TRIBAL CHILD SUPPORT ENFORCEMENT SYSTEMS WORKGROUP

Session II

Final Report

June 2005

![](media/image1.wmf){width="1.775in" height="1.8930555555555555in"}

U. S. DEPARTMENT OF HEALTH & HUMAN SERVICES

Administration for Children and Families

Office of Child Support Enforcement

Division of State and Tribal Systems

This page intentionally left blank.

TABLE OF CONTENTS

[1. Introduction 1](#introduction)

[1.1 Background 1](#background)

[1.2 Scope 1](#scope)

[1.3 participants 1](#participants)

[1.4 process 4](#process)

[2. meeting summaries 5](#meeting-summaries)

[2.1 Key Issues for Session II 5](#key-issues-for-session-ii)

[2.2 meeting #1 5](#meeting-1)

[2.3 meeting #2 9](#meeting-2)

[2.4 meeting #3 10](#meeting-3)

[2.5 meeting #4 11](#meeting-4)

[2.6 Workgroup Concerns 12](#workgroup-concerns)

[2.7 Next Steps 13](#next-steps)

This page intentionally left blank

# Introduction

## Background

The Tribal Child Support Enforcement (TCSE) Systems Workgroup met for
the first time in August 2002. The Workgroup was chartered to recommend
guidelines to maximize the benefits of automating tribal child support
enforcement programs while limiting the fiscal impact associated with
design, development, and implementation of automated systems.

During the first series of four meetings, the Workgroup discussed issues
with potential impact on the successful implementation of automation in
Tribal Child Support Enforcement programs.

The final report for Session I meetings is available at:

[www.acf.hhs.gov/programs/cse/stsys/tab9.htm](http://www.acf.hhs.gov/programs/cse/stsys/tab9.htm).

The primary outcomes of the Session I meetings included:

1)  Identification of the considerations involved in developing
    automated systems for TCSE programs, including acquiring and
    managing automated systems and services, and the related Federal
    funding processes.

2)  Identification of high-level TCSE program automation needs,
    requirements, and constraints.

3)  Definition of the high-level operational capabilities required for
    TCSE systems.

## Scope

This report summarizes the activities and results of the second series
of meetings of the TCSE Systems Workgroup. Session II meetings focused
on functional requirements for automated TCSE systems and methods for
procuring, implementing and operating these systems, in order to
optimize tribal and Federal resources.

Session II of the TCSE Systems Workgroup included four meetings during
2004:

-   March 29-30, 2004 in Milwaukee, Wisconsin

-   May 6, 2004 in Washington, DC;

-   July 7-8, 2004 in Denver, Colorado and

-   August 18-19, 2004 in Seattle, Washington.

## participants

All Session II meetings were attended by key Federal and Tribal
Workgroup members. Additional Federal and state representatives were
invited to attend specific session meetings.

A majority of the individual Workgroup members have participated in both
series of Workgroup meetings. Not all tribal representatives attended
every meeting, but most participating tribes sent at least one
representative to each meeting.

Federal participants represented organizational components of the Office
of Child Support Enforcement (OCSE), including the Division of State and
Tribal Systems (DSTS), the Division of Special Staffs (DOSS), and
Administration for Children and Families (ACF) regional staff. Tribal
participants represented the tribes operating Federally funded Tribal
Child Support Enforcement programs, and one additional tribal
organization.

For the final two meetings, the Federal support team was augmented by
two members of its BAE Systems contract technical assistance support
staff. BAE Systems staff provided technical assistance in defining and
documenting technical and system requirements. As in the first series of
meetings, State Information Technology Consortium (SITC) staff arranged
travel and meeting accommodations for participants and documented the
Workgroup's activities.

### Tribal Representatives 

All named tribes sent at least one representative to every meeting.
Participants are listed in alphabetical order by tribe:

-   Tami Lorbecke, Chickasaw Nation

-   Jacqueline Pische, Forest County Potowatomi Community

-   Frances Whitfield, Lac du Flambeau Band of Lake Superior Chippewa
    Indians

-   Karen Burke, Lummi Nation

-   Rosemund Hoffman, Menominee Indian Tribe of Wisconsin

-   Janet Pribbernow, Menominee Indian Tribe of Wisconsin

-   Kurt Nelezen, Menominee Indian Tribe of Wisconsin

-   Pierette Baldwin-Gumbrecht, Navajo Nation

-   Melody Bidtah, Port Gamble S'Klallam Tribe

-   Sandra Starnes, Port Gamble S\'Klallam Tribe

-   Linda Tresaugue, Puyallup Tribe of Indians

-   Keith Bowman, Tanana Chiefs Conference

-   Jesse Fogleboch, Tanana Chiefs Conference

### State Representatives {#state-representatives .unnumbered}

The following individual participated to provide the "state" perspective
on CSE automation issues affecting the tribes:

