Department of Health and Human Services 
OFFICE OF 
INSPECTOR GENERAL 
CLIENT COOPERATION WITH 
CHILD SUPPORT ENFORCEMENT 
Use of Good Cause Exceptions 
JUNE GIBBS BROWN 
Inspector General 
MARCH 2000 
OEI-06-98-00043  OFFICE OF INSPECTOR GENERAL 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, is to 
protect the integrity of the Department of Health and Human Services programs as well as the 
health and welfare of beneficiaries served by them.  This statutory mission is carried out through a 
nationwide program of audits, investigations, inspections, sanctions, and fraud alerts.  The 
Inspector General informs the Secretary of program and management problems and recommends 
legislative, regulatory, and operational approaches to correct them. 
Office of Evaluation and Inspections 
The Office of Evaluation and Inspections (OEI) is one of several components of the Office of 
Inspector General.  It conducts short-term management and program evaluations (called 
inspections) that focus on issues of concern to the Department, the Congress, and the public.  The 
inspection reports provide findings and recommendations on the efficiency, vulnerability, and 
effectiveness of departmental programs. 
OEI's Region VI prepared this report under the direction of Chester B. Slaughter, Regional 
Inspector General and Judith V. Tyler, Deputy Regional Inspector General. 
Principal OEI staff included: 
DALLAS  HEADQUARTERS 
Blaine Collins
 Alan Levine, Program Specialist 
Ruth Ann Dorrill
 Joan Richardson, Program Specialist 
Marnette Robertson
 Linda Hall 
Clark Thomas, Ph.D.

Nancy Watts

Lisa White

FIELD OFFICES 
Lucille Cop 
Vincent Greiber 
Ianna Kachoris 
Thomas Purvis 
Graham Rawsthorn 
To obtain copies of this report, please call the Dallas Regional Office at 214-767-3310. 
Reports are also available on the World Wide Web at our home page address: 
http://www.dhhs.gov/progorg/oei  E X E C U T I V E  S U M M A R Y  
PURPOSE 
To describe State use of good cause exceptions which exempt Temporary Assistance to 
Needy Families (TANF) clients from requirements to cooperate with child support 
enforcement. 
BACKGROUND 
Federal law requires TANF clients to cooperate with State child support enforcement 
agencies in establishing paternity, and in creating and enforcing child support and medical 
support orders.  States are allowed to exempt TANF clients from cooperating with child 
support through good cause exceptions, typically when the pursuit of support is expected 
to result in physical or emotional harm to the child or client, when the child is born as a 
result of forcible rape or incest, or when adoption proceedings are pending.  This report 
describes use of good cause exceptions in six focus States which we chose in order to 
examine a variety of implementation strategies and experiences regarding TANF client 
cooperation.  We gathered survey responses and reviewed documents from 99 local child 
support and 103 local public assistance offices, and interviewed 180 managers and 
caseworkers. 
FINDINGS 
Public Assistance and Child Support Staff Report Few Requests for Good Cause 
Exceptions and Virtually No Fraudulent Claims 
Consistent with prior research about the use of good cause exceptions, respondents in our 
focus States report receiving few requests for exceptions from TANF clients.  Staff 
believe that most, if not all, requests for good cause exceptions are legitimate.  While staff 
recognize the potential for clients to fraudulently claim a good cause exception simply to 
avoid cooperating with child support enforcement, no caseworker or manager we 
interviewed was aware of a case with such fraud.  Rather, staff indicate that the 
administrative process for requesting an exception deters fraud. 
A Variety of Reasons and Disincentives Help Explain the Low Number of TANF 
Client Requests for Good Cause Exceptions 
Most State child support agencies do not pursue child support enforcement when a good 
cause exception is granted, yet staff report that many TANF clients potentially eligible for 
an exception want child support collected.  Some clients find it easier to claim they have 
no information about an absent parent than to corroborate a good cause exception.  While 
i  public assistance staff provide at least minimal notification of good cause exceptions, few 
attempt to assess whether client circumstances support an exception. 
Most Local Offices Make Some Efforts to Preserve Client Safety, But These 
Efforts Are Often Modest and Not Fully Implemented 
Many public assistance and some child support staff refer TANF clients who report 
domestic violence concerns to shelters and other community resources and may also keep 
client addresses confidential to help preserve safety.  Most local offices also routinely 
record potential domestic violence problems by labeling paper and electronic case files 
which have good cause exceptions. 
RECOMMENDATIONS 
Successful operation of the child support enforcement program requires effective, 
cooperative action by both the Office of Child Support Enforcement and the Office of 
Family Assistance.  Therefore, we recommend that the Assistant Secretary for the 
Administration for Children and Families (ACF) encourage States to complete the 
following. 
Develop Strategies That Allow TANF Clients Who May Be at Risk of Domestic 
Violence to Safely Pursue Child Support 
Enhance Local Office Training to Improve Staff Understanding of Good Cause 
Exceptions and Better Equip Workers to Assist TANF Clients At Risk 
Evaluate Their Standards and Practices for Protecting TANF Client Confidentiality 
and Assess the Need for Further Federal Guidelines 
COMPANION REPORTS 
This is one of four OIG reports on how States gain TANF client cooperation with child 
support enforcement.  One companion report, Client Cooperation with Child Support 
Enforcement: Policies and Practices (OEI-06-98-00040), provides an overview of 
cooperation polices and how they are implemented. Another report, Client Cooperation 
with Child Support Enforcement: Challenges and Strategies to Improvement (OEI-06-98-
00041), examines why some clients do not cooperate and how States  attempt to gain 
cooperation. The remaining report, Client Cooperation with Child Support Enforcement: 
The Role of Public Assistance Agencies (OEI-06-98-00042), discusses responsibilities of 
public assistance agencies and collaboration between agencies. 
ii  T A B L E  O F  C O N T E N T S  
PAGE

EXECUTIVE SUMMARY  i

INTRODUCTION  1

FINDINGS

State Use of Good Cause Exceptions  4

Preserving Client Safety  9

Reasons For Clients Not Requesting Exceptions  12

RECOMMENDATIONS  17

ENDNOTES  18
 I N T R O D U C T I O N  
PURPOSE 
To describe State use of good cause exceptions which exempt Temporary Assistance to 
Needy Families (TANF) clients from requirements to cooperate with child support 
enforcement. 
