October 6, 2021
Kids in Need of Defense (KIND) submits this comment in response to the above Request for Information (RFI). The questions in the RFI pose significant implications for the wellbeing and safety of unaccompanied children. Over decades, a framework of legal protections has aimed to ensure children are treated with dignity and regard for their particular vulnerability as children in the immigration system. Despite this progress, significant work remains to realize a system that assures children’s wellbeing and best interests at every point. KIND is troubled by recent measures in Texas that undermine the ORR system by withdrawing state licenses and oversight from ORR providers. We share ORR’s desire to ensure children receive appropriate care amid these setbacks. We believe the best course lies not in creating a federal licensing system to bridge gaps created by these unlawful actions, but instead in the federal government’s challenging these actions and any other measures that discriminate against ORR in exercising its legal obligations to care for unaccompanied children. The comments below detail our concerns and recommendations.
