President Trump’s Department of Health and Human Services has created the Unaccompanied Alien Children Legal Representation Division (UACLRD) to represent migrant children in immigration court proceedings. The federal unit, detailed in a recent Federal Register order signed by Secretary Kennedy, operates under the department’s Office of General Counsel and grants attorneys direct legal advice, explanations of immigration procedures, and courtroom appearances for children traveling alone to the United States.

The division explicitly mandates that its lawyers remain “separate and distinct” from HHS branches advising agencies responsible for child custody and care, including the Office of Refugee Resettlement. This structural separation aims to prevent conflicts of interest, though advocates warn such a firewall’s effectiveness in practice remains unproven.

The move follows an internal HHS review identifying six types of fraud within the Biden administration’s unaccompanied children program—such as falsified identity documents, manipulated photographs, unverified addresses, fingerprint fraud, undisclosed household members, and age misrepresentation. The review found that approximately 85 percent of reviewed cases involved intentional document fraud, with documented incidents including a 15-year-old girl released to an alleged brother who lied about his relationship and a 17-year-old boy who died after being placed with a relative whose documents could not be authenticated.

HHS reported referring roughly 479,000 unaccompanied children to the Office of Refugee Resettlement between 2021 and 2024 and receiving 1,669 reports of suspected fraud over a 13-month period. While details on staffing levels, operational timelines, case assignment protocols, and continued funding for external legal services remain unclear, the administration asserts the new unit authorizes full legal representation without compromising child safety.

Critics argue government-employed attorneys could face pressure to prioritize voluntary departure over advocating for children’s rights, but the order explicitly separates legal representation from custody oversight to address past vulnerabilities in the program.