Age Determination Practices for Unaccompanied Alien Children in ...

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that reflects age determination procedures released in final form byHHS.In addition, while ICE’s 2004 guidance shares many similaritieswith HHS’ 2009 procedures, as we report, both documents offerguidance not contained in the other. ICE can improve its fieldguidance by including, at minimum, elements of both policies suchas challenges associated with age determinations, the limits ofusing radiographs, and how to handle ambiguous radiographicexam results. By incorporating these subjects into new fieldguidance ICE can enhance its existing field instructions and equipboth new and more experienced field officers and agents with basicprocedures for handling different types of cases.Recommendation #3: Release guidance on the selection of "bestqualified" practitioners to conduct radiographic exams and reportresults when practical.ICE Response: ICE concurred with our recommendation and saidthat it will work with its Division of Immigration Health Servicesto develop such guidance.OIG Evaluation: This recommendation is resolved, but remainsopen pending receipt of such guidance. Making field officersaware of medical or dental professionals certified in forensics canfacilitate acquisition of a more credible age estimation under tighttime constraints.Age Determination Practices for Unaccompanied Alien Children in ICE CustodyPage 21
Appendix APurpose, Scope, and MethodologyIn a House Report associated with the Consolidated Security,Disaster Assistance, and Continuing Appropriations Act, 2009(P.L. 110-329), 5 the House Appropriations Committee voicedconcern that DHS had “not ceased its reliance on bone and dentalforensics for child age determination, as directed” in a previousreport. This previous report suggested that ICE use holistic agedeterminationmethodologies. 6 The House AppropriationsCommittee also asked us to report on any cases in which bone anddental forensics were used in FY 2008 or 2009. 7At the request of the House Committee on Appropriations, wereviewed ICE’s age determination practices for those in itscustody, focusing on the use of dental and skeletal radiographs.Our objectives were to (1) identify the practices and proceduresICE used to determine the age of undocumented detainees held inICE custody in fiscal 2008 and 2009; (2) determine whether ICEimplemented age determination methodologies as identified inHouse Report 110-181, attached to P.L. 110-161; and(3) document any cases where ICE relied on bone and dentalforensics for child age determinations in FY 2008 and 2009.We conducted field work at ICE headquarters in Washington, DC,and the National Records Center in Lees Summit, MO. Weinterviewed headquarters staff at ICE DRO, and field officejuvenile coordinators at DRO offices nationwide via telephone.We also spoke to individuals working in the health care, academic,and advocacy communities across the United States on the use ofradiographs for determining an individual’s age.We reviewed 89 A-files to assess how radiographs are used in agedeterminations, what other evidence ICE collects for this purpose,and how radiographic exams are presented to ICE. We reviewedand analyzed applicable laws, policy documents, records, andnongovernmental reports and journal articles relating to agedeterminations.We conducted our review between March and June 2009 under theauthority of the Inspector General Act of 1978, as amended, andaccording to the Quality Standards for Inspections, issued by theCouncil of the Inspectors General on Integrity and Efficiency.5 H.R. 110-862. 6 H.R. 110-181. 7 Pursuant to the House Appropriations Committee’s request, we focused on ICE’s practices for agedeterminations exclusively, and did not examine CBP’s role in making age determinations forunaccompanied alien children. Age Determination Practices for Unaccompanied Alien Children in ICE CustodyPage 22
Page 3: Table of Contents/AbbreviationsExec
Page 8: Figure 1. Age Determinations in DHS
Page 12 and 13: process and indicated that notice o
Page 14 and 15: According to ICE’s guidance, sour
Page 16 and 17: do not use radiographic exams, othe
Page 18 and 19: In response to the TVPRA, HHS relea
Page 20 and 21: marking the date an age determinati
Page 22 and 23: proximity to the office. Other coor
Page 26 and 27: Appendix BManagement Comments to th
Page 28 and 29: Appendix CMajor Contributors to Thi
Page 30: ADDITIONAL INFORMATION AND COPIESTo

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