-   Wally McClure, Washington

### Federal

The following individuals provided a Federal perspective in one or all
of the meetings:

-   Jay Adams, HHS/ACF, OCSE

-   Dennis Barton, HHS/ACF Region VIII

-   Joseph Bodmer, HHS/ACF, OCSE

-   John Cheng, HHS/ACF, OCSE

-   Levi Fisher, HHS/ACF Region X

-   Mary Gay, HHS/ACF Region IV

-   James Hicks, HHS/ACF, OCSE

-   Jan Jensen, HHS/ACF Region X

-   Sally Kolanowski, HHS/ACF Region V

-   Sherri Larkins, HHS/ACF Region VII

-   Joseph Lonergan, HHS/ACF, Division of Mandatory Grants

-   Doreen McNicholas, HHS/ACF Region VIII

-   Carolyn Brady Meier, HHS/ACF Region VI, Dallas

-   Carl Rich, HHS/ACF, Region VI

-   Ellamae Williams, HHS/ACF, OCSE

### Session II Support Staff

The following individuals provided technical assistance or meeting
planning support during Session II conferences:

-   Paula Cottrell, SITC

-   Jean Cost, BAE Systems

-   Sheila Drake, SITC

-   Tom Mahony, BAE Systems

-   Suzanne Poe, SITC

## process

As in the first series of meetings, tribal participants represented a
range of perspectives and experience on automation issues. Some
participants represented tribes that use extensive automation in TCSE
programs, while others spoke for tribes operating TCSE programs using
manual processes. In addition, Workgroup members contributed opinions
and viewpoints that considered the larger tribal community.

At each meeting, Workgroup members addressed specific sets of issues.
The group then strove for consensus, from all tribal representatives, on
each issue and its associated sub-issues. Although several tribes, or
tribal consortia, sent more than one representative, if a vote were
necessary to determine a majority view, only one vote per tribe was
permitted.

Meeting highlights were produced following each meeting to document the
proceedings, the points of consensus and the outstanding issues. Meeting
highlights were distributed to all Workgroup members prior to the next
meeting, and reviewed by the meeting attendees.

A List Serve maintained by OCSE promoted ongoing dialogue among
Workgroup participants.

# meeting summaries

## Key Issues for Session II

Key issues for discussion on the Workgroup's agendas included:

-   Preparing for TCSE systems grant applications

-   Tribal Advance Planning Document (TAPD) process

-   Federal reviews

-   TCSE system certification

-   Consortia and model system alternatives

-   Procurement / acquisition for TCSE systems

-   Funding for TCSE systems

-   Operations and maintenance

-   Risk analysis, backup and security

-   Defining high level software requirements for TCSE system

-   TCSE system architecture

The Workgroup agreed to focus on selected issues at each of the meetings
and to attempt to cover all the issues by the end of the meetings. The
meeting summaries that follow briefly touch on the results of these
discussions. Detailed meeting minutes were also distributed to members
during the Session.

## meeting #1

Coincident with the first meeting, Federal regulations regarding the
establishment of Tribal Child Support Enforcement programs were
finalized at 45 CFR Part 309, known informally as the 'Final Rule." The
Workgroup agreed to base all Session II proceedings on the premises of
the Final Rule. The Workgroup also acknowledged that Federal regulations
and Federal policy guidance related to TCSE system requirements have not
been formalized to date.

The Workgroup expressed reservations that any future system regulation
not require all tribes operating a TCSE program to automate their
programs. The Workgroup recommended that the choice of whether or not to
automate remain a decision for each tribal program to make.

The group agreed to defer discussion of funding considerations until the
second meeting, in Washington, D.C., to allow participation by staff
from the OCSE Division of Mandatory Grants.

### Tribal Advance Planning Document (TAPD) Process

OCSE will create a template and examples of appropriate levels of detail
for a Tribal Advance Planning Document (TAPD) process as technical
assistance for tribes in applying for systems grants. The group agreed
that for consistency, the template should approximate the structure and
content of the current Advance Planning Document (APD) process for
states.

