**10. Harm and Risk Mitigation**

The purpose of a viable custody classification system is to ensure safety and security and contribute to orderly facility operations, by separating and managing detainees based on verifiable and documented data. A thorough screening by qualified personnel during the admissions process is also crucial for the identification of individuals for whom detention would be detrimental to their health and/or wellbeing therefore merit modification of the conditions of confinement, transfer to a suitable facility. Rarely are individuals considered for release, although policy does not prevent it.

In CY2020, ICE tested 80,200 of 137,749 detainees (58%) for COVID-19 and recorded 8622 positive cases (11%) at over 100 immigration detention facilities. Approximately, 30% (2566) of positive COVID-19 cases occurred at the 18 IHSC-staffed facilities whereas the remaining 70% (6056) of cases occurred at facilities operated by contract medical staff or the local health authority. Of the detainees who tested positive for COVID-19 in 2020, approximately 89% (7687) were exposed to the virus while in ICE custody, whereas 5% (435) were exposed before contact with ICE. Eight detainees died while in ICE custody as a result of COVID-19 (GAO-21-414). At least several more are believed to have died in 2020 shortly after their release or removal (Smart et al. 2021). The data strongly sugges<sup>t</sup> adequate screening and testing for COVID-19, correct and consistent use of PPE, sufficient space for quarantine, and information and access to vaccination could have slowed the spread of COVID-19 and saved lives.
