Examples of Dual Enrollment Involving ORR-Funded Refugee Programs

DCL 25-06

Initially published December 20, 2024
Revised December 31, 2024
Revised January 7, 2025
Revised January 23, 20251

Dear Colleague:

ORR is publishing this Dear Colleague Letter (DCL) with ACF-ORR-RPB Policy Letter 25-02, Dual Enrollment Involving ORR-Funded Programs, to provide examples of requirements and considerations about dual enrollment. Each example includes information about the programs involved, a sample scenario, and some factors to consider. Note that all requirements of each program in which an individual is enrolled apply.

I. Examples

  1. Refugee Cash Assistance (RCA), Refugee Support Services (RSS), and Matching Grant (MG)
    1. Program Descriptions:
      1. RCA benefits help ORR-eligible individuals meet their most basic needs, such as food, shelter, and transportation, and are generally equivalent to public cash benefits established by State governments. Unless exempt or non-employable, individuals receiving RCA benefits are required to participate in RSS employment services designed to facilitate self-sufficiency through employment, such as employability assessments, job training, job placement and follow-up, English language training, and other targeted services. A variety of other services, such as on-the-job training, transportation, translation and interpreter services, and case management are also authorized and funded under RSS.
      2. The MG Program helps ORR-eligible individuals who are not receiving federal financial assistance, including RCA, to achieve self-sufficiency through employment within 240 days2 of enrollment after their arrival in the United States, by providing intensive case management and employment services. MG services and benefits may also include housing and utilities assistance, food assistance, transportation, cash allowance, health and medical assistance, English language training, social adjustment and integration, and other support services.
    2. Scenario:
      Mr. A is a single father and a recently arrived refugee enrolled in the MG Program. Mr. A needs English language training but has not participated since he does not have child care for his daughter. As an MG participant, Mr. A is not eligible to receive RSS employment services: those would be duplicative of the MG employment services, an essential feature of the MG program. However, Mr. A is eligible for non-duplicative RSS employability services. Upon learning of Mr. A’s barriers to employment, the MG case manager works closely with the RSS case management team to enroll Mr. A and his daughter in an RSS-funded program that offers both English language training and child care services for ORR-eligible individuals. Mr. A’s dual enrollment in MG and RSS-funded employability services is allowable because the services provided are different, not duplicative, and Mr. A continues to participate in the employment services required for enrollment in the MG program.
    3. Factors to consider:
      1. Most ORR-eligible individuals receive most services through either RCA and its complement of RSS or the MG Program. An RCA enrollee is not eligible for any MG services, and an MG enrollee is not eligible for RCA.
      2. An MG enrollee, however, may participate in RSS-funded employability services, such as English language training and other services described in 45 CFR §§ 400.154(b)-(k), that do not duplicate any employment services provided by the MG Program. A MG enrollee may not participate in RSS-funded employment services (as delineated in 45 CFR § 400.154(a)).
      3. A service provider may view employment services as those explicitly designed to help individuals obtain employment, and employability services as designed to enable individuals to improve their employability or work skills. For example, the employment service of providing referrals to job opportunities helps an individual find and secure a specific job; the employability services of transportation assistance for work and English language training both increase an individual’s ability to be employed.
      4. The individual must have a MG Self Sufficiency Plan (SSP), as a required service under MG.
      5. Since a MG enrollee is ineligible for RSS-funded employment services, the RSS provider cannot prepare an RSS Family Self Sufficiency Plan (FSSP) for the client. However, the RSS provider would be required to document the employability services the client receives through RSS and encouraged to share any crucial case updates with the MG case management team.
  2. MG and Refugee Career Pathways (RCP):
    1. Program Descriptions:
      1. The MG Program helps ORR-eligible individuals who are not receiving federal financial assistance, including RCA, to achieve self-sufficiency through employment within 240 days3 of enrollment after their arrival in the United States, by providing intensive case management and employment services. MG services and benefits may also include housing and utilities assistance, food assistance, transportation, cash allowance, health and medical assistance, English language training, social adjustment and integration, and other support services.