The group discussed and agreed to a general content for Tribal APD
documents to afford sufficient information for Federal review prior to
approval of a grant request. Sections should include Project
Organization and Executive Commitment, Project Management Plan
(Including Tasks, Schedules, and Procurement Plan), Security Plan,
Budget, and Cost-Benefit Analysis. Detail needed for the planning of a
new or transferred automated system and for Federal review and approval
would include:

-   How and by whom the intended project would be organized and
    administered, including:

    -   The types of personnel required

    -   Staff reporting structures

    -   A description of the interface with potential contractors

-   The extent of tribal executive commitment to the project

-   A project management plan, including:

    -   A listing of discrete tasks to be performed

    -   A project schedule

-   The plan for security, including:

    -   Systems security

    -   Back up/disaster recovery

    -   Physical security

-   The project annual budget request, by quarter, including the
    following line items:

    -   Direct Personnel

    -   Contractor Services

    -   System Hardware

    -   System Software

    -   Training

    -   Supplies

    -   Travel

    -   Overhead (optional)

    -   Other (with accompanying explanation)

-   A high-level cost/benefit analysis. This would be more qualitative
    than quantitative, relative to the requirements imposed on states. A
    cost/benefit analysis would be submitted at the beginning and end of
    each project.

-   The assurance that the project would be competitively procured.
    (Tribes may opt to submit a description or link to tribal
    competitive sourcing procedures/laws in the TAPD, or these
    procedures/laws could be listed in the contract and submitted to the
    Federal government for written approval prior to award).

States are required to resubmit APDs for their CSE projects annually, or
whenever a project experiences an overrun or project plans change. The
Workgroup discussed potential overrun thresholds, agreeing that overruns
in excess of ten percent of total project cost or \$100,000 may be
possible triggers for a TAPD Update.

The Workgroup agreed that Cost Allocation is not usually a part of
Tribal automation projects.

TAPD submissions would be necessary for those projects involved with
building or transferring a new system. Depending on final Federal
regulations, projects below a threshold, possibly \$100,000, might also
not be subject to the TAPD process.

### Federal Reviews

The Workgroup recommended that for consistency and understanding within
and outside the tribal community, regulations and guidance for tribes
should use the terminology similar to that currently in use for
regulations and guidance to states. The group considered and discussed
several levels of Federal review, including self-certification reviews,
and on-site reviews for compliance, audit, or certification.

The Workgroup agreed to consider and make recommendations on appropriate
dollar thresholds for Federal procurement reviews. The group
acknowledged that recommendations will need to consider current
regulatory thresholds for enhanced funding, and other efforts in
progress such as APD reform efforts, and the unique cost justification
environment faced by Tribal automation projects.

Apart from the consideration of dollar thresholds, below which Federal
monitoring may be unnecessary, the Workgroup discussed possible
"triggers" to ensure appropriate Federal monitoring and assistance for
tribal system development efforts.

The "triggers" included:

-   Systems that fail to meet a critical milestone, as identified in the
    TAPD.

-   Systems in need of a total redesign.

-   System development efforts determined "at risk" of failure,
    significant delay or significant cost overruns.

-   A request from the tribal IV-D director or superior(s).

###  TCSE System Certification

As in the first series of meetings, the Workgroup grappled with
balancing the sovereignty of tribes with the desirability of Federal
oversight to ensure consistent quality. The Workgroup agreed that some
form of tribal systems certification was desirable. Tribes considering
the transfer of a TCSE system from another tribe or jurisdiction would
need some assurance that certain functional capabilities were met by the
system to be transferred.

The Workgroup discussed the Federal certification process used for state
CSE systems. Since most TCSE systems are anticipated to have a smaller
scale and less complex requirements than state CSE systems, the
Workgroup recommended a streamlined certification process, including
some combination of pre-certification and self-certification.

The group recommended that any "model" systems that OCSE might assist in
building for tribes be considered as "pre-certified". These, as well as
any data standardization efforts, would benefit a broader base of
tribes.

To self-certify, the Workgroup recommended that a checklist be provided
by OCSE for tribes to submit with a report on their respective TCSE
systems.

However, the Workgroup expressed a concern that future tribal system
selection choices not be limited to the use of a state system or a TCSE
model system. The Workgroup recognized that in that situation a higher
level of justification and certification would be appropriate.

### Tribal Consortium

Tribal members of the Workgroup discussed the feasibility of joining
together to develop one or two scalable model systems for use by current
grantees and future Tribal entrants to the CSE program. Since most
Tribes are in rural areas, accessing Information Technology expertise
will be a challenge. The Tribes present expressed interest in exploring
the possibility of establishing a consortium with a group of Tribal IV-D
directors acting as a steering committee, in order to shorten the
timeframe for gaining access to automation. The Workgroup recognized
there would be a number of logistical questions concerning how a
Consortium might be administered.