BACKGROUND 
Federal law requires public assistance clients receiving TANF benefits to cooperate with 
State child support enforcement agencies in establishing paternity and in creating and 
enforcing child support and medical support orders.  Cooperation often involves providing 
information about noncustodial parents and appearing for appointments as needed.  State 
child support agencies are required to determine if a TANF client is cooperating in good 
faith and notify the public assistance agency of each clients cooperation status.  States 
are allowed to exempt clients from child support enforcement cooperation requirements 
through good cause exceptions. 
Prior to the passage of welfare reform legislation,1 Federal law required States to grant 
clients good cause exceptions when one of the following circumstances existed:  when 
pursuing paternity establishment or child support enforcement was reasonably expected 
to result in physical or emotional harm to the child, or physical or emotional harm to the 
client which reduced such persons capacity to care for the child adequately; and when 
one of three circumstances existed (i.e., the child was born as a result of forcible rape or 
incest, adoption proceedings were pending, or a public or social agency was assisting the 
client to determine whether to release the child for adoption) and because of this 
circumstance, enforcement would be detrimental to the child.2 
These pre-reform regulations required States to provide clients with written notification of 
the right to claim good cause as an exception to the cooperation requirement prior to 
requiring cooperation and clients to acknowledge such notification by signing and dating 
a copy of the notice.3  States were also required, upon request, to provide reasonable 
assistance in obtaining corroborative evidence to substantiate a good cause exception 
claim.  Clients who claimed good cause under the pre-reform regulations were required to 
provide corroborative evidence of a good cause circumstance ... [and], when requested, 
furnish sufficient information to permit the State and local agency to investigate the 
circumstances.4  Once an exception was granted, Federal regulations required State 
public assistance agencies to determine whether child support enforcement could proceed 
without risk of harm to the child or caretaker and notify the client of its determination. 
1
 Welfare reform legislation changed many Federal provisions regarding good cause 
exceptions.  These changes were made in an attempt to improve client cooperation with 
child support enforcement.5  Current policy allows, but does not require, States to keep 
the prior Federal standards for granting good cause exceptions.  States now have 
discretion to expand or constrict the circumstances they accept as qualifying for good 
cause exceptions, as long as they are taking into account the best interests of the child.6 
States determine what standards of proof are required to demonstrate the circumstances 
warranting exceptions and which agency - child support, public assistance or Medicaid - is 
responsible for evaluating, and approving or denying, requests for good cause exceptions.7 
States may also decide whether to provide clients any assistance in demonstrating good 
cause circumstances.8 
Researchers, advocates, and policy-makers voice two concerns about States use of good 
cause exceptions.  The first concern involves the potential for clients to fraudulently claim 
exceptions when they do not have a legitimate fear of domestic violence or other 
qualifying circumstance simply to avoid cooperating with child support enforcement. 
This concern has been minor in the past because States report receiving very few requests 
for exceptions and granting even fewer.9  However, some fear that stricter enforcement of 
penalties for noncooperation may encourage some clients to seek an exception even in the 
absence of qualifying circumstances.  Second, because States grant few exceptions, yet 
domestic violence among the TANF population is reportedly widespread,10 there is 
concern that some clients may not request an exception even when they do have 
circumstances that meet a States definition of good cause.  Some fear that TANF clients 
may not be adequately informed of their right to request an exception or may have other 
reasons or disincentives for not requesting an exception. 
This report describes the use of good cause exceptions in six focus States.  We describe 
State policies and processes regarding good cause exceptions to child support cooperation 
requirements.  We review State efforts to preserve the safety of clients who are granted an 
exception.  We also explore reasons and disincentives that may lead clients not to request 
good cause exceptions.  Disincentives are of particular interest because of the apparent 
disparity between the high incidence of domestic violence within the TANF population 
and the relatively small number of requests for good cause exceptions. 
SCOPE AND METHODOLOGY 
To examine State use of good cause exceptions to child support enforcement cooperation 
requirements, we began by gathering information from local child support and public 
assistance offices.  Administrators from 99 local child support offices and 103 public 
assistance offices in six States - California, Georgia, Illinois, New Jersey, Texas and 
Virginia - returned mail surveys regarding good cause exception policies and practices. 
We also gathered and reviewed agency documents including client cooperation policy 
statements, standardized claim forms, examples of correspondence with clients, and other 
related documents.  Additionally, we made site visits to a subset of local offices, visiting 
2
  offices in one or two cities and their surrounding areas in each of the six focus States. 
During these visits, we conducted interviews with approximately 180 local public 
assistance and child support managers and caseworkers.  At almost all offices, we 
interviewed one or more managers, then separately interviewed two or more caseworkers. 
These respondents provided detailed information about how good cause exception policies 
are implemented, as well as the effect of good cause exceptions on office operations, staff, 
and clients.  Resource constraints prevented us from directly interviewing clients.  Finally, 
we conducted telephone interviews of administrators from each States child support 
enforcement and public assistance agency to confirm information regarding State policies. 
We purposively selected the six focus States to include a variety of implementation 
strategies and experiences regarding client cooperation and good cause exceptions.  To 
achieve this variety, we considered many criteria including type of penalties for 
noncooperation, number of good cause requests, number of good cause exceptions 
granted, Family Violence Option (FVO) status, outstanding program characteristics 
(innovations, privatization, etc.), and geographic region.  We also purposively selected 
local child support and public assistance offices within these States to provide a mix of 
urban, suburban, mid-size, and rural locations.  For on-site interviews, we visited offices in 
one or two cities and their surrounding areas in each focus State.  The selection of focus 
States does not purport to be representative of the nation, nor do local offices represent all 
offices within individual focus States.  The selections do, however, allow for examination 
of good cause exceptions to TANF client cooperation processes under conditions found 
throughout the country. 
This report relies on the experiences and perceptions of local office survey respondents 
and interviewees.  We did not attempt to independently verify the information provided. 
