and systems The Secretary of Health and Human Services shall establish the necessary infrastructure and systems for the appropriate identification, recruitment, training, and oversight of counsel available to provide assistance and representation to unaccompanied children under subsection (b) without charge to the child. (d) Model guidelines on legal representation of children (1) Development of guidelines The Director of the Office of Refugee Resettlement, in consultation with the Director of the Executive Office for Immigration Review, the Secretary of Homeland Security, and nongovernmental stakeholders with relevant expertise in providing immigration-related legal services to children, shall develop model guidelines for the legal representation of unaccompanied children in immigration proceedings, which shall be based on— (A) the 2018 report of the American Bar Association entitled Standards for the Custody, Placement and Care