Workgroup suggestions included:

-   Use of the National Tribal Child Support Organization as a possible
    grantee with responsibility for building a system. (It was later
    learned that this approach was not allowable under current
    regulations).

-   Joining of two or more Tribes together through intergovernmental
    agreements, with one Tribe taking the lead for purposes of
    administering procurements and contracts, etc.

The Workgroup agreed to continue discussion of the issues surrounding
consortia at a future time.

## meeting #2

The Workgroup spent both days of this meeting focused on funding and
security issues. Meeting participants included Joe Lonergan of the
Division of Mandatory Grants, affording Workgroup the opportunity to
discuss procedural questions about Federal funding for TCSE systems.

The Workgroup focused on how a request for a TCSE system would be
conducted within the context of the Federal grant application process.
The Workgroup examined Federal and state CSE program interactions, and
discussed commonalties and differences in tribal and Federal procurement
laws. The Workgroup hoped to identify processes and procedures that
tribes and Federal government representatives could follow until Federal
guidance and regulation for TCSE systems is available.

### Procurement /Acquisition of a TCSE System

The Workgroup reviewed and discussed the alignment of tribal
acquisition/procurement practices with Federal procurement practices.

Federal Financial Participation (FFP) cannot be granted unless
procurements are to be conducted with "full and open competition".
Decisions to award sole source contracts need additional justification.
The Workgroup used Title 45, Section 92.36 of the Code of Federal
Regulations (FCR), which describes "full and open competition", as a
framework for discussing possible commonalities or differences between
Federal and tribal procurement laws. Tribal Workgroup participants
described similar procurement and competitive guidelines contained in
their respective tribal laws. Some Tribes also "pass through" the
standard Federal contractual clauses (see Part 95 of the FCR), such as
the Davis Bacon lobbying clause, in their contracts.

The Workgroup recognized that Federal regulation does not permit
expenditures on proprietary software. To meet program needs, the
Workgroup noted that tribes can purchase off-the-shelf software, as long
as it does not duplicate existing TCSE system functionality.

To understand Federal expectations for solicitation documents (such as
Requests for Proposals (RFPs) or Invitations for Bid (IFBs)), the
Workgroup discussed the components of a "typical" RFP. OSCE offered to
supply a standardized template for an RFP, but most tribal
representatives felt this would not hasten the procurement approval
process within their tribal government; tribes preferred to use their
own RFP formats. Also, most tribes expected multiple tribal departments
to be involved in the approval process.

Some tribes noted that in previous acquisitions/procurements,
preference, in the form of bonus evaluation points, was given to tribal
member suppliers/vendors. Successful bidders might also be required to
hire tribal members and/or to sign an agreement stating that they would
use tribal courts, should disputes arise. Similar preferences appear in
state RFPs.

The Federal government also requires a procedure for protests and
appeals in procurements. A dispute resolution process should appear as a
notice in the Request for Proposals (RFP) for a tribal system.

Discussions of the approval process, thresholds for tribal and Federal
approval, and required documentation are ongoing, and tribal Workgroup
participants will continue to supply feedback from their respective
tribal organizations.

### Funding For Developing New TCSE Systems

The Workgroup addressed procedures that tribes or tribal organizations
should follow to successfully and efficiently request funding to develop
automated TCSE systems.

The Workgroup discussed ways that the states currently request and
receive funding for systems or software development projects. States
typically receive funding based on the annual submission of a request.
After reviewing the components of the Advance Planning Documents
required of states, the Workgroup agreed that a streamlined, but
similar, Tribal Advance Planning Document (TAPD) could serve to support
requests for TCSE systems funding.

The Workgroup discussed the need to track expenditures for TCSE system
development projects separately from TCSE program operations. The
Workgroup agreed that TCSE system development would be funded through
specific grant applications that would be separate from ongoing program
or planning grants. As discussed in the prior meeting, projects below a
threshold, possibly \$100,000, might not be subject to the submission of
a separate grant request or TAPD.

### Funding for Operating and Maintaining Existing TCSE Systems

TAPDs would not be required for systems that are already developed and
in use, including the use of state systems. Expenditures for the ongoing
operations and maintenance of existing TCSE systems should be listed as
individual line items in the overall grant application for program
operations.