However, the information included in the report does relate the experience of front line 
staff who deliver services to clients on a daily basis, and who demonstrate considerable 
concern for the effectiveness of their programs.  This study was conducted in accordance 
with the Quality Standards for Inspections issued by the Presidents Council on Integrity 
and Efficiency. 
COMPANION REPORTS 
This is one of four OIG reports on how States gain TANF client cooperation with child 
support enforcement.  One companion report, Client Cooperation with Child Support 
Enforcement: Policies and Practices (OEI-06-98-00040), provides an overview of 
cooperation polices and how they are implemented. Another report, Client Cooperation 
with Child Support Enforcement: Challenges and Strategies to Improvement (OEI-06-98-
00041), examines why some clients do not cooperate and how States  attempt to gain 
cooperation. The remaining report, Client Cooperation with Child Support Enforcement: 
The Role of Public Assistance Agencies (OEI-06-98-00042), discusses responsibilities of 
public assistance agencies and collaboration between agencies. 
3
 F I N D I N G S  
STATE USE OF GOOD CAUSE EXCEPTIONS 
All six focus States have adopted the prior Federal definition of good cause by which 
TANF clients may be exempted from child support cooperation requirements in cases of 
domestic violence, when conception was the result of forcible rape or incest, when 
adoption is pending, or when the client is consulting with a social service agency regarding 
the possibility of adoption.  Some focus States have added circumstances that warrant an 
exception, including mental incapacity of the client, cases with non-parent caretakers, 
cases in which conception occurred from artificial insemination, cases in which clients lack 
knowledge about absent parents, and cases in which domestic violence is anticipated.  Five 
focus States make their public assistance agency responsible for evaluating requests for 
good cause exceptions.  In the sixth State, child support workers evaluate requests for 
good cause exceptions, but are employees of the public assistance agency and work in the 
same offices as public assistance workers throughout the State. 
Staff in Local Public Assistance and Child Support Offices Report Few Requests 
for Good Cause Exceptions and Virtually No Fraudulent Claims 
While our study makes no attempt to quantify the number of good cause exception 
requests processed by local offices, we did ask local office staff their perception of the 
frequency of requests.  Consistent with prior research about the use of good cause 
exceptions, respondents in our focus States report receiving few requests for exceptions. 
In many offices, even experienced caseworkers have never had a client request a good 
cause exception, or have only received one or two requests in several years.  Typical 
caseworker and manager responses to questions about the frequency of requests for 
exceptions were, Ive had one in six years, and Very, very few.  There is a form in 
there that the worker is supposed to fill out and turn in each month on each [client] that 
claims good cause.  I cant remember the last time I had to fill one out.  One local 
public assistance office administrator reported participating in a Statewide review of good 
cause claims and related her experiences.  I had to review 17 of them.  We don't get a lot 
of them.  They are primarily domestic violence (proven) or threat of domestic violence. 
Normally they can prove their claim. 
Staff believe that most, if not all, requests for good cause exceptions are legitimate.  One 
worker expressed what we heard from most staff, The few cases I have had have been 
outright, fully validated cases, such as incest or sexual abuse.  The clients could validate 
this, and were not just making up a story.  While staff did recognize the potential for 
clients to fraudulently claim a good cause exception simply to avoid cooperating with child 
support enforcement, no caseworker or manager we interviewed was aware of any such 
attempted fraud.  Rather, staff indicate that the administrative process for requesting 
4
 an exception deters fraud.  Most offices require corroboration, and a client may have to 
relay their story to more than one staff member in one or both agencies.  Additionally, 
staff experience in confronting other types of welfare fraud likely helps them in judging the 
authenticity of client good cause exception requests. 
Public Assistance Staff Provide at Least Minimal Notification to TANF Clients of 
Their Right to Request a Good Cause Exception, Yet Few Individually Assess 
Clients for the Circumstances that Might Warrant an Exception 
Ninety-three percent of public assistance staff responding report their offices provide new 
applicants and clients seeking re-determination of benefits written materials explaining 
their right to request a good cause exception.  These materials are often included with 
application forms and documents that explain requirements to cooperate with child 
support enforcement.  The written explanations of good cause exceptions often include a 
list of the circumstances that may warrant an exception and the standards of proof needed 
to corroborate the circumstances.  Additionally, public assistance staff often provide a 
second notice of the opportunity to request a good cause exception to TANF clients who 
have already been deemed noncooperative by the child support agency. 
In addition to providing written notification, 87 percent of public assistance staff 
responding report they discuss good cause exceptions with clients during the application 
process.  Staff explain that they typically use the written materials as guides for these 
discussions.  However, staff also report they are unlikely to extend their discussions 
beyond the written materials.  That is, staff report that during discussions about good 
cause exceptions they seldom go so far as to ask TANF clients whether any of the 
circumstances exist in their lives or to otherwise assess individual needs.11  One public 
assistance administrator summarizes, We dont really look for domestic violence.  The 
clients have to bring it up.  Upon completion of notice, 96 percent of public assistance 
respondents report they require their clients to sign a form indicating they have received 
notification of their right to request a good cause exception. 
TANF Clients Typically Submit Requests for Good Cause Exceptions to Public 
Assistance Staff, Either Verbally or in Writing, Though Child Support Staff May 
Also Become Involved 
During application or re-determination interviews, clients may formally request a good 
cause exception directly with public assistance staff.  Among local public assistance 
respondents, 40 percent report they rely simply on a verbal request, 29 percent require a 
written request, and the remaining 31 percent accept either verbal or written requests for 
exceptions.  In some States, the written form for requesting an exception is printed on the 
same form that notifies clients of the States child support cooperation requirements.  One 
States written form includes a check box beside the following statement, I wish to claim 
good cause for not cooperating with child support requirements.  The situations which 
5
  justify good cause have been explained to me.  I agree to provide evidence to support 
this claim of good cause within 20 days. 
Some clients do not mention circumstances that warrant a good cause exception until they 
are meeting with child support enforcement staff.  This may occur because child support 
staff often ask more detailed questions and clients may only then realize the risk that the 
State may actually contact the noncustodial parent.  Respondents report that when child 
support workers become aware of circumstances that may warrant a good cause 
exception, they typically refer the client back to the public assistance agency to request an 
exception.  As one child support worker explains, If the client comes in and there is 
some sort of fear for their life, their well being, or if there is any type of domestic 
violence, we can always refer [clients] to apply for good cause through the welfare 
department.  We tell our clients they need to communicate this back to welfare as soon as 
possible. Child support staff report they also notify the public assistance agency of their 
action. 
