Child Support Enforcement: Certification Process for State Information
Systems (Letter Report, 06/15/98, GAO/AIMD-98-134).
Pursuant to a congressional request, GAO reviewed the Department of
Health and Human Services (HHS) certification process for state child
support enforcement systems, its administration of the process and the
certification status of the state systems.
GAO noted that: (1) certification guidance issued by the Office of Child
Support Enforcement (OCSE) addresses the system requirements of the
Family Support Act of 1988 and HHS' implementing regulations; (2)
analysis of the certification process shows that OCSE has administered
this process consistently across states since it began certifying child
support enforcement systems in 1993; (3) it has used the same guidance
for certification reviews and conducted reviews that were similar in
scope and length for each level of certification; (4) while OCSE
published many certification reports on the results of its certification
reviews, its reporting was not always consistent; (5) as of March 31,
1998, OCSE had either certified or conditionally certified 25 of the 54
child support enforcement systems; and (6) OCSE had also conducted 13
additional reviews and was preparing certification reports for those
systems.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: AIMD-98-134
TITLE: Child Support Enforcement: Certification Process for State
Information Systems
DATE: 06/15/98
SUBJECT: Child support payments
Federal/state relations
Requirements definition
Systems evaluation
Law enforcement information systems
IDENTIFIER: HHS Child Support Enforcement Program
HHS State System Approval Information System
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Cover
================================================================ COVER
Report to Congressional Requesters
June 1998
CHILD SUPPORT ENFORCEMENT -
CERTIFICATION PROCESS FOR STATE
INFORMATION SYSTEMS
GAO/AIMD-98-134
Child Support Systems Certification
(511240)
Abbreviations
=============================================================== ABBREV
AFDC - Aid to Families With Dependent Children
APD - advance planning document
C.F.R. - Code of Federal Regulations
GAO - General Accounting Office
HHS - Department of Health and Human Services
OCSE - Office of Child Support Enforcement
TANF - Temporary Assistance for Needy Families
Letter
=============================================================== LETTER
B-279010
June 15, 1998
The Honorable Daniel Patrick Moynihan
Ranking Minority Member
The Honorable John D. Rockefeller IV
Committee on Finance
United States Senate
This report responds to your request that we review the Department of
Health and Human Services (HHS) certification process for state child
support enforcement systems and its administration of the process and
determine the certification status of the state systems. The Family
Support Act of 1988 requires states to obtain HHS certification that
their child support enforcement systems meet federal requirements.
All states were to obtain this certification by October 1, 1997, or
face the possibility of substantial financial penalties for
noncompliance after the deadline.\1
--------------------
\1 Legislation to reduce the penalties for failure to certify state
systems was pending as of March 31, 1998.
RESULTS IN BRIEF
------------------------------------------------------------ Letter :1
Certification guidance issued by the Office of Child Support
Enforcement (OCSE) addresses the system requirements of the Family
Support Act of 1988 and HHS' implementing regulations. Our analysis
of the certification process shows that OCSE has administered this
process consistently across states since it began certifying child
support enforcement systems in 1993. It has used the same guidance
for certification reviews and conducted reviews that were similar in
scope and length for each level of certification. While OCSE
published many certification reports on the results of its
certification reviews, its reporting was not always consistent. For
example, six preliminary certification review reports included an
inaccurate description of the criteria against which the systems'
financial components were measured. As of March 31, 1998, OCSE had
either certified or conditionally certified 25 of the 54 child
support enforcement systems.\2 OCSE had also conducted 13 additional
reviews and was preparing certification reports\3 for those systems.
--------------------
\2 The 54 state systems consist of systems for the 50 states and for
the District of Columbia, Guam, Puerto Rico, and the Virgin Islands.
The term system refers to the hardware and software components of the
child support enforcement systems.
\3 OCSE conducted the review for one state during the week of March
30, 1998, and began preparing that state's report on April 6, 1998.
BACKGROUND
------------------------------------------------------------ Letter :2
The Child Support Enforcement Program was established in 1975 to help
strengthen families and reduce dependence on welfare by helping to
ensure that the responsibility for supporting children was placed on
parents. The states operate programs to locate noncustodial parents,
establish paternity, and obtain support orders, along with enforcing
actual collections of those court-ordered support payments. The
federal government--through OCSE--funds 66 percent of state
administrative and operating costs, including costs for automated
systems, and up to 90 percent of expenses associated with planning,
designing, developing, installing, and/or enhancing automated
systems.