(Throughout the Session II meetings, Workgroup members had extended
interactions with the Federal team to clarify and define the terms
software development, operations, and maintenance, as apposed to office
automation. A set of working definitions was subsequently incorporated
into the draft *Guide for Tribes and Tribal Organizations*. See Meeting
#4.)

### Risk Analysis, System Backup, and Security 

The Workgroup recognized that risk analysis is not currently prescribed
by OCSE for tribes (as it is for states). However, Workgroup members
discussed the importance of documenting and following strategies to
mitigate risks to their operations and systems (ranging from floods to
dishonest employees or environmental contaminants). Discussion included
advantages of performing a risk analysis at least once every three years
to ensure that back-ups and contingency plans provide for data recovery
and uninterrupted program operations

## meeting #3

Both days of this meeting were devoted to assessing high-level
functional software requirements for a core TCSE system. The discussion
was scheduled as a four-day effort, beginning with Meeting #3 and
continuing to conclusion during Meeting #4. Workgroup members envisioned
and reached consensus on the basic components of an acceptable,
effective TCSE system and considered additional data elements that might
be needed by tribes in general.

### Methodology for Defining Requirements

The Workgroup used portions of the *Automated Systems for Child Support
Enforcement: A Guide for States* as a guide tool for facilitating
discussion. This guide is used in the certification of state systems and
incorporates functional requirements from the *Family Support Act of
1988* and *The Personal Responsibility and Work Opportunity
Reconciliation Act of 1996 (PRWORA)*.

During Session I meetings, the Workgroup made an initial assessment of
the *Guide for States,* drafting a "tool" for future discussion by
"graying out" language and sections as potentially not relevant to TCSE
systems. During this meeting, the participants revisited these "grayed
out" areas, to confirm their level of relevance.

As a larger effort, Workgroup members began a more detailed review of
the *Guide for States*, to assess in turn each of the eight basic
functional capability areas required by Federal regulation for state CSE
systems. These are: "Case Initiation," "Locate," "Establishment," "Case
Management," "Enforcement," "Financial Management," "Reporting," and
"Security and Privacy." The Workgroup discussed each requirement and
associated data elements in terms of its functionality in a TCSE system,
and its relevance to the needs of individual tribes. The Workgroup
gained consensus on changes to text and data elements. For example, the
Workgroup agreed to define a case as "foreign" when it originated in
another tribe or state (instead of terming the case as
"intergovernmental" or "interjurisdictional").

Using terms derived from IEEE standards terminology, the Workgroup
classified requirements and data elements as:

-   **"Essential" --** Necessary to a core TCSE system. Requirement is
    viewed as mandatory. No system would be acceptable without this
    functionality.

-   **"Conditional" --** A TCSE system could be accepted without this
    functionality, but a tribe wishing to exercise this functionality
    would not need further justification to do so.

-   **"Optional"** **--** Exceeds the actual requirements for a TCSE
    system. This requirement does not impact the successful operation of
    an automated TCSE system. Funding for this functionality requires
    additional justification.

The Workgroup completed discussion of six of the eight functional areas,
deferring the final two areas for the next meeting. Subsequent to the
meeting, Workgroup members received two draft versions of the document
in process to review prior to Meeting #4. One version contained the full
text of all requirements as discussed; the second contained the full
text of all requirements classified by the group as "Essential."

## meeting #4

Much of the effort during this last two-day meeting of Session II
focused on the completing the initial assessment of requirements in the
*Guide to States.* The Workgroup also completed a detailed review of the
requirement changes completed in the prior meeting.

### TCSE System Requirements

A result of this TCSE Workgroup effort is a draft document identifying
the basic or "core" functional requirements for a TCSE system, the
*Automated Systems for Tribal Child Support Enforcement: Guide for
Tribes and Tribal Organizations, TCSE Requirements Definition Toolkit*.
In the absence of enabling regulations, this document is not official,
nor should it be interpreted as such. It will remain an internal working
product for subsequent TCSE Workgroups until appropriate regulations are
established. At that time, an updated document will be made available
for use by tribes considering the development of a TCSE system, by
contractors supporting the design and development of those systems, and
by Federal staff providing regulatory and technical assistance to
tribes.

A second, expanded version of the TCSE functional requirements will be
made available in the future. The expanded document will identify, in
addition to the essential or "core" system requirements, the additional
conditional requirements and optional requirements that might be
exercised by tribes working on more expansive or individualized TCSE
systems.

By creating the document with "Essentials" components, the Workgroup
intended to provide high level guidance concerning requirements
definition for any basic TCSE system built in the future. The Workgroup
recognized that more work will need to be done to detail the required
data elements within these functional components.