States Require TANF Clients to Corroborate Circumstances That Warrant Good 
Cause Exceptions Within a Specified Time Frame, and Most Local Offices Will 
Grant Time Extensions and Assist Clients in Gathering Information 
All focus States have policies requiring TANF clients to provide documentation of 
circumstances that warrant a good cause exception.  Almost all local public assistance 
staff (93 percent) report they require proof or documentation of domestic violence, and 
most (81 percent) also require documentation that conception occurred as a result of 
forcible rape or incest, or that adoption is pending. 
As shown in Table 1, local offices accept several types of evidence to corroborate 
circumstances of domestic violence, including police reports, court orders, hospital 
records, and shelter documentation.  More than half of local respondents report they also 
accept written statements of clients (59 percent), or friends of clients (62 percent), who 
attest to having knowledge of domestic violence.  Some local offices accept verbal 
statements from the clients or acquaintances, without need for written verification. 
To corroborate pending adoption or conception as a result of forcible rape or incest, 
clients may present such documentation as adoption papers, court documents, birth 
certificates, police reports and hospital records.  Staff note that clients may not have 
documented the nature of conception at the time of birth, and that client statements are 
often allowed as acceptable evidence of these circumstances. 
States require TANF clients to corroborate circumstances that warrant a good cause 
exception promptly upon request for an exception, though many grant time extensions. 
Ninety-one percent of public assistance staff report their offices allow recipients between 5 
and 30 days to produce good cause evidence.  Only nine percent of local respondents 
report initially allowing clients more than 30 days to corroborate their claims.  Regardless 
6
 of time limits, 89 percent of public assistance staff say they will extend the time allowed 
for corroboration.  Local public assistance staff report granting extensions often (28 
percent), sometimes (35 percent) or rarely (37 percent). 
Table 1: DOCUMENTATION ACCEPTED FOR DOMESTIC VIOLENCE CASES 
Documentation of Domestic Violence  Local Focus Offices 
Police record or documentation of abuse in the home  94% (89 offices) 
Protective order already in place  89% (85) 
Hospital record or documentation of abuse  86 % (82) 
Shelter documentation or statement  79 % (75) 
Written statement by a friend of the custodial parent  62 % (59) 
Referral to domestic violence shelter  61 % (58) 
Written statement by the custodial parent  59 % (56) 
Verbal statement by the custodial parent  34 % (32) 
Verbal or written statement by mental health professional, clergy, 
medical, court, or social service agency  21 % (20) 
Verbal statement by a friend of the custodial parent  19 % (18) 
Eighty-three percent of local public assistance staff report they will assist clients in 
gathering information or evidence to document circumstances which warrant a good cause 
exception.  Assistance would involve contacting courts, hospitals, police departments, or 
other agencies.  For example, one worker said, We ask [the client] for a copy of a 
restraining order.  If they dont have it with them, I will call the police asking them to fax 
a copy.  While most local offices wait until clients request assistance in gathering 
documentation, twenty-eight percent of respondents report their staff will automatically 
assist clients without a request.  Prior to welfare reform, States were required to provide 
this type of assistance to clients upon request.  Sixteen percent of local public assistance 
respondents report their staff will not assist clients in obtaining documents to corroborate 
their request for a good cause exception.  Our research suggests, however, that gathering 
documentation for  corroboration of claims is not a substantial barrier to most clients who 
seek an exception, whether or not staff assist them, and that, if necessary, staff may even 
waive the requirement for documentation. 
Local Public Assistance Staff Evaluate Requests for Good Cause Exceptions and 
Have Discretion in Deciding Whether Clients Qualify 
Respondents report that front line public assistance staff typically decide whether to grant 
good cause exceptions to requirements to cooperate with child support enforcement. 
Caseworkers explain that they have the advantage of dealing directly with TANF clients to 
7
 evaluate their claims.  Workers suggest that discussion with clients often helps them 
understand the clients circumstances.  As one worker reports, It depends on the client's 
situation. You can usually tell [if the circumstances exist]. 
Public assistance managers and supervisors also often participate in good cause exception 
determinations.  These administrators may simply consult with caseworkers, or they may 
actually make the final decision.  During interviews, many caseworkers said they had 
limited experience with requests for exceptions and that they would seek input from a 
supervisor before making a final determination.  They report, Cases are so few that a 
worker would come to us to ask how to handle a case, because it is not a routine 
situation. and I wouldnt take good cause for someone without having discussed it with 
at least another co-worker to make sure that Im doing it right.  I have the authority and 
it could be my judgement, but I would feel more comfortable taking it to my supervisor 
because it is not something that comes up every day.  Maybe, once a year you get a client 
claiming good cause.  A few public assistance workers report routinely consulting their 
child support enforcement counterpart before deciding to grant or deny requests for 
exceptions.  When this occurs, child support staff typically review and comment on the 
findings and basis for a proposed determination. 
Staff appear to have substantial discretion as they evaluate good cause exception requests. 
Even in the absence of written documentation, staff may grant an exception.  For example, 
one caseworker describes, In most cases, now, we just take her at her word, and she 
does not have to have any other evidence, like a police report.  If she says she is afraid 
[and] has verification, fine.  But if not, we will take her word for it.  Additionally, 
considering that so few clients request exceptions, staff appear to prefer to approve 
requests, lest they mistakenly deny a legitimate request.  As one supervisor explains, "Very 
few claims are ever refused because the liabilities far outweigh the benefit of collecting 
that support." 
Staff use internal agency determination forms to process requests for good cause 
exceptions in all focus States.  Some determination forms identify the circumstances for 
the request, and record client information, evidence provided, and the source of evidence. 
Other forms simply record whether the exception was granted.  Local public assistance 
offices typically notify TANF clients in writing of their decision to grant or deny a good 
cause exception request.  Such notice often includes information about any future steps 
the client needs to take.  Clients whose requests for a good cause exception are denied can 
appeal the decision.  Ninety percent of local public assistance staff report that clients may 
appeal a determination to a caseworkers supervisor.  If the dispute remains unresolved, 
clients can request a formal hearing. 