The Family Support Act of 1988 required that statewide systems be
developed to track determination of paternity and child support
collections. To address that requirement, OCSE developed regulations
and guidance for conducting certification reviews. In 1993, OCSE
published a certification guide,\4 which addresses the functional
requirements for child support enforcement systems. In general, the
certification guide requires that the systems be operational,
statewide, comprehensive, and effective and efficient. The guide
also provides 53 specific requirements, which are grouped into the
following categories: case initiation, location of parents,
establishment of paternity, case management, enforcement, financial
management, reporting, and security and privacy. (See appendix I for
the system regulations and appendix II for descriptions of the
guide's specific requirements by category.) The guide was developed
to help OCSE's analysts ensure that certification reviews are
conducted consistently--using the same criteria and standards for
documentation. The analysts use the certification guide in
conducting certification reviews, and states refer to it in preparing
for their certification reviews.
To ensure that states are meeting the functional requirements
specified in the certification guide, OCSE also developed a
certification questionnaire.\5 The questionnaire provides a series of
questions for analysts' use in determining if the states' systems
address the functional requirements. The format and content of the
questionnaire mirror those of the certification guide. In addition
to the certification guide and questionnaire, OCSE has provided
supplementary guidance to (1) aid in developing and testing specific
areas such as financial requirements and (2) clarify and expand upon
the requirements provided in the certification guide and
questionnaire.
OCSE uses its guidance to ensure that its staff consistently perform
three types of certification reviews: functional, level 1, and level
2. A functional review occurs early in the development of a system
before it is operational in a pilot site. During functional reviews,
analysts evaluate parts of the system against the certification
requirements to inform the state of the work that remains before its
system can be certified. A level 1 review occurs when an automated
system is installed and in operation in one or more pilot locations.
(OCSE created this level of review in 1990 due to state requests for
agency guidance prior to statewide implementation). A level 2 review
occurs when the system is considered by the state to be operational
statewide.\6 This review is required for final certification.
Systems are granted full certification when they meet all functional
requirements and conditional certification when the system needs only
minor corrections that do not affect statewide operation. According
to OCSE analysts, states whose systems receive either type of level 2
certification are exempt from penalties for failing to meet system
requirements imposed by the Family Support Act.
The Family Support Act of 1988 set a deadline of October 1, 1995, for
implementation and federal certification of such systems. However,
when only a few states met the deadline, the Congress passed
legislation extending it by 2 years, to October 1, 1997. Current law
requires HHS to impose substantial financial penalties on states that
did not have certified child support enforcement systems by October
1, 1997. The Congress, under the House bill HR 3130 with Senate
modifications SP 2286, is considering legislation to reduce those
penalties. OCSE certified 17 states by the extended deadline and
another 8 states since the deadline (as of March 31, 1998).
In June 1997 we made several recommendations designed to strengthen
OCSE's oversight of child support enforcement systems. Specifically,
we reported that the certification reviews are conducted too late for
effective oversight.\7 Because the reviews are conducted toward the
end of the system development projects, the reviews come too late for
timely redirection of systems development without significant costs
being incurred.
--------------------
\4 Automated Systems for Child Support Enforcement: A Guide for
States, U.S. Department of Health and Human Services, Administration
for Children and Families. (Revised June 1993.) (This guide replaced
draft guidance distributed in November 1992.)
\5 Automated Systems for Child Support Enforcement: Child Support
Systems, Certification Questionnaire, U.S. Department of Health and
Human Services, Administration for Children and Families. (Revised
January 1994.)
\6 According to OCSE analysts, if a state had a level 1 review prior
to its level 2 review, the scope of the level 2 review may be limited
to those problems identified during the level 1 review.
\7 Child Support Enforcement: Strong Leadership Required to Maximize
Benefits of Automated Systems (GAO/AIMD-97-72, June 30, 1997).
