Southwest Key Programs Did Not Always Comply With Health and Safety Requirements For The Unaccompanied Alien Children Program

The Unaccompanied Alien Children (UAC) program, which is overseen by HHS's Office of Refugee Resettlement (ORR), served between 7,000 and 8,000 children annually from fiscal year (FYs) 2005 through 2011. In FY 2012, the number of children served in the program increased to 13,625. In FY 2014, ORR served 57,496 children and in FY 2015, ORR served 33,726 children. In FY 2016, ORR served 59,170 children. Because of the rapid increase of vulnerable children entering ORR care, and the significant increases in program funding, we are conducting a series of reviews of ORR care providers across the Nation.

Southwest Key did not meet or properly document that it met certain safety standards for the care or release of some children in its custody. Additionally, we found that Southwest Key was unable to support the number of reunifications reported to ORR for FFY 2016.

Based on our UAC case file sample review results, we estimated that Southwest Key did not properly document the care or release of 38 percent of all children released to sponsors in FY 2016. Without adequate documentation in the UAC case files, ORR could not be assured that for 8,323 children, Southwest Key had followed ORR policies regarding sponsor background checks, prompt care, or that the Department of Homeland Security (DHS) was notified about the child's release to a sponsor. Finally, we determined that some Southwest Key employee and volunteer files we reviewed were missing evidence of required background checks.

We recommend that Southwest Key comply with ORR regulations pertaining to (1) video monitoring in common areas, (2) sponsor and other household members background checks, (3) admission/intake assessments and medical exams, (4) discharge notifications to DHS and other stakeholders, and (5) safety and well-being follow-up calls. In addition, we recommend that Southwest Key comply with State regulations pertaining to (1) minimum bedroom space, (2) health and safety standards for shelters, and (3) employee background investigations. We also recommend that Southwest Key ensure that information reported to ORR is accurate. The report also contains other procedural recommendations for Southwest Key to operate its UAC program in accordance with Federal and State requirements.

In written comments to our draft report, Southwest Key generally concurred with most of our findings and recommendations, provided what it believed was important context to some findings, and outlined corrective actions it had taken to address the findings. Southwest Key disagreed with our findings related to background checks for sponsors and adult household members and initial intake assessments. We maintain that our findings and recommendations are valid and commend Southwest Key for taking corrective action to address the findings. We also recognize Southwest Key's efforts to ensure program compliance while supporting an extraordinary number of children under difficult operational circumstances.