Most Public Assistance Offices Periodically Reassess Good Cause Exceptions 
Seventy-four percent of public assistance staff report their offices conduct periodic 
reassessments of good cause exceptions.  About half of these respondents specify that 
8
 they reassess every six months, while the others reassess every twelve months.  If 
circumstances have changed and a good cause exception no longer applies, the public 
assistance agency may rescind the exception, again requiring TANF clients to cooperate 
with child support enforcement.  About one-quarter of public assistance staff report that 
their office does not reassess clients with good cause exceptions.  Most of these offices do 
not have routine procedures for reassessment, and a few appear confused about their 
offices role, including some who believe the child support agency periodically reassesses 
clients with exceptions. 
Most State Child Support Agencies Do Not Pursue Paternity Establishment or 
Child Support Enforcement When a Good Cause Exception Is Granted 
Caseworkers explain that some TANF clients wish to pursue child support enforcement 
despite the existence of circumstances that warrant a good cause exception.  According to 
policy documents, five focus States will not pursue paternity establishment or child 
support enforcement in cases in which the client has been granted a good cause exception. 
The other State has a policy allowing clients to determine whether the child support 
agency will pursue enforcement.  However, 37 percent of local child support respondents 
report they will pursue support if the client wishes, including some local respondents from 
States with a policy not to pursue support.  Some of these respondents may be unclear 
about State policy because they have never encountered a good cause case, but it appears 
that some local staff may use discretion in pursuing support. 
Local child support staff report they handle cases with good cause exceptions in one of 
four ways:  the public assistance agency never refers the case to the child support agency; 
the case is referred, but the child support agency never adds it to their caseload; the case is 
referred and child support adds it to their caseload, but immediately closes the case, never 
pursuing enforcement; or, the case is referred and child support adds it to their caseload, 
but only pursues enforcement at the clients request. 
PRESERVING CLIENT SAFETY 
The objective of granting good cause exceptions is often to protect clients and children 
from harm.  In processing good cause requests, public assistance and child support staff 
report they have some mechanisms in place to help ensure this protection.  Local offices 
may also promote additional services to assist clients, beyond exempting them from child 
support cooperation requirements. 
Nearly All Local Public Assistance and Child Support Offices Make Some Effort to 
Preserve Client Safety, and 78 Percent of Staff Believe Good Cause Exceptions 
Reduce the Threat of Harm 
Ninety-two percent of local child support and 96 percent of local public assistance staff 
report having procedures in place to preserve the safety of custodial parents and children 
9
 who fear harm from noncustodial parents.  These procedures often center on preserving 
confidentiality of case information, but may still be modest efforts and not yet fully 
implemented.  Additionally, local child support and public assistance office efforts to 
preserve confidentiality may be limited by court documentation that is not kept secure. 
Staff from both agencies appear to appreciate the purpose of good cause exceptions, and 
78 percent of respondents in both agencies report they believe receiving a good cause 
exception reduces the threat of harm to the custodial parent and child.  Table 2 outlines 
procedures local offices use to enhance client safety. 
Table 2:  REPORTED PROCEDURES TO ENHANCE CLIENT SAFETY 
Procedures to Enhance Client Safety  Public Assistance  Child Support 
Focus Offices  Focus Offices 
Referral to domestic violence shelter  80% (76 offices)  29% (25 offices) 
Referral to domestic violence counselor or group  76% (73)  29% (25) 
Measures to protect client address confidentiality  58% (56)  72% (63) 
Flag in automated system to identify cases  35% (34)  51% (44) 
Many Public Assistance and Some Child Support Staff Refer TANF Clients Who 
Report Domestic Violence Concerns to Community Resources 
As reported in Table 2, primarily public assistance, but also child support, staff report they 
refer clients to community resources when domestic violence is a concern.  Typically, 
these referrals are to resources specific to domestic violence, such as women's shelters or 
violence counselors, but may include other community resources such as food banks, 
homeless shelters, churches and child care services.  A few public assistance offices we 
visited actively coordinated these additional social services.  For example, one urban office 
offered transportation to a nearby shelter.  In other public assistance offices, staff may 
simply pass out brochures, distribute shelter phone numbers, or verbally mention the 
availability of such resources.  As part of large social service agencies, some child support, 
and particularly public assistance offices, have counselors or social workers available on-
site to assist clients with domestic violence issues.  As one public assistance worker 
reports, We are not trained, in that we don't have advanced degrees, but we refer 
[clients to services].  A lot of times they are in various emotional states and they just 
need a social worker to talk to them.  They just need to tell their stories.  Staff are 
limited by the number of services available in their particular community.  Although there 
is wide variation in available services, most communities appear to have agencies or non-
profit entities which assist victims of domestic violence. 
10
 Protecting Client Addresses is a Common Practice of Local Public Assistance 
and Child Support Offices to Help Preserve Client Safety 
Noncustodial parents are likely to never be contacted for child support enforcement when 
a good cause exception has been granted.  However, a few child support offices may 
continue to pursue support even when a good cause exception has been granted, and some 
clients who are at risk of domestic violence may choose not to request an exception in 
order to pursue support.  Under these circumstances, child support and public assistance 
offices may contact noncustodial parents regarding their support obligations.  In sending 
letters and documents, offices may inadvertently reveal the county of residence or even 
more specific location information about the client and children.  A number of respondents 
report taking precautions in sending information to noncustodial parents in all cases, while 
others only take such measures when a client indicates a domestic violence problem.  For 
example, some staff report that they are not allowed to use client or child address 
information in correspondence with noncustodial parents when a case is known to involve 
a risk of domestic violence.  Other staff report they take no further action on such cases. 
Among focus State offices which report any precautionary procedures, 72 percent of child 
support and 58 percent of public assistance respondents report they take some measures 
to protect the confidentiality of client and child addresses. 