OBJECTIVES, SCOPE, AND
METHODOLOGY
------------------------------------------------------------ Letter :3
Our objectives were to determine (1) whether HHS' certification
guidance addresses the system provisions in the Family Support Act of
1988 and implementing regulations, (2) whether HHS has consistently
administered the certification process, and (3) the certification
status of the state systems. Our work was done to determine whether
OCSE's certification guidance completely addresses the system
requirements in the act and supporting regulations; it does not
determine the overall adequacy of OCSE's certification review
process. This issue was addressed in our June 1997 report,\8 in
which we identified weaknesses in HHS' oversight of these systems,
including the timeliness of the certification reviews.
To document the certification process, we obtained and analyzed
OCSE's guidance for certifying child support enforcement systems. To
determine whether this guidance addresses the legal and regulatory
requirements for child support enforcement systems, we compared the
certification guide and questionnaire to the child support
enforcement system regulations. We also analyzed whether the
regulations addressed the system provisions of the Family Support Act
of 1988.
To determine whether OCSE consistently administered the certification
process, we obtained and reviewed all certification reports issued as
of March 31, 1998, and assessed how OCSE officials at headquarters
and in one regional office plan, administer, and report the results
of certification reviews. While we discussed this review process
with these officials, we did not visit states to observe OCSE
conducting certification reviews or conduct independent work to
verify the information presented in OCSE's certification reports.
We performed our work at HHS headquarters in Washington, D.C., and at
the HHS regional office in Atlanta, Georgia. We conducted our work
between December 1997 and April 1998, in accordance with generally
accepted government auditing standards.
HHS provided written comments on a draft of this report. These
comments are presented and evaluated in the "Agency Comments" section
of this report and are included in appendix IV.
--------------------
\8 GAO/AIMD-97-72, June 1997.
OCSE CERTIFICATION GUIDANCE
ADDRESSES LAW AND IMPLEMENTING
REGULATIONS
------------------------------------------------------------ Letter :4
OCSE's guidance for certification reviews generally complies with the
system provisions in the Family Support Act of 1988 and the
implementing regulations established by the Secretary of HHS. This
guidance includes: (1) the certification guide, which defines
systems functional requirements and (2) the certification
questionnaire, which in essence, is the certification guide presented
in a questionnaire format.
Our analysis showed that the certification guide and questionnaire
address key system elements of the law and implementing regulations.
OCSE included references to system and program regulations in both
the certification guide and questionnaire. We analyzed those
references to determine whether the certification guidance addressed
the regulations cited. The comparison in appendix III shows that
each of the implementing regulations is addressed in OCSE's
certification objectives. For example, section 307.10(b)(1) of the
regulation requires that child support enforcement systems maintain
identifying information on individuals involved in child support
cases. Seven different certification objectives in the certification
guidance address this requirement. Two of those certification
objectives, A-8 and D-4, demonstrate how the guide addresses this
requirement; respectively, they state that, "the system must accept
and maintain identifying information on all case participants," and
"the system must update and maintain in the automated case record,
all information, facts, events, and transactions necessary to
describe a case and all actions taken in a case."
CONSISTENT ADMINISTRATION OF
CERTIFICATION REVIEWS
------------------------------------------------------------ Letter :5
OCSE has been consistent in the way it administers certification
reviews. Specifically, it used the same types of teams, the same
guidance that was discussed earlier, and the same method for
certification reviews. Although the scope and length of functional,
level 1, and level 2 certification reviews varied, OCSE has been
generally consistent in the way that it conducted each type of
review.
OCSE's review process is as follows. It begins preparing for a
certification review when the state notifies it that the state system
is compliant and ready for certification. When OCSE receives the
request, it requires the state to submit consistent documentation,
which includes the completed certification questionnaire. After OCSE
receives the documentation, it assigns a team to review the
information and develop issues for discussion during the
certification review. These teams consistently included at least one
supervisor and two systems analysts. In some cases, regional
analysts also participated in the documentation review.
Following that review, certification teams are formed from staff who
have similar background and expertise. For example, the
certification team leaders are usually systems analysts from OCSE
headquarters. These leaders are assisted by teams from the
Administration for Children and Families regional offices responsible
for the states being reviewed. The regional teams are usually a
combination of staff with systems, policy, or audit expertise.