The Workgroup expressed a need to determine how the design of one or
more model systems could be leveraged across a significant subset of the
tribes expected to operate TCSE programs. At the same time, the
Workgroup recognized that any base or model system would need
modification to meet the needs of specific tribes or tribal
organizations.

The Workgroup was hopeful that Federal guidance and regulation on the
TCSE system development would make Federal Financial Participation (FFP)
available for all "essential" system requirements as outlined by the
Workgroup. The Workgroup anticipated that requirements deemed
"conditional" would also gain funding approval, and that "optional"
requirements would require additional justification, including
cost-reasonableness, in order to be funded through FFP.

[]{.mark}

### TCSE System Architecture Considerations

The Federal team presented an overview of the technical considerations
involved in developing TCSE systems. The team identified the key
decisions that will need to be made, and the technical alternatives that
exist in each area, starting with a high level view of system
architectures and environments. These areas will be revisited in more
substance and detail by subsequent working groups in later stages of the
TCSE system design process.

## Workgroup Concerns

Each concern raised by Workgroup members was discussed and addressed
during the Session II meetings. Most were resolved to the satisfaction
or agreement of the members. Some require additional action or thought
at a future point in time, or should serve as cautionary guidance for
future processes.

Some Workgroup members were concerned that the process of defining
requirements would permanently limit the functionality that TCSE systems
could contain, presenting difficulties for tribes needing larger
solutions, as well as for tribes that otherwise might opt for simpler
solutions.

Concern was expressed that future Tribal system choices should not be
limited to the use of state systems or a finite choice of
tribally-recognized model systems.

Concern was expressed that the use of automation could depersonalize
customer service in TCSE programs.

Workgroup members recognized that an automated system may not always be
appropriate for a TCSE program. Whether to automate TCSE processes
should remain a choice for each tribe or tribal organization to make.

Existing Federal tribal regulations do not impose time restrictions on
tribal intake procedures. However, tribes may have their own timeframe
requirements that a TCSE system should support..

Some tribes do not print notices directly through the tribal child
support office. Instead, tribal courts must issue these notices. Also,
some TCSE program offices cannot take actions, until the custodial
parent returns to court.

Since most tribes are in rural areas, accessing information technology
expertise is challenging.

Ways that tribes address foster care requires study and definition.

## Next Steps

The Workgroup felt a key future goal should be to shorten the timeframes
for TCSE programs to gain access to automation. To that end, the
Workgroup discussed the feasibility of joining together to develop one
or two scalable model systems for use by current grantees and future
entrants to the TCSE program. If Federal funding becomes available, the
Workgroup members agreed to act as a steering committee for the
development of a general detailed design for these models. The Workgroup
recommended that tribes that have not participated in the Workgroup to
date, but that have submitted funding requests, also be considered for
participation.

In the meantime, Workgroup members also recognized the viability of
continuing to pursue other options, such as transferring and modifying
an existing state system.

Clear definitions of such terms as "software development",
"enhancement", "operations", "maintenance" and "office automation" will
be critical to effective planning for TCSE systems, to effective
interaction between the tribes and OCSE, and to effective communication
of written policies and regulations.

Workgroup members felt any upcoming TCSE system regulations should be
"standalone", self-explanatory, and all-inclusive; that is, the language
should "spell out" and not cite existing FCR language relevant to
whatever guidance is provided.

Dollar thresholds still need to be finalized and communicated concerning
what will trigger Federal monitoring or a Federal review. Overruns in
excess of ten percent of total project cost or \$100,000 were discussed
as possible triggers requiring a TAPD Update. Projects below a \$100,000
threshold were discussed as possibly not being subject to the submission
of a TAPD.

###  Tribal Activities

Workgroup members agreed to review the data elements associated with
requirements defined as "Essential" in the *Automated Systems for Tribal
Child Support Enforcement: Guide for Tribes and Tribal Organizations,
TCSE Requirements Definition Toolkit*.. They will consider whether their
TCSE programs currently collect the data, either by automated or manual
means. They will also estimate the data collection effort that would be
required to populate an automated system with this information.

### Federal Activities

The issue was raised that initial tribal grantees would be penalized, if
their Federal match rate dropped to 80% during the creation of tribal
system models; while new tribes, just entering the program, will be able
to realize 90% FFP for the first three years that they are in the
program. This issue has been raised within OCSE, but Workgroup members
requested that it receive continued monitoring and attention.