standardized choices for abnormal findings in the mental status examination.
The form would provide more options for documenting substances a child may have used, replace fixed diagnosis selections with free-text fields and make additional formatting changes intended to improve data quality.
ORR also plans to update the related “Dear Colleague” letter that health professionals are expected to review during an initial visit with a child.
How the forms are used in ORR care
Unaccompanied children in ORR custody are placed in care provider programs while the agency works toward reunification with a qualified sponsor or another authorized placement outcome.
Care providers arrange or deliver routine and emergency medical, dental and mental health services for unaccompanied children.
They are also expected to follow treatment plans ordered by qualified health professionals.
Those plans may include specialist referrals, medication administration and accommodations for physical or mental impairments that affect daily activities.
Care provider staff may also respond to non-emergency health concerns through consultation with a licensed health professional or through over-the-counter medication procedures authorized by a child’s primary provider.
The forms generally serve as worksheets for providers and care staff documenting services for unaccompanied children.
After information is collected, staff enter the relevant data into ORR’s secure electronic record system.
When a child receives emergency or urgent care, is hospitalized or is admitted to an out-of-network facility, the paper mental health form may not be completed during the visit.
ORR nevertheless requires relevant information to be entered into the electronic record using available health records.
Proposed DHS information sharing during repatriation
One of the most consequential changes would update the stated purpose of the information collection to include limited health information sharing with DHS.
The provision would apply when DHS identifies an unaccompanied child in ORR custody for repatriation and the child has a health condition requiring ongoing management or an accommodation.
The stated purpose is continuity of care.
ORR says relevant information would help ensure that the child receives recommended treatment and accommodations during travel and after transfer.
The proposed information could include the child’s name, alien number and date of birth, along with active diagnoses or health concerns requiring management.
It could also include allergies, current medications and dosages, isolation or quarantine requirements, health-related accommodations and durable medical equipment needs.
Health-related travel restrictions would also be included among the categories of information identified in the proposal.
The notice does not establish a general transfer of every health record to DHS.
Instead, it describes sharing relevant information in specific cases involving an unaccompanied child with health needs who has been identified for repatriation.
Who would complete the forms
The proposed respondents include mental health professionals and care provider staff serving unaccompanied children.
Mental health professionals may include psychiatrists, psychiatric nurse practitioners, physician assistants, licensed psychologists, social workers and other community-based licensed mental health providers.
Care provider staff would continue to document onsite health interventions and may also record mental health information obtained from health records when a mental health professional did not complete the assessment form directly.
Estimated paperwork burden
ORR estimates that the proposed changes would reduce the annual response and recordkeeping burden compared with the existing collection.
The agency attributes the reduction partly to a lower number of unaccompanied children in ORR care and partly to shorter forms, removed fields and skip patterns that limit questions to the types of visits where they are needed.
| Collection activity | Estimated annual burden |
|---|---|
| Mental Health Assessment Form responses | 318.5 hours |
| Onsite Health Intervention Form responses | 4,341.6 hours |
| Total response burden | 4,660.1 hours |
| Total recordkeeping burden | 3,933.6 hours |
For the Mental Health Assessment Form, ORR estimates 250 mental health professionals would submit an average of 9.8 responses annually, with an average response time of about 0.13 hours.
For the Onsite Health Intervention Form, the agency estimates 150 care provider staff respondents would submit an average of 321.6 responses per year, with an average response time of about 0.09 hours.
How to submit a public comment
Public comments are due by November 4, 2026.
Comments may be submitted through the information collection portal identified in the notice.
Members of the public may also request copies of the proposed collection by emailing the Administration for Children and Families at [email protected].
Commenters should identify the information collection by its title: “Mental Health Assessment Form and Onsite Health Intervention Form.”
Comments submitted through the federal docket may become publicly available.
Individuals should avoid including unnecessary personal information in comment text or attachments.
What happens next
The notice is a request for public input, not a final rule changing immigration status, custody eligibility or repatriation policy.
After the comment period, ACF and ORR may review submissions and continue the request for OMB approval, modify the proposed forms or take another action permitted under the federal information collection process.
The proposal also does not itself order care providers to begin using revised forms immediately.
Any implementation details would depend on subsequent agency action and instructions issued for the approved collection.
For families, advocates and service providers, the most important practical issue is whether the final forms preserve accurate documentation of mental health needs, medications, accommodations and travel-related restrictions for unaccompanied children moving between agencies or care settings.
Frequently Asked Questions
What forms is ORR proposing to revise?
ORR is proposing changes to the Mental Health Assessment Form and the Onsite Health Intervention Form. The agency also plans to merge two existing public health investigation forms into the expanded onsite intervention form.
When is the public comment deadline?
Comments on the proposal are due November 4, 2026.
Would the proposal change immigration status or custody rules?
No. The notice concerns an information collection and proposed documentation changes. It does not itself change immigration status, custody eligibility or repatriation rules.
What health information could be shared with DHS?
In specified repatriation situations, the proposal identifies information such as active diagnoses, allergies, medications, quarantine requirements, accommodations, durable medical equipment needs and health-related travel restrictions.
Fact-Checked: Verified against the Federal Register notice published October 5, 2026, including the proposed form changes, November 4, 2026, comment deadline and burden estimates.
Disclaimer: This article summarizes a proposed federal information collection and is not legal or medical advice.
New Minimum Wage In Canada and 5 Provinces, Effective April 1