In performing the certification reviews, these teams consistently use
the certification questionnaire. OCSE used the same certification
questionnaire for all of its level 1 and level 2 certification
reviews except one. The first level 1 review was conducted before
OCSE developed the certification questionnaire.
OCSE analysts have also used a consistent method for conducting
certification reviews. Certification review teams spend
approximately 1 week on-site conducting certification reviews.
(Because functional reviews and level 1 reviews are more limited in
scope, those reviews do not always take a full week.) During the
certification review, the review team usually holds an entrance
conference at the state office and allows the state staff to provide
an overview of the child support enforcement system. The next few
days are spent reviewing the state's responses to the certification
questionnaire and observing how adequately system screens and
functions address the federal requirements. This review at the state
office is often performed using a test version of the system--one
that does not include actual cases. To supplement the information
obtained at the state office, the certification team usually spends
at least one day visiting local offices to observe the system in
operation. At the local offices, the team interviews staff about
their use of the system and the systems training they have received.
In addition, they have the staff process sample cases to ensure that
the system will handle them correctly, observe the staff processing
actual cases, and review reports and documents generated by the
system.
OCSE uses the certification guide and questionnaire in lieu of a
manual to instruct its staff on how to conduct certification reviews
and relies heavily upon on-the-job training to ensure that the
reviews continue to be conducted consistently. In one instance when
a new certification staff member was added, that person was paired
with experienced staff for the first two or three reviews after
joining the review team, to gain experience and learn how to
consistently cover the issues addressed by the certification teams.
INCONSISTENT REPORTING ON
CERTIFICATION REVIEWS
------------------------------------------------------------ Letter :6
OCSE began reporting on the results of its certification reviews in
1994. In general, the format and process for preparing certification
reports has been standardized. However, we noted that several
reports contained inconsistencies, such as including inaccurate
descriptions of the criteria against which the systems' financial
components were measured.
OCSE's analysts used a standard template for preparing certification
reports. As a result, we found the certification reports to be very
similar in format and content. Even though the scope of the
different reviews varied, the reports for functional, level 1, and
level 2 reviews addressed similar topics. For example, they
typically included a background section giving the history of the
development of and funding for the system and describing the scope
and methodology of the certification review. The reports also
presented both certification findings and management findings.
Certification findings are those system problems that must be
addressed prior to system certification. Management findings are
optional systems changes for management to consider. These findings
often relate to the efficiency of the states' systems.
OCSE used a consistent process for reviewing the draft certification
reports. According to an OCSE supervisor, division management
reviewed all certification reports for consistency prior to their
issuance. In addition, the office requested comments from states
before publishing the final reports. According to OCSE officials,
the nature, extent, and timeliness of the states' comments varied
and, when appropriate, states' comments were incorporated into the
final certification reports.
While OCSE published many standardized certification reports on the
results of its certification reviews, we noted three types of
exceptions with the reporting process. First, OCSE certified two
state systems in July and December 1997, respectively, by sending a
brief letter to each state instead of issuing a complete standardized
written report. The division director explained that standardized
reports were not prepared for those systems because the certification
team found no problems with them during the review. Second,
according to officials, a report was not published for one state's
level 1 review because the level 2 review was requested before the
earlier report was published.
Finally, the reports for one level 1 and five functional reviews
contained a qualifying statement not contained in the boilerplate
language of the standardized reports. This qualifying statement said
that, in order to even be conditionally certified, a system must
process the financial component of all sample cases correctly, in
accordance with predetermined results. In contrast, the other
standardized reports' paragraph on this subject did not contain this
qualification.
The division director told us that the boilerplate language in the
standardized reports was appropriate and that the qualifying language
in the six reports was incorrect. She said OCSE will conditionally
certify a system even though it does not process all sample cases
correctly, as long as the majority of the financial transactions are
processed accurately and the state has reasonable explanations for
any variances. She added that none of the systems was denied level 2
certification based on the qualifying statement, and that she was
unaware of any other systems that were denied certification for
failing to process all test cases correctly.\9 The division director
also noted that the problem was not widespread because only one lead
analyst was responsible for the incorrect language. However, the
review process did not prevent the incorrect language from being
incorporated into the six published reports. Finally, she said that,
until we brought this issue to her attention, she was not aware that
any reports included this language; and that she would act to ensure
that such qualifying language did not appear in future reports.
