The 448,000-Child Handoff: How HHS Releases Migrant Kids to Addresses It Never Checks — and Then Stops Looking

Between fiscal years 2019 and 2023, the Department of Homeland Security transferred more than 448,000 unaccompanied migrant children to the Department of Health and Human Services, which placed nearly all of them with "sponsors" and closed the files. More than 31,000 of those release addresses were blank, undeliverable, or missing apartment numbers, and ICE officers in the field told the DHS Inspector General that the addresses HHS collected were wrong roughly 80 percent of the time. Over the same period, HHS's Office of Refugee Resettlement waived home studies for the sponsors of 79,143 children while conducting only about 7,000, and released 11,488 children to non-parent sponsors who were never fingerprinted or background-checked at all. The government's own position, stated under oath and never retracted, is that this is legal: ORR "is not legally responsible for children after they are released from ORR care." No state child welfare agency is told a federal child has landed in its jurisdiction. Meanwhile, the shelter contractors paid to hold those children before release — Southwest Key, BCFS, and a handful of others — booked billions of dollars on a per-child, per-day model that pays for beds, not for outcomes.

How the pipeline actually works

The legal architecture dates to two statutes. The Homeland Security Act of 2002 (§ 462) stripped custody of unaccompanied children from the immigration enforcement agency and gave it to ORR, a small refugee office inside the Administration for Children and Families. The Trafficking Victims Protection Reauthorization Act of 2008 (codified at 8 U.S.C. § 1232) then required DHS to transfer non-Mexican unaccompanied children to HHS within 72 hours and directed HHS to place each child "in the least restrictive setting that is in the best interest of the child."

In practice that means: Border Patrol apprehends a child, refers them to ORR, ORR places them in a grantee-run shelter, and a case manager works to identify a sponsor. Sponsors are ranked in categories — Category 1 (parent or legal guardian), Category 2 (close relative: brother, sister, aunt, uncle, grandparent), Category 3 (distant relative or unrelated adult). ORR runs public-records and sex-offender checks on all sponsors; FBI fingerprint checks and state child abuse and neglect registry checks are required only for certain categories or when a red flag appears. A home study — an actual investigation of the living conditions, the standard of care, and interviews with the sponsor and other household members — is mandatory under 8 U.S.C. § 1232(c)(3)(B) only in a narrow set of cases, most notably when the child is a confirmed victim of a severe form of trafficking, is a child with disabilities, or has been a victim of abuse.

Everything else is discretionary, and ORR's own policy guide says so explicitly: "In times of high volume home study referrals, ORR reserves the right to except certain sponsors from its ORR mandated home study requirements in its discretion and subject to available resources."

That sentence is the load-bearing wall of this entire system. It converts the most meaningful safeguard — a human being physically entering the home a child is about to be sent to — into a budget line that gets cut first when volume rises. And volume rose: 138,917 children released in calendar year 2021 and 124,781 in 2022, of whom 16,456 and 18,004 respectively went to distant relatives or non-family sponsors.

Once the child walks out the shelter door, the federal safety net consists of two things: a "Safety and Well-Being Follow-Up Call" placed 30 days after release, and — for a minority of children — Post-Release Services (PRS), a case-management referral. ORR has described PRS as reaching roughly the top 20 percent most vulnerable children in its care. For the other four out of five, the 30-day phone call is the entire post-placement child welfare system of the United States government.

What the watchdogs found

The HHS Office of Inspector General audited that system and published the results in 2024 (OEI-07-21-00250). Reviewing case files from a period of high referrals, OIG found that in 16 percent of children's case files, one or more required sponsor safety checks lacked any documentation that they were ever conducted. In 19 percent of cases where a child was released to a sponsor with a pending FBI fingerprint check or state child abuse registry check, the file was never updated with the results — the check came back, or didn't, into a void. In 22 percent of cases, the 30-day follow-up call was not made on time; in 18 percent, no call was documented at all. And in 35 percent of files, the sponsor-submitted identification documents had legibility problems — meaning the government could not reliably read the ID of the adult it was handing a child to.

The DHS Inspector General took the other end of the pipeline. In a March 2025 management alert (OIG-25-21), it reported that ICE "cannot effectively monitor the location and status of all unaccompanied alien children after federal custody." As of October 2024, more than 43,000 children served with Notices to Appear had failed to show up for immigration court. As of January 2025, ICE had never served Notices to Appear on more than 233,000 children at all — meaning those children have no court date, no docket, and no scheduled moment at which anyone would notice their absence. Multiple DHS field offices confirmed to auditors that HHS had released children to incomplete or commercial addresses; at one field office, officers found 34 children released to two addresses that did not exist.