      2. The RCP Program helps ORR-eligible individuals achieve self-sufficiency by obtaining the necessary credentials, education, experience, and job skills to secure employment in professional and/or skilled career fields. RCP participants learn about career pathways and develop personalized career development plans for career entry and advancement. RCP participants also receive the necessary training and technical assistance to begin their careers and acquire the resources and knowledge they need to succeed.
    2. Scenario:
      Ms. M is a former nurse who became an asylee in 2023. She enrolled in MG to receive employment services and other support services. She also enrolled in RCP to learn about the process to resume her nursing career. Ms. M is interested in attending nursing school in the future and receiving credential recognition services. Ms. M’s enrollment in MG and RCP programming is allowable because the services provided are different, not duplicative, and Ms. M continues to participate in the employment services required for enrollment in the MG program.
    3. Factors to consider:
      1. A MG enrollee may participate in RCP employability programming if it does not duplicate any employment services provided by the MG Program.
      2. All programmatic requirements for each program remain. While RCP services may help Ms. M enter the nursing field in the U.S., MG services and requirements, including the obligation for early employment, must be prioritized, since MG is the main source of her initial resettlement services.
      3. Since not all agencies offer all programs, the services and benefits will depend on the specific programs offered by service providers in the area.
  3. Unaccompanied Refugee Minors (URM) and Job Corps, a non-ORR training program for youth
    1. Program Descriptions: 
      1. Through its network of providers, the URM Program provides a range of foster care placements to eligible children and youth who arrive in the United States without a parent or guardian, as well as the necessary care and services to help these children and youth develop appropriate skills to transition to adulthood. Children and youth in the URM Program receive access to critical services such as support for housing, food, clothing, and other necessities, case management services, and coordination of immigration assistance.
      2. Job Corps (JC) is a non-ORR career training program administered by the U.S. Department of Labor. JC participants are low-income 16- through 24-year-olds who are U.S. citizens, legal U.S. residents or residents of a U.S. territory, or individuals who are authorized to work in the United States. JC is a full-time program that helps eligible youth complete their high school education, trains them for meaningful careers from one of 10 industries, and assists them with obtaining employment. Most JC participants are housed on one of the organization’s 120+ residential campuses located throughout the United States. There are a few non-residential campuses where JC participants have training for between 8 months and 3 years, depending on type of training, pace, etc.
    2. Scenario:
      Ms. Z is a 17-year-old minor who is currently placed with a foster family through the URM Program. While attending a career fair at her high school, Ms. Z learns about Job Corps, a non-ORR career training program administered by the U.S. Department of Labor that helps eligible youth ages 16-24 complete their high school education, trains them for meaningful careers, and assists them with obtaining employment. Ms. Z decides to enroll in Job Corps where she will receive housing, a living allowance, and career training. Ms. Z will remain in the URM program to receive case management and other ORR-funded services or benefits not provided through Job Corps. Ms. Z’s enrollment in URM and Job Corps is allowable if the services provided are not duplicative.
    3. Factors to consider:
      1. The URM program is a comprehensive yet flexible program that provides wraparound services for children and youth, comparable to youth in domestic foster care. Just like other youth, URM participants have the option to go to college and other pursue training opportunities, such as those offered by Job Corps. URM services are adjusted, as needed, to ensure that URM and JC assistance is complementary, not duplicative.
  4. Services to Afghan Survivors Impacted by Combat (SASIC) and PC:
    1. Program Descriptions:
      1. The SASIC Program supports eligible Afghans and their families in addressing and overcoming severe and long-lasting trauma. Through the SASIC Program, ORR seeks to create a national network of culturally responsive providers specialized in meeting the needs of Afghans who have experienced trauma. SASIC recipients provide direct services, such as medical, psychological, and social work services.