--------------------
\9 We did not verify whether any states were denied certification
based on the results of their sample test cases, nor did we assess
the sample case test process to determine if all cases should, or
should not, be processed as a condition of certification.
CURRENT STATUS: MANY SYSTEMS
NOT CERTIFIED, MORE REVIEWS
SCHEDULED
------------------------------------------------------------ Letter :7
As of March 31, 1998, OCSE had either certified or conditionally
certified 25 of 54 child support enforcement systems, representing
approximately 38 percent of the reported average national caseload
for fiscal year 1995. OCSE had conducted 67 certification reviews
for the 54 state systems as of March 31, 1998. Some states have had
several levels of review. Figure 1 shows the highest level of
certification for the 54 child support enforcement systems as of
March 31, 1998.
Figure 1: Certification Status
of 54 State Systems as of March
31, 1998\ a
(See figure in printed
edition.)
\a Level 2 certified state systems include 7 systems that were fully
certified and 18 systems that were conditionally certified as of
March 31, 1998.
Source: HHS.
As figure 2 indicates, 25 state systems were level 2 certified as of
March 31, 1998. Figure 2 shows the status of level 2 certification
for each state.
Figure 2: Status of State
Level 2 Certification Reviews
as of March 31, 1998
(See figure in printed
edition.)
\a The systems division director stated that OCSE will not certify
Kansas' system based upon its February 1998 level 2 certification
review.
Source: HHS.
Since the October 1997 deadline, OCSE's certification review workload
has increased substantially, as shown by figure 3. OCSE conducted 13
level 2 certification reviews for the first quarter of calendar year
1998,\10 equaling the number of level 2 reviews conducted in
1997--the most done in any previous year.
Figure 3: Level 2
Certification Reviews
Conducted, June 1, 1994 - March
31, 1998\a
(See figure in printed
edition.)
\a This graph reflects all level 2 reviews conducted, including
reviews for the 25 certified systems. The 1998 reviews were
conducted during the first 3 months of the calendar year.
Source: HHS.
The OCSE systems director told us, however, that the increased
workload did not affect the staffing or quality of the certification
reviews. She explained that (1) her staff traveled extensively, used
newly acquired laptop computers, and worked long hours to manage the
increased workload and (2) additional OCSE staff supported the system
certification staff by relieving them of administrative duties. The
systems director said that management chose to maintain its
experienced review teams rather than add additional staff to conduct
certification reviews. She said she prohibited the certification
staff from taking vacations to ensure that the scheduled work was
expeditiously completed. OCSE is currently documenting the results
of and preparing certification reports for the certification reviews
performed in 1998. The systems director said she expects the rate of
certification reviews to decline sharply because, as of March 31,
1998, only one request for a certification review was pending.
--------------------
\10 The first quarter of calendar year 1998 is the second quarter of
OCSE's fiscal year 1998.
CONCLUSIONS
------------------------------------------------------------ Letter :8
OCSE's certification guidance addresses the system requirements of
the Family Support Act of 1988 and HHS' implementing regulations, and
OCSE has administered the certification process consistently across
states. Further, while OCSE, in general, used a standardized format
and process in preparing certification reports on the results of its
reviews, these reports were not always consistent.
RECOMMENDATION
------------------------------------------------------------ Letter :9
We recommend that the Assistant Secretary of the Administration for
Children and Families increase OCSE's oversight of the reporting
process to ensure that the reports consistently address criteria for
evaluating the financial components of state systems.
AGENCY COMMENTS
----------------------------------------------------------- Letter :10
The Assistant Secretary for Children and Families agreed with our
recommendation to increase OCSE's oversight of the reporting process.
She stated that OCSE would increase its oversight and consistency of
reporting by subjecting the functional and level 1 reports to the
same degree of management review being provided to the level 2
reports.
--------------------------------------------------------- Letter :10.1
We will provide copies of this report to the Assistant Secretary,
Administration for Children and Families, Department of Health and
Human Services; the Director of the Office of Management and Budget,
and appropriate congressional committees. We will also make copies
available to others upon request.