The most cited figure — that HHS "lost contact with 85,000 children" — comes from New York Times reporter Hannah Dreier's Pulitzer-winning 2023 series Alone and Exploited, which found HHS could not reach more than 85,000 children on follow-up calls over roughly two years and lost immediate contact with about a third of children released. HHS has disputed the framing, arguing an unanswered phone call is not a missing child. That defense is weaker than it sounds: an unanswered call is the only instrument the agency built, and when it fails, nothing else is triggered. There is no second attempt protocol with teeth, no home visit, no referral to local police, no notification to the state.

This is not new information to the federal government. In 2016, the Senate Permanent Subcommittee on Investigations, chaired by Rob Portman with Claire McCaskill as ranking member, published Protecting Unaccompanied Alien Children from Trafficking and Other Abuses: The Role of the Office of Refugee Resettlement. The investigation was opened after HHS placed eight Guatemalan children with a labor trafficking ring that forced them to work up to 12 hours a day at Trillium Farms egg operations in Marion, Ohio, while living in dilapidated trailers. Ringleader Aroldo Castillo-Serrano was sentenced to 188 months — more than 15 years — in federal prison; the defendants were ordered to pay $67,230 in restitution. Parents in Guatemala had paid him up to $15,000 on the promise their children would attend school.

Ten years later, the structural fix the subcommittee demanded has still not been built.

The money

The federal accounts are CFDA 93.676 (Unaccompanied Alien Children Program) and CFDA 93.566 (Refugee and Entrant Assistance). Together they have moved an extraordinary amount of money through a very small number of hands.

Southwest Key Programs, Inc. (Austin, TX) was the largest shelter operator in the country, holding roughly $3 billion in cumulative HHS awards. USAspending records show individual award lines including $546 million (FY2014), $468.2 million and $395.0 million (FY2018), and $412.7 million and $400.5 million (FY2022). In FY2024 the organization reported $921.5 million in revenue against $928.2 million in expenses, and in the twelve months preceding January 2025 it received at least $861 million from the federal government across 101 transactions — approximately $860.66 million of it from HHS. Its founder, Juan Sánchez, drew scrutiny for compensation nearing $1.5 million in 2016; in 2017 he received roughly $784,000 in base salary plus $238,500 in bonus, alongside a $2.5 million cash-value life insurance and retirement policy. He left in 2019. In FY2024, the top-paid executive, Anselmo Villarreal, was compensated $1.1 million.

BCFS Health and Human Services (San Antonio, TX; EIN 74-1260710), formerly Baptist Child & Family Services, shows the per-bed model at its most extreme. Its Form 990 filings report revenue of $537.5 million in FY2019, $873.3 million in FY2020, $4.436 billion in FY2021, $2.661 billion in FY2022 — and then a collapse to $246.1 million in FY2023. The FY2021 spike tracks the emergency intake sites stood up during the 2021 surge, including the Fort Bliss site near El Paso built for up to 5,000 beds. Employee headcount over the same period barely moved: 3,503 in FY2020, 3,236 in FY2021. A nonprofit whose staffing stayed flat while revenue grew five-fold in one year is not scaling services; it is scaling billing. Aggregated officer compensation in BCFS filings peaked at $985,913. Co-founder Kevin Dinnin has since moved to lead the affiliated FirstDay Foundation.

The unit economics explain the spike. HHS has used a figure of roughly $775 per child per night for influx facility care — a number it has recycled since at least 2018 — and those facilities are paid to stand ready whether or not children are in the beds. The HHS OIG found that at the Homestead, Florida influx facility, operated under contract by Comprehensive Health Services, ORR did not follow federal competition regulations and paid approximately $67 million to keep Homestead fully staffed and equipped for nearly three months after the last child had left.

Set that against the post-release side of the ledger. A home study — the single intervention most likely to prevent a child from being delivered to a trafficker — costs a small fraction of one child-month in an influx bed. ORR conducted roughly 7,000 of them across four years while releasing hundreds of thousands of children. The program is not underfunded. It is funded at the wrong end.

Named failures

Southwest Key. In July 2024, the Justice Department sued Southwest Key in the Western District of Texas, alleging a pattern of "severe or pervasive sexual harassment" of children in its shelters dating to at least 2015 — including "severe sexual abuse and rape, solicitation of sex acts, solicitation of nude photos." The complaint alleged one employee repeatedly abused three girls, ages 5, 8, and 11, at the Casa Franklin shelter in El Paso, entering their bedrooms at night; another, at a Mesa, Arizona shelter, took a 15-year-old boy to a hotel and paid him for sexual acts over several days in 2020. It further alleged Southwest Key discouraged children from disclosing abuse, in violation of federal requirements. In March 2025, DOJ dismissed the case — not because the allegations were resolved, but because HHS had stopped placing children with Southwest Key and opened a grant review. The company furloughed roughly 5,000 employees and laid off nearly 1,500. No adjudication of the allegations was ever entered. No damages were paid to any child.

