Why OIG Did This Review. HHS frequently addresses issues that transcend a single program. To achieve its mission, HHS needs to collaborate effectively across its internal agencies. In previous work, OIG identified instances in which limited or ineffective internal coordination hampered the Department’s efforts to effectively serve beneficiaries. Accordingly, OIG initiated this review to assess coordination within HHS regarding a Centers for Disease Control and Prevention (CDC) public health order that significantly affected operations of the Office of Refugee Resettlement (ORR), a program office within the Administration for Children and Families (ACF). Specifically, in March 2020, CDC issued a Title 42 order under which most noncitizen children entering the United States without a parent (“unaccompanied children”) were expelled to their home countries. This Title 42 order affected ORR because previously such children would have been referred to ORR for care. Coordination across HHS operating divisions regarding overlapping programs or initiatives is a best practice for effective governance. Our retrospective analysis of the Title 42 order’s development and initial implementation in 2020 serves to identify steps that HHS can take to improve internal coordination in the future and better ensure that ORR has the information necessary to effectively care for unaccompanied children. How OIG Did This Review. This review focuses primarily on events that occurred from March through November 2020. Our findings are based on interviews with officials and staff within CDC and ACF; written responses to questions submitted to CDC, ACF, and others within HHS; and internal HHS documents, such as emails and memoranda. We also reviewed relevant public documents. We conducted a qualitative analysis of these materials to establish the timeline and content of coordination between CDC and ORR; the context for that coordination; and factors that assisted or challenged effective coordination to protect the well-being of unaccompanied children and to address the impact of the Title 42 order on ORR operations.
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