Please contact me at (202) 512-6253 or by e-mail at
[email protected] if you have any questions concerning this
report. Major contributors are listed in appendix V.
Joel C. Willemssen
Director, Civil Agencies Information Systems
CHILD SUPPORT ENFORCEMENT SYSTEMS
REGULATIONS
=========================================================== Appendix I
45 C.F.R. 307.10:Functional requirements for computerized support
enforcement systems
At a minimum, each state's computerized support enforcement system
established under the title IV-D state plan at 302.85 of this
chapter must:
(a) Be planned, designed, developed, installed, or enhanced in
accordance with an initial and annually updated APD [advance planning
document] approved under 307.15; and
(b) Control, account for, and monitor all the factors in the support
collection and paternity determination processes under the state
plan. At a minimum this must include:
(1) Maintaining identifying information such as Social Security
numbers, names, dates of birth, home addresses, and mailing addresses
(including postal zip codes) on individuals against whom support
obligations are sought to be established or enforced and on
individuals to whom support obligations are owed, and other data as
required by the Office;
(2) Periodically verifying the information on individuals referred to
in paragraph (b)(1) of this section with federal, state, and local
agencies, both intrastate and interstate;
(3) Maintaining data necessary to meet federal reporting requirements
on a timely basis as prescribed by the Office;
(4) Maintaining information pertaining to
(i)Delinquency and enforcement activities;
(ii)Intrastate, interstate and federal location of absent parents;
(iii)The establishment of paternity; and
(iv)The establishment of support obligations;
(5) Collecting and distributing both intrastate and interstate
support payments;
(6) Computing and distributing incentive payments to political
subdivisions which share in the cost of funding the program and to
other political subdivisions based on efficiency and effectiveness if
the state has chosen to pay such incentives;
(7) Maintaining accounts receivable on all amounts owed, collected,
and distributed;
(8) Maintaining costs of all services rendered, either directly or by
interfacing with state financial management and expenditure
information;
(9) Accepting electronic case referrals and update information from
the state's title IV-A program and using that information to identify
and manage support enforcement cases;
(10) Transmitting information electronically to provide data to the
state's AFDC [Aid to Families With Dependent Children; now Temporary
Aid for Needy Families (TANF)] system so that the IV-A agency can
determine (and report back to the IV-D system) whether a collection
of support causes a change in eligibility for, or the amount of aid
under, the AFDC program;
(11) Providing security to prevent unauthorized access to, or use of,
the data in the system;
(12) Providing management information on all IV-D cases under the
state plan from initial referral or application through collection
and enforcement;
(13) Providing electronic data exchange with the state Medicaid
system to provide for case referral and the transfer of the medical
support information specified in 45 C.F.R. 303.30 and 303.31;
(14) Providing electronic data exchange with the state IV-F program
for purposes of assuring that services are furnished in an integrated
manner unless the requirement is otherwise met through the exchange
conducted under paragraph (b)(9) of this section;
(15) Using automated processes to assist the state in meeting state
plan requirements under part 302 of this chapter and Standards for
program operations under part 303 of this chapter, including but not
limited to:
(i)The automated maintenance and monitoring of accurate records of
support payments;
(ii)Providing automated maintenance of case records for purposes of
the management and tracking requirements in 303.2 of this chapter;
(iii)Providing title IV-D case workers with on-line access to
automated sources of absent parent employer and wage information
maintained by the state when available, by establishing an electronic
link or by obtaining an extract of the data base and placing it
on-line for access throughout the state;
(iv)Providing locate capability by automatically referring cases
electronically to locate sources within the state (such as state
motor vehicle department, state department of revenue, and other
state agencies), and to the Federal Parent Locator Service and
utilizing electronic linkages to receive return locate information
and place the information on-line to title IV-D case workers
throughout the state; (v)Providing capability for electronic funds
transfer for purposes of income withholding and interstate
collections;
(vi)Integrating all processing of interstate cases with the
computerized support enforcement system, including the central
registry; and
(16) Providing automated processes to enable the Office to monitor
state operations and assess program performance through the audit
conducted under section 452(a) of the Act.