Most Local Offices Routinely Record Potential Domestic Violence Problems by 
Labeling Paper and Electronic Case Files Which Have Good Cause Exceptions 
Ninety-eight percent of local public assistance and 67 percent of child support staff in 
focus States keep client records which indicate the specific circumstances surrounding a 
good cause exception.  Records indicate and differentiate between whether the exception 
was granted because of domestic violence, conception due to forcible rape or incest, 
pending adoption, or other exceptions.  Most of these offices report their objective in 
differentiating files and flagging cases is to preserve client safety. 
Under welfare reform, States are required to place a Family Violence Indicator (FVI) on 
all relevant child support case files and are not allowed to release files which include an 
FVI if the State has reason to believe the release of this information may result in physical 
or emotional harm to the client or child.12  At the time of our data collection, several 
months prior to the Federal deadline for implementing the FVI, 35 percent of local public 
assistance and 51 percent of local child support staff report employing an automated flag 
in the agency computer system.  Among local child support offices which do not keep 
specific records of the type of good cause circumstances, respondents report staff are 
made aware of safety concerns through their automated referral from the public assistance 
agency. 
Staff report several advantages to indicating the reasons for a good cause claim on the 
clients record.  First, with this information, offices may be able to implement and apply 
precautionary measures to more effectively protect the client and possibly even pursue 
11
 child support.  Second, records of any exceptions will already be established when clients 
later attempt to receive public benefits or pursue child support in another county or State. 
That areas child support and public assistance staff are then notified of the potential for 
domestic violence when they review the case file.  Transfer of files to other counties or 
States may also benefit from child support agencies actually opening and immediately 
closing a case, rather than not opening one at all.  When the former occurs, the child 
support office in the clients new location would receive notice of the good cause 
exception, regardless of whether the client continues to receive TANF benefits. 
A third benefit to differentiating records by the types of circumstances for a good cause 
exception is that offices may be able to use the information for future case analysis and for 
aggregate data collection.  Numerous local child support (36 percent) and public 
assistance (48 percent) staff report they keep office statistics with this type of information. 
A quarter of the child support (24 percent) and public assistance (27 percent) staff report 
they refer to such information to determine how frequently the case has been, or should 
be, reviewed.  Child support staff explain that the information is used to help determine 
whether child support should be pursued; however, most often such cases are routinely 
closed or staff cease all action on the case. 
A Few Offices Assist Exempted TANF Clients in Creating a Safety Plan Outlining 
Actions They May Take to Escape Domestic Violence 
Requesting a good cause exception to child support cooperation requirements may open 
an opportunity for local agency staff to discuss an overall plan to safely escape domestic 
violence.  Advocates for victims of domestic violence suggest that developing such a 
safety plan for the custodial parent and child to escape future violence may enable the 
child support agency to eventually pursue support.  Commonly called safety plans, these 
documents are typically personalized to the particular client and outline emergency 
procedures which clients may take if they decide to leave their abuser, and may also 
provide information to ease their transition to independence.  These plans can serve as a 
checklist to ensure the victim does not neglect important details and is able to leave their 
abuser under the safest possible conditions.  Safety plans often contain phone numbers and 
locations of community resources, family, friends and police, as well as data on financial 
accounts and school records, and even instruction in physical self-defense.  In our focus 
States, just eight percent of local public assistance and three percent of local child support 
staff report they routinely provide at-risk clients with information about developing 
personal safety plans.  This assistance typically consists of distributing brochures outlining 
safety plans or providing samples of completed plans.13 
REASONS FOR CLIENTS NOT REQUESTING EXCEPTIONS 
Despite efforts to inform TANF clients about good cause exceptions, public assistance 
staff report they receive few requests for exceptions each year.  Even some experienced 
workers indicate they have never had a client request an exception.  Staff emphasize that 
12
 few, if any, clients fraudulently request an exception.  Rather, both child support and 
public assistance staff suggest a number of reasons and disincentives which help explain 
limited client use of good cause exceptions. 
Some TANF Clients May Not Request An Exception Because They Want the State 
to Pursue Child Support Enforcement 
As reported above, most of our focus States have policies not to pursue child support 
enforcement in cases with good cause exceptions.  As shown in Table 3, almost two-thirds 
of public assistance (66 percent) and child support (64 percent) staff report these policies 
are reasons that more potentially eligible clients do not request a good cause exception.  A 
child support worker comments, I think most of the custodial parents who have been 
abused still want to get the noncustodial parent to pay child support.  Child support 
income is potentially important to the self-sufficiency of TANF clients, and staff report 
that some clients who would qualify for good cause prefer to by-pass requesting an 
exception in hopes of eventually receiving child support.  In addition to financial motives, 
some clients want to pursue support for reasons of fairness, We get moms who feel the 
guy should not get off the hook for support by battering her.  We refer them to legal 
services to help them prepare restraining orders and everything they might need to take 
action to protect themselves.  If they want to pursue the case, it is up to them, but we feel 
they should have all necessary referrals to protect themselves. 
Table 3: CHILD SUPPORT AND PUBLIC ASSISTANCE STAFF PERCEPTIONS OF 
REASONS WHY TANF CLIENTS DO NOT REQUEST GOOD CAUSE EXCEPTIONS 
Reasons Why Clients Do Not  Public Assistance  Child Support 
Request Good Cause Exceptions  Focus Offices  Focus Offices 
Want to pursue child support  66% (65 offices)  64% (61 offices) 
Claiming lack of information may be safer  59% (58)  54% (52) 
Easier to claim lack of knowledge  58% (57)  58% (56) 
Embarrassed to admit domestic violence exists  56% (55)  46% (44) 
Fear intervention by child welfare agency  34% (34)  43% (41) 
Fear retaliation from the noncustodial parent  28% (28)  25% (25) 
Dont understand the good cause provisions  23% (23)  46% (44) 
Dont know about the good cause provision  6% (6)  34% (33) 
Some TANF Clients May Not Request An Exception Because They Fear Further 
Abuse or Unwanted Intervention From Other Social Service Agencies 
Although all focus States have begun to implement safety procedures, clients may still be 
concerned that an abusive noncustodial parent may be able to locate them because their 
13
 address or other information is not secure.  This apparently prevents some clients from 
disclosing any information about their situation.  Table 3 shows that 28 percent of public 
assistance and 25 percent of child support staff report some clients fear retaliation from a 
noncustodial parent.  Additionally, in local interviews, several child support workers in 
each State expressed concern about the confidentiality of court proceedings.  Their 
concerns include the need for a procedure to notify the judge of domestic violence 
concerns and the confidentiality of social security numbers and addresses on all court 
documents.  For example, one child support administrator explained, There is much 
frustration with the court process.  Court documents are public information, and 
therefore he can find out all of her information.  We cannot protect clients if it goes to 
court.  If we are going after him she wants us to guarantee that we can protect her. 
