CLINIC is among the thousands of organizations and individuals that submitted comments in response to the Department of Homeland Security and the Department of Health and Human Services’ Notice of Proposed Rulemaking (NPRM) entitled “Apprehension, Processing, Care, and Custody of Alien Minors and Unaccompanied Alien Children.” CLINIC opposes the NPRM which would eviscerate the protections currently in place under the Flores Settlement Agreement. As detailed in our 60-page comments, there is no justifiable reason to implement a rule change that will increase and prolong the detention of children. The only way for DHS and HHS to comply with the Flores Settlement Agreement is to rescind this NPRM.