CHILD SUPPORT ENFORCEMENT SYSTEM
REQUIREMENTS PROVIDED IN OCSE
CERTIFICATION GUIDE\A AND
QUESTIONNAIRE
========================================================== Appendix II
------------ ------------------------------------------------------------------
(A) Case
Initiation
A-1 The system must accept, maintain, and process information for non-
AFDC services.
A-2 The system must automatically accept and process referrals from
the State's Title IV-A (AFDC) agency.
A-3 The system must accept and process referrals from the State's
Title IV-E (Foster Care) agency.
A-4 The system must automatically accept appropriate referrals from
the State's Title XIX (Medicaid) agency.
A-5 The system must automatically accept and process interstate
referrals.
A-6 The system must uniquely identify and edit various case types.
A-7 The system must establish an automated case record for each
application/referral.
A-8 The system must accept and maintain identifying information on all
case participants.
(B) Locate
--------------------------------------------------------------------------------
B-1 The system must electronically interface with all appropriate
sources to obtain and verify locate, asset and other information
on the non-custodial/putative parent or custodial parent. The
system must automatically generate any needed documents.
B-2 The system must record, maintain, and track locate activities to
ensure compliance with program standards.
B-3 The system must automatically resubmit cases to locate sources.
B-4 The system must automatically submit cases to the Federal Parent
Locator Service (FPLS).
(C) Establishment
--------------------------------------------------------------------------------
C-1 The system must automatically track, monitor, and report on the
status of paternity establishment and support Federal regulations
and State laws and procedures for establishing paternity.
C-2 The system must automatically record, track and monitor
information on obligations, and generate documents to establish
support including medical support.
C-3 The system must accept, maintain, and process information
concerning established support orders.
C-4 The system must accept, maintain, and process information
concerning medical support services.
(D) Case Management
--------------------------------------------------------------------------------
D-1 If the State chooses to have case prioritization procedures, the
system must automatically support them.
D-2 The system must automatically direct cases to the appropriate case
activity.
D-3 The system must automatically accept and process case updates and
provide information to other programs on a timely basis.
D-4 The system must update and maintain in the automated case record
all information, facts, events, and transactions necessary to
describe a case and all actions taken in a case.
D-5 The system must perform routine case functions, keep the
caseworker informed of significant case events, monitor case
activity, provide case status information, and ensure timely case
action.
D-6 The system must automatically support the review and adjustment of
support obligations.
D-7 The system must allow for case closure.
D-8 The system must provide for management of all interstate cases.
D-9 The system must manage Responding-State case actions.
D-10 The system must manage initiating-State case actions.
(E) Enforcement
--------------------------------------------------------------------------------
E-1 The system must automatically monitor compliance with support
orders and initiate enforcement actions.
E-2 The system must support income withholding activities.
E-3 The system automatically must support Federal tax refund offset.
E-4 The system must automatically support State tax refund offset.
E-5 The system must automatically identify, initiate, and monitor
enforcement actions using liens and bonds.
E-6 Where action is appropriate under State guidelines, the system
must support Unemployment Compensation Intercept (UCI).
E-7 The system must be capable of forwarding arrearage information to
credit reporting agencies.
E-8 The system must support enforcement through Internal Revenue
Service full collection services when previous enforcement
attempts have failed.
E-9 In cases where previous enforcement attempts have failed, the
system must periodically re-initiate enforcement actions.
E-10 The system must support the enforcement of spousal support.
E-11 The system must automatically monitor compliance with and support
the enforcement of medical insurance provisions contained within
support orders.
(F) Financial Management
--------------------------------------------------------------------------------
F-1 With the exception of those cases with income withholding in
force, the system must automatically bill cases with obligations.
F-2 The system must automatically process all payments received.
F-3 The system must support the acceptance and disbursement of
payments using electronic funds transfer (EFT) technology.
F-4 The system's accounting process must be uniform statewide, accept
and maintain all financial information, and perform all
calculations relevant to the IV-D program.
F-5 The system must distribute collections in accordance with 45
C.F.R. 302.32, 302.51, 302.52, 303.72, and 303.102.
F-6 The system must generate notices to AFDC and former AFDC
recipients, continuing to receive IV-D services, about the amount
of support collections; and must notify the IV-A agency about
collections for AFDC recipients.