Fear of harm and immediate prevention of harm to their family may take precedence over 
disclosing any information about the noncustodial parent, including circumstances which 
would qualify for a good cause exception.  For example, public assistance staff explain, 
We have a lot of women who wont apply for assistance no matter how much we 
convince them its confidential.  It scares them to even talk. They are concerned that he 
could find out where she is. 
Some staff do not agree that pursuing support will automatically place a client at further 
risk.  In interviews, staff indicated that courts may take action to protect the client, such as 
issuing restraining orders.  A child support administrator reports, It's not always the case 
that enforcing child support in domestic violence cases endangers the mom.  The judge 
deals with domestic violence issues and it is out of our hands ... they handle that in family 
court.  Other tactics intended to minimize contact between the client and the 
noncustodial parent may allow offices to pursue support despite the threat of violence.14 
As also seen in Table 3, numerous child support (43 percent) and public assistance (34 
percent) staff believe that custodial parents may fear that disclosure of domestic abuse 
may lead to an intervention by the child welfare agency.  By admitting to a State agency 
that the household is at risk of violence, the client may be inviting an investigation that 
could jeopardize her custody.  A public assistance administrator says, I think many 
clients just dont bother to claim it and provide the documentation.  Others dont want to 
disclose that sort of thing.  Child protective services (CPS) sometimes gets involved.  If 
the mother claims that the child is in danger, she might fear the CPS will take the kids 
away.  Clients may also fear that police will be called to arrest the noncustodial parent for 
abuse, especially if child support enforcement in their State is part of a law enforcement 
agency. 
Some TANF Clients May Not Request An Exception Because They Find it Safer 
and Easier to Claim a Lack of Knowledge About Absent Parents 
Clients who fear retaliation or child welfare agency involvement, as well as clients who 
wish to avoid the process of requesting and corroborating circumstances that warrant a 
good cause exception, may find it safer and easier to simply cooperate with child support 
14
 enforcement than to request an exception.  As shown in Table 3, 59 percent of child 
support and 54 percent of public assistance respondents believe that clients may view 
claiming a lack of knowledge about absent parents as safer than requesting a good cause 
exception.  Similarly, 58 percent of respondents from each agency perceive that clients 
may view claiming a lack of knowledge as easier than requesting an exception.  A public 
assistance administrator explains,  I think rather than claim good cause they just tell us 
they dont know because its shorter and faster or because they think that nothing will 
happen.  So many of our clients have gone on and off welfare that they think because 
they didnt have to worry about it before, why should they have to worry about it now. 
As we report elsewhere, claiming a lack of knowledge about absent parents does not 
release clients from otherwise cooperating with child support enforcement efforts 
including keeping appointments for interviews, court hearings and genetic testing.15 
However, formally attesting to a lack of knowledge does satisfy the cooperation 
requirements of three of our focus States and may satisfy requirements to cooperate in 
good faith in other States.  Therefore, through this strategy clients may avoid being 
penalized for noncooperation, avoid providing information about a noncustodial parent, 
and avoid requesting and corroborating a good cause exception.  The primary 
disadvantage of the strategy for clients is that they are far less likely to have child support 
collections as a source of income once they stop receiving TANF benefits. 
Some TANF Clients May Not Request An Exception Because They Do Not Fully 
Understand Benefits and Requirements, and Staff May Not Provide Guidance 
Table 3 also shows that while 34 percent of child support workers report they believe 
more clients do not request exceptions because they do not know about them, only six 
percent of local public assistance staff believe this is a reason.  The difference here is likely 
to lie in the fact that it is primarily public assistance staff who are responsible for notifying 
clients of their right to request a good cause exception.  Perhaps more importantly, 23 
percent of public assistance and 46 percent of child support staff responding suggest that 
clients do not seek an exception because, although they are aware of the good cause 
exception, they do not fully understand it.  Clients often receive a large amount of 
information and answer many questions during their initial interview, of which only a small 
part involves discussion of good cause exceptions.  It may be difficult for clients to 
understand the significance of the provisions unless workers make a special effort to 
emphasize them. 
While 68 percent of public assistance staff report they include information about domestic 
violence and client safety in their staff training programs, only 48 percent of child support 
respondents report similar information in their training.  Several child support 
administrators told us that because it is the public assistance office which normally decides 
whether to grant good cause exceptions, they assume public assistance workers are trained 
to identify domestic violence, so there is little need to train their own 
15
 staff.  If staff are not trained to provide education and outreach to identify good cause 
circumstances, clients may not understand that they can request an exception or how to do 
so.  Without assistance from a worker, some clients may not identify themselves as 
potential candidates for good cause exceptions.  As one child support administrator 
comments, You may see some signs, but without training we dont really know how to 
identify the signs.  A public assistance administrator adds, We have had very limited 
training in domestic violence issues.  We deal with it purely on what the client tells us on 
a client-by-client basis.  We have no real standardized procedures. 
Additionally, although the term good cause has a formal meaning in child support 
cooperation regulations, we found staff sometimes also use the term, for example, to refer 
to the clients difficulty in arranging transportation to an appointment as a good cause 
for not cooperating.  While most workers appear to know that they use the same term to 
refer to a variety of situations, multiple use of the term good cause can create confusion 
and misunderstanding among staff and clients. 
