The International Rescue Committee (IRC) in Florida stands in strong opposition to the Department of Children and Families’ proposed ruling, “65C-9.004: Standards for Unaccompanied Alien Children Homes and Unaccompanied Refugee Minor Programs,” as issued on February 10th, 2022.

The IRC is an international organization that helps people affected by humanitarian crises to survive, recover and rebuild their lives. Since 1960, the IRC has proudly offered a range of services to refugees, asylees, Special Immigrant Visa (SIV) recipients, survivors of trafficking, and unaccompanied children arriving in the state of Florida. The IRC’s offices in Miami and Tallahassee work with unaccompanied children and their families to offer home studies and post-release services; case managers work with families to ensure the home is safe and appropriate for the child, address any identified case management needs, connect families to local resources, and build the family’s competency towards self-sufficiency. 

This proposed rule would prevent a residential child-caring agency, child-placing agency, or foster home that cares for unaccompanied children from obtaining or renewing their state license. This proposed rule would also mandate welfare checks on unaccompanied children after being reunited with their families. Taken together, the IRC believes the proposed rule will harmfully impact the safety and wellbeing of unaccompanied children arriving in Florida.

Reasons for Opposition:

A. The proposed rule departs from Florida’s proud history of offering safe haven to children, and is not supported by the public.

  1. Florida has a long and proud history of welcoming unaccompanied minors for over half a century. After the Castro takeover, Cuban families were desperate to send their children to a place where they would be safe and have access to opportunity. From 1960 to 1962, Florida brought in more than 14,000 children from Cuba, a process that the IRC was a part of facilitating.
  2. Unaccompanied children arriving in the US today are just as deserving of safety, protection, and opportunity as they were in the 1960s. Unaccompanied children are forced to flee their homes due to persecution, trafficking, or violence – sometimes at the hands of their own government. They have endured long and arduous journeys while seeking safety and hoping to reunite with parents and family. When these children arrive in Florida, they deserve to be met with a safe environment that provides for their basic needs and supports their mental, emotional, and physical wellbeing. 
  3. Programs that support unaccompanied children are first and foremost family reunification programs: over 80% of unaccompanied children are reuniting with a close family member in the United States, and over 40% of these children are reuniting with a parent or legal guardian.[1] A recent poll found that a majority of Americans believe that reuniting separated family members and providing safe treatment for unaccompanied children should be the government’s utmost priority.[2]

B. Refusing to issue or renew state licenses to shelters only results in the loss of experienced practitioners, while compounding children’s trauma.

  1. Since the 1990s, state licensed shelters have developed and maintained rigorous standards for care and protection of unaccompanied children. The closure of such state-licensed facilities will only transition children into the care of unlicensed facilities, and result in the loss of agencies and staff with the valuable expertise working with unaccompanied children.
  2. It is widely a shared value and best practice in the child welfare sector that reuniting children with their parents and families offers the best outcomes for a child’s health and well-being, and that separation can lead to long-lasting, harmful effects.[3] Many unaccompanied children are sent to Florida in order to be as close as possible to parents or family members who are already Florida residents. The closure of state-licensed facilities in Florida may result in unaccompanied children being temporarily placed in shelters in other states. This will unnecessarily extend their painful separation and compound children’s trauma.
  3. The Florida Department of Children and Families is charged with helping children, not adding to their trauma. The Department should thus be invested in easing children’s path to reunification with their family. 

C. The current system of support for unaccompanied children after they are reunited with family builds trust and leads to voluntary participation in services. The proposed mandated welfare checks are unnecessary, invasive, and damage trust between children and families and their new communities.

  1. After unaccompanied children are reunited with their parents or placed with sponsors, community-based organizations such as the IRC offer individualized and trauma-informed home study and post-release services. Providers work hard to foster an environment of trust, safety, and communication – one which encourages the majority of families to gladly accept post-release services and raise support needs without fear.
  2. This system ensures children are able to smoothly transition into their new communities, receiving cultural orientation, support enrolling in school, referrals to legal services, resources for learning English as a second language, and more. Parents are empowered to help their children navigate these milestones; critically, they are provided with the information about upcoming immigration hearings and procedures that will protect their children’s ability to stay in the US.
  3. Mandating invasive and duplicative government check-ins will create a culture of fear among sponsoring families and compound the trauma experienced by unaccompanied children. These check-ins are likely to have a chilling effect, making families less likely to seek out support when encountering challenges.
  4. This ruling will moreover work against the efforts of community-based providers of post-release services who have built trust with unaccompanied children and their families. Florida’s Department of Children and Families should be further investing in evidence-based models and practices that demonstrate success, rather than measures that will harm existing service provision and make it harder for children to successfully integrate into their new communities.


The current system of care reflects a shared set of values: families belong together and all children should be safe and have access to opportunity, regardless of where they were born. The IRC urges Florida’s Department of Children and Families to rescind the proposed ruling in its entirety. Instead, Florida should dedicate its efforts towards practices that best care for unaccompanied children and facilitate their reunification with family.

To learn more about the work of the IRC in Florida and for information on how you can get involved with the IRC as a donor or volunteer, please contact us at [email protected]

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[1] “Statement by Homeland Security Secretary Alejandro N. Mayorkas Regarding the Situation at the Southwest Border,” Department of Homeland Security, 03/16/2021,

[2]  “Public is Concerned about Biden’s Handling of Immigration and Border Security,” Associated Press/NORC at the University of Chicago, 4/5/2021,

[3] “The Child Welfare Placement Continuum: What’s Best for Children?” National Conference of State Legislatures, 11/3/2019,