      2. The PC Program supports ORR-eligible individuals with challenging needs that require special attention, such as those with serious medical conditions or experiencing mental health challenges (including trauma resulting from war and/or other violence), women at risk, and elderly refugees without a support system. Services in the PC Program include long-term case management, social adjustment services, and mental health interventions.
    2. Scenario:
      Ms. T is an Afghan humanitarian parolee who is eligible for ORR benefits and services, including those funded by the Afghanistan Supplemental Appropriations Act, 2022, and the Additional Afghanistan Supplemental Appropriations Act, 2022 (hereinafter collectively referred to as “ASA”).  After arriving in the United States, Ms. T was diagnosed with Post-Traumatic Stress Disorder, and she needs mental health services. Ms. T receives assistance from a service provider that offers both SASIC and PC services, and she is eligible for mental health services under both programs. The SASIC program is specifically designed to provide culturally and linguistically tailored mental health services for eligible Afghans, so Ms. T is enrolled within SASIC rather than PC. Not only does the agency feel that SASIC mental health services are better suited for Ms. T, but the agency also decides that using the dedicated funding stream for Afghan arrivals is the most effective use of their funds, since they can use the PC program for non-Afghans who require similar assistance. The agency does, however, enroll Ms. T in the PC program for services not available through SASIC (e.g., emergency cash assistance).
    3. Factors to consider:
      1. The SASIC and PC Programs have similar goals and services. However, since the SASIC Program is specifically designed to provide culturally and linguistically tailored mental health and other services for ORR-eligible Afghan arrivals, an agency might consider enrollment in the SASIC Program most appropriate for Ms. T.
      2. An individual can be enrolled in SASIC and enrolled in the PC program for services not available through SASIC (e.g., emergency cash assistance). An individual cannot be enrolled in both SASIC and another mental health or trauma-service program (e.g., ORR’s Survivors of Torture Program) if the same services would be provided, since their services would be duplicative.
      3. All requirements of both programs apply. In this scenario, that would include the development and documentation of both a SASIC Individual Self-Sufficiency Plan and a PC Self-Sufficiency Plan.
  5. PC and Refugee Health Promotion (RHP)
    1. Program Descriptions:
      1. The PC Program supports ORR-eligible individuals with challenging needs that require special attention, such as those with serious medical conditions or experiencing mental health challenges (including trauma resulting from war and/or other violence), women at risk, and elderly refugees without a support system. Services in the PC Program include long-term case management, social adjustment services, and mental health interventions.
      2. The goal of the RHP Program is to promote the health and well-being of ORR-eligible individuals by: 1) providing opportunities to increase health literacy, 2) coordinating health care, and 3) organizing wellness groups. RHP grant recipients are responsible for ensuring that the program’s services complement, but do not duplicate, other ORR-funded activities.
    2. Scenario:
      Shortly after Mr. W’s arrival in the United States, he began receiving mental health case management services through the PC Program to address depressive episodes. He is also enrolled in the RHP Program to participate in RHP “Wellness Group” activities since the PC provider does not offer psychosocial group activities. Mr. W’s participation in both programs is allowable and not duplicative because the specific services he is receiving under the RHP are not provided under the PC program.
    3. Factors to consider:
      1. All requirements of both programs apply, including the development and documentation of a PC Self-Sufficiency Plan and reporting required by the RHP program.

For more information or if you have questions about a dual enrollment situation, reference program-specific policy and contact your ORR Program Officer(s), Regional Representative/Analyst, or Health Liaison, as applicable.

 

Thank you for your work and dedication to ensure that children and families have continued access to critical services.

 

Sincerely,

Robin Dunn Marcos
Deputy Assistant Secretary for Humanitarian Services
Director, Office of Refugee Resettlement
Administration for Children and Families

 

Footnotes

1 Removal of previous section II.

2 December 31, 2024: Corrected from “12 months” to “240 days.”

2 January 7, 2025: Corrected from “12 months” to “240 days”.