(G) Reporting
--------------------------------------------------------------------------------
G-1 The system must maintain information required to prepare Federal
reports.
G-2 The system must provide an automated daily on-line report/
worklist to each caseworker to assist in case management and
processing.
G-3 The system must generate reports required to ensure and maintain
the accuracy of data and to summarize accounting activities.
G-4 The system must provide management reports for monitoring and
evaluating both employee, office/unit, and program performance
G-5 The system must support the expeditious review and analysis of all
data that is maintained, generated, and reported by the system.
(H) Security and Privacy
--------------------------------------------------------------------------------
H-1 The State must have policies and procedures to evaluate the system
for risk on a periodic basis.
H-2 The system must be protected against unauthorized access to
computer resources and data in order to reduce erroneous or
fraudulent activities.
H-3 The State must have procedures in place for the retrieval,
maintenance, and control of the application software.
H-4 The State must have procedures in place for the retrieval,
maintenance, and control of program data.
H-5 The system hardware, software, documentation, and communications
must be protected and back-ups must be available.
--------------------------------------------------------------------------------
Source: OCSE's Automated Systems For Child Support Enforcement: A
Guide for States.
\a The certification guide is currently being revised to incorporate
changes required by welfare reform. The new version will refer to
Temporary Assistance for Needy Families, the program that replaced
Aid to Families With Dependent Children.
COMPARISON OF REGULATIONS TO
OCSE'S CERTIFICATION OBJECTIVES
FOR CHILD SUPPORT ENFORCEMENT
SYSTEMS
========================================================= Appendix III
The shaded circles in the chart below indicate that the identified
certification objective addresses part, or all, of the specified
component of the child support enforcement system regulations in 45
C.F.R. 307.10 (b). Collectively, the certification objectives
address all components of the system regulations.
(See figure in printed
edition.)
Source: GAO analysis of the regulations in appendix I and the
certification objectives in appendix II.
(See figure in printed
edition.)
(See figure in printed edition.)Appendix IV
COMMENTS FROM THE DEPARTMENT OF
HEALTH AND HUMAN SERVICES
========================================================= Appendix III
(See figure in printed edition.)
(See figure in printed edition.)
MAJOR CONTRIBUTORS TO THIS REPORT
=========================================================== Appendix V
ACCOUNTING AND INFORMATION
MANAGEMENT DIVISION, WASHINGTON,
D.C.
Mark E. Heatwole, Senior Assistant Director
Norman F. Heyl, Business Process Analyst
Anh Q. Le, Information Systems Analyst
Letitia Downer, Intern
Michael P. Fruitman, Communications Analyst
ATLANTA REGIONAL OFFICE
Amanda C. Gill, Analyst In Charge
Cynthia J. Scott, Evaluator
OFFICE OF GENERAL COUNSEL
Edda Emmanuelli-Perez, Senior Attorney
RELATED GAO PRODUCTS
=========================================================== Appendix V
Child Support Enforcement: Privatization: Challenges in Ensuring
Accountability for Program Results (GAO/T-HEHS-98-22, Nov. 4, 1997).
Child Support Enforcement: Leadership Essential to Implementing
Effective Automated Systems (GAO/T-AIMD-97-162, Sept. 10, 1997).
Child Support Enforcement: Strong Leadership Required to Maximize
Benefits of Automated Systems (GAO/AIMD-97-72, June 30, 1997).
Child Support Enforcement: Early Results on Comparability of
Privatized and Public Offices (GAO/HEHS-97-4, Dec. 16, 1996).
Child Support Enforcement: Reorienting Management Toward Achieving
Better Program Results (GAO/HEHS/GGD-97-14, Oct. 25, 1996).
Child Support Enforcement: States' Experience with Private Agencies'
Collection of Support Payments (GAO/HEHS-97-11, Oct. 23, 1996).
Child Support Enforcement: States and Localities Move to Privatized
Services (GAO/HEHS-96-43FS, Nov. 20, 1995).
Child Support Enforcement: Opportunity to Reduce Federal and State
Costs (GAO/T-HEHS-95-181, June 13, 1995).
*** End of document. ***