The unlicensed shelters. On June 10, 2026, the HHS Inspector General reported that ORR failed to adequately monitor unlicensed Unaccompanied Children Program care providers' compliance with background check requirements. Some ORR-funded facilities operate in states that no longer license or inspect them at all. ORR was supposed to conduct abbreviated monitoring visits roughly every 90 days; it did not do so, or did not do so timely. In January 2024, ORR itself disclosed to OIG that an unlicensed provider had never conducted the required national FBI fingerprint-based background checks on staff — only state-level checks. ACF partially concurred with the first recommendation and concurred with the second.

The children who went to work. Federal investigators examined whether 50 children — some as young as 13 — illegally employed cleaning Midwestern slaughterhouses for Packers Sanitation Services Inc. were labor trafficking victims; Homeland Security Investigations agents interviewed children who had cleaned the JBS plant in Grand Island, Nebraska. Some were unaccompanied minors released by ORR to sponsors. On July 14, 2023, Duvan Tomas Perez, 16, was killed at the Mar-Jac Poultry plant in Hattiesburg, Mississippi, pulled into a machine he was cleaning. He was legally too young to be in the building — federal law bars anyone under 18 from meatpacking work — and had been hired on the identity of a 32-year-old man. OSHA cited Mar-Jac for 17 violations with $212,646 in proposed penalties. His mother sued.

The 344. An internal ORR audit found the government had released 344 children to non-family sponsors who were already hosting three or more other unaccompanied children. Under the current architecture, that is not a rule violation. It is not even an automatic flag.

The accountability gap, named precisely

The gap is not an oversight. It is a jurisdictional design.

When a state child welfare agency places a child, the child remains in that agency's legal custody, a court retains jurisdiction, a guardian ad litem is appointed, caseworkers make mandated visits, and any adult who suspects abuse is a mandated reporter with a hotline to call. When ORR places a child, none of that attaches. The child is not in federal custody, not in state custody, and not in any court's protective jurisdiction. Acting Assistant Secretary Steven Wagner testified to the Senate in 2018 — after disclosing that ORR could not determine the whereabouts of 1,475 children — that it is "HHS' long-standing interpretation of the law that ORR is not legally responsible for children after they are released from ORR care."

State CPS agencies are generally notified only after the fact, when ORR develops derogatory information about a sponsor or household member. There is no routine notification at placement. A county child protection office can have four hundred federally placed children living inside its borders and no list of them, no addresses, and no legal trigger to check.

GAO has been pushing on this for a decade. Its 2016 report (GAO-16-180) found ORR had limited information about the post-release services it was paying for. In its 2025 follow-up (GAO-25-107840), GAO reported ORR had fully addressed five of nine recommendations; the recommendation on grantee follow-up with children and sponsors after release remains only partially addressed, and GAO says it will close the post-release services recommendation only when ORR finishes building a case management system capable of tracking those services at all. The HHS OIG currently has an open review of ORR's National Call Center — the helpline children and sponsors are supposed to use — examining what the center actually did when someone called about a child's safety after release.

What changed in 2025–2026, and why it didn't fix this

The current administration has replaced a missing-persons problem with an enforcement program. In 2025 ORR issued an interim final rule rescinding the Biden-era Foundational Rule provision that barred disqualifying sponsors solely on immigration status and barred sharing sponsor immigration information for enforcement purposes. Since January 2025, according to internal data reviewed by Reuters in July 2026, ORR has shared more than 460,000 "leads" with ICE about children, sponsors, and household members; more than 12,000 people have been arrested on the strength of them. In November 2025, ICE launched the "UAC Safety Verification Initiative" with 287(g) state and local partners to run welfare checks on roughly 450,000 children released under the prior administration, reporting more than 24,400 children located through door-knocks by mid-November and planning a call center handling 6,000–7,000 calls a day.

Locating children is a legitimate objective. But routing it through the deportation agency inverts the incentive that makes any child protection system function: the willingness of the adult in the home, and the child, to pick up the phone. Advocates and reporters have documented ICE arresting relatives who came forward to claim children from shelters. The measurable result is that children are stuck: average time in ORR custody rose from 30 days in FY2024 to 194 days in June 2026. At the same time, the government terminated the Acacia Center for Justice contract that funded roughly 100 legal service providers serving more than 20,000 children, and shelter capacity contracted sharply — New York's bed count was cut roughly in half, with providers across Michigan, California, and Illinois filing layoff notices totaling about 1,000 jobs. In February 2026, children in ORR shelters sued HHS in Diego N. v. U.S. Department of Health and Human Services, No. 1:26-cv-00577 (D.D.C.), challenging the re-detention of children already released to approved sponsors and the requirement that those sponsors reapply.

Neither administration built the thing that was missing. One released children fast and lost them. The other holds them for six months and hunts their families. In both models, no child welfare agency ever gets custody, and no one is accountable for what happens on day 400.

Why it matters, and what would actually fix it

These are children the United States government physically took possession of. Whatever anyone believes about immigration, the moment federal agents put a 14-year-old in a van, the government assumed a duty of care that does not evaporate at a sponsor's front door. Every failure documented above — the illegible IDs, the waived fingerprints, the nonexistent addresses, the unanswered 30-day call — is a point where a trafficker's paperwork was accepted at face value by a system that had already been paid.

Five changes would close most of the gap, and none require a new statute beyond appropriations language:

1. Verify the address before release, not after. Every release address should be validated against USPS and commercial address databases and screened for repeat use. A sponsor address already associated with three unrelated children should be a hard stop requiring a home study, not a footnote in an audit.
2. Make home studies mandatory for every Category 3 and every non-parent Category 2 placement, and strike the "subject to available resources" discretion. Fund it by moving money out of standby influx capacity, where HHS has demonstrably paid tens of millions for empty beds.
3. Notify the state and county child welfare agency at placement, every time. Pair it with a federally funded child welfare liaison in each receiving state so notification produces a case, not a filing. Children placed in a state should be visible to the agency legally charged with protecting children in that state.
4. Fund post-release services for 100 percent of children for at least 12 months, with in-person contact requirements and a documented escalation path when contact fails — a second visit, then a referral to local child protective services, not a closed file.
5. Firewall child safety reporting from immigration enforcement, and publish grantee performance data — significant incident reports, substantiated abuse findings, staff background check compliance — as a condition of every award. A shelter operator that has paid out on abuse allegations should not be able to bid on the next cohort with a clean public record because the lawsuit was dismissed for reasons unrelated to the facts.

The federal government spends roughly $775 a night to hold one of these children. It spends nothing at all to find out whether they are alive a year later. Until that ratio changes, every reform is theater — and the next Marion, Ohio is already fully funded.

Sources: HHS OIG, Gaps in Sponsor Screening and Followup Raise Safety Concerns for Unaccompanied Children (OEI-07-21-00250) · DHS OIG, ICE Cannot Effectively Monitor the Location and Status of All Unaccompanied Alien Children After Federal Custody (OIG-25-21, Mar. 2025) · HHS OIG, ORR Needs To Improve Its Monitoring of Unlicensed UAC Program Care Providers' Compliance With Background Check Requirements (June 2026) · HHS OIG, ORR Did Not Award and Manage the Homestead Influx Care Facility Contracts in Accordance With Federal Requirements · GAO-25-107840, Unaccompanied Children: Efforts by ORR to Address GAO Recommendations · GAO-16-180, Unaccompanied Children: HHS Can Take Further Actions to Monitor Their Care · Sen. Grassley, New HHS Data Confirms… Tens-of-Thousands of Migrant Children with Unvetted Sponsors, Declined Recommended Home Studies · Senate PSI hearing, Adequacy of HHS Efforts to Protect Unaccompanied Alien Children from Human Trafficking · DOJ, Leader of Human Trafficking Organization Sentenced to Over 15 Years for Exploiting Guatemalan Migrants at Ohio Egg Farms · DOJ, Justice Department Sues Southwest Key for Sexual Abuse and Harassment of Children in Shelters · Texas Tribune, DOJ drops lawsuit over alleged abuses at migrant shelters · Steven Wagner testimony, Senate Judiciary (May 2018) · Reuters/US News, Thousands of children, sponsors arrested by ICE after tips from US child migrant agency (July 2026) · DHS, ICE and 287(g) Partners Launch Initiative… (Nov. 2025) · Texas Tribune, ICE arresting relatives trying to take custody of migrant kids (July 2026) · NY Focus, NY's Beds for Unaccompanied Minors Evaporate as Feds End Contracts (May 2026) · Acacia Center for Justice statement · NBC News, Report finds more than 340 migrant kids were sent to live with nonrelatives who sponsored other children · NBC News, Feds investigating possible human trafficking of children who cleaned slaughterhouses · NPR, A 16-year-old worker died while working at a Mississippi poultry plant · Pulitzer Prizes, Hannah Dreier, Alone and Exploited · ACF, ORR Unaccompanied Children Program Policy Guide, Section 2 · 45 CFR Part 410 · ACF, ORR Influx Care Facilities Fact Sheet · Form 990 / USAspending records for Southwest Key Programs Inc. and BCFS Health and Human Services (EIN 74-1260710), CFDA 93.676 and 93.566, via PMC CivicOps database.