Some TANF Clients May Not Request An Exception Because They Find It Difficult 
to Disclose Circumstances of Domestic Violence 
Also shown in Table 3, about half of public assistance (56 percent) and child support (46 
percent) staff report they perceive that clients are embarrassed to admit they are victims of 
domestic violence.  Clients may not want to disclose their circumstances to a stranger, 
especially if the worker is not able to take time to carefully explain the good cause 
exception and make an effort to gain the clients trust.  Clients may also be intimidated by 
the volume of information collected during an interview, particularly in the public 
assistance office.  Public assistance interviews can last from 30 minutes to two hours, 
covering a wide range of topics.  Some public assistance offices assign a single caseworker 
to handle nearly all aspects of a clients case, in part to allow the client to develop a 
relationship with that worker.  However, clients in other offices may communicate with 
different workers who specialize in various aspects of their case.  The physical setting of 
the office, particulary if interviews take place in a large room with no partitions for 
privacy, may also affect the clients willingness to divulge information. 
Creating an atmosphere that eases disclosure may be more difficult with victims of 
domestic violence than with other clients.  One male public assistance worker says,   
... when I talk to someone who has been in an abusive relationship, I find I have to be 
especially soft when I talk to them, tone everything down, and make them see I 
understand, and not to frighten them ....  Clients may be even more hesitant to confide in 
child support staff since they are likely to ask more questions specific to the father, and 
may be housed in a law enforcement agency that some clients may perceive as threatening. 
One worker explains that they consider client comfort, We let her know that we are 
going to help her as best we can, [and] that we understand the situation.  So we get them 
to open up as much as possible, but still there is a shame factor, and we know she usually 
does not tell us everything. 
16
 R E C O M M E N D A T I O N S  
Successful operation of the child support enforcement program requires effective, 
cooperative action by both the Office of Child Support Enforcement and the Office of 
Family Assistance.  Therefore, we recommend that the Assistant Secretary for the 
Administration for Children and Families (ACF) encourage States to: 
Develop Strategies That Allow TANF Clients Who May Be at Risk of Domestic 
Violence to Safely Pursue Child Support 
Child support agencies typically do not pursue child support for TANF clients who are 
granted a good cause exception, yet victims of domestic violence would likely benefit 
from the additional income child support could provide.  ACF should assist States in 
developing practices which would allow clients who are at risk of domestic violence to 
decide whether the States child support agency will pursue support and help protect 
clients who decide to do so.  This might include taking precautions during court 
appearances, making further referrals to community resources, and assisting clients to 
develop safety plans. 
Enhance Local Office Training to Improve Staff Understanding of Good Cause 
Exceptions and Better Equip Workers to Assist TANF Clients At Risk 
For effective use of good cause exceptions, staff should understand the benefits and 
requirements associated with exceptions, be able to identify individuals who may be 
eligible for an exception, and be prepared to assist clients in requesting and corroborating 
an exception.  ACF should assist States in developing training tools that both clarify State 
policy and address ways to individually assess and work with clients who are at risk of 
domestic violence to improve their safety and cooperation. 
Evaluate Their Standards and Practices for Protecting TANF Client Confidentiality 
and Assess the Need for Further Federal Guidelines 
Clients who perceive themselves at risk of domestic violence may fear disclosure of 
personal information, discouraging them from either cooperating with child support or 
requesting a good cause exception.  ACF should assess agency practices in contacting 
noncustodial parents, including the use of identifying information on correspondence and 
court documents, and encourage all agencies involved to promote a safe environment for 
clients.  Also, ACF should explore with States the feasibility of labeling all cases with 
good cause exceptions or risk of domestic violence, both to enhance confidentiality and to 
improve caseload analysis.  In communicating with States on these issues, ACF should 
assess whether further Federal guidance is needed. 
ACF did not provide comments in response to our draft report and recommendations. 
17
 E N D N O T E S  
1.  The Personal Responsibility and Work Opportunity Act of 1996 
2.  45 CFR 323.42. 
3.  45 CFR 323.40. 
4.  Ibid. 
5.	 The Federal Office of Child Support Enforcement (OCSE) has helped facilitate a number 
of national meetings to further explore the ramifications of these changes, and created 
materials to provide assistance to States in implementing the policy regarding good cause 
exceptions.  OCSE has also funded several demonstration projects to test different models 
for using good cause exceptions and assisting clients at risk of domestic violence. 
6.  42 U.S.C. Section 654(29). 
7.	 We do not attempt to assess any change in agency responsibility for administering good 
cause exceptions among our focus States as a result of welfare reform. 
8.	 In a related matter, welfare reform legislation also instituted the Family Violence Option 
(FVO), a provision designed to take into account the effect of domestic violence on a 
clients ability to meet program requirements.  States which adopt the FVO may exempt 
TANF clients from child support cooperation requirements, as well as work and other 
program requirements, and avoid Federal penalties for failure to meet work participation 
rates if the State demonstrates that their failure was due to exempting clients for 
Federally recognized good cause domestic violence waivers.  In order to grant these 
waivers, States must assess clients for a history of domestic violence, refer such 
individuals to counseling or supportive services, and assure that waivers from program 
requirements are accompanied by an appropriate service plan.  Federal Register: April 
12, 1999 (Volume 64, Number 69), page 17881.  At the time of data collection, three of 
our focus States had passed the FVO.  We determined that it was too early in the 
implementation of this provision to assess the impact of adopting the FVO. 
9.	 For example, the Office of Child Support Enforcement reports that only 4,196 clients (of a 
total AFDC-TANF caseload of 6,461,723 clients) requested a good cause exception to 
child support cooperation requirements in 1997, and only 2,296 exceptions were granted 
by States. The Federal Office of Child Support Enforcement, 22nd Annual Report, 
Appendix C, Tables 46 and 26, respectively. 
10.	 See, for example, Domestic Violence: Prevalence and Implications for Employment 
Among Welfare Recipients, Government Accounting Office, November 1998, 
GAO/HEHS-99-12. 
18
 11.	 The frequency of assessments may increase as States implement the FVO, which requires 
States to screen public assistance applicants for a history of domestic violence. 
12.  42 U.S.C. 654(26)(B)(C). 
13.	 States which adopt the Family Violence Option are required to develop appropriate 
service plans for victims of domestic violence, which would typically include safety 
considerations. 
14.	 A recent report produced collaboratively by OCSE and The Center for Law and Social 
Policy, Models for Safe Child Support Enforcement, describes a number of strategies 
employed by States in order to enhance client safety while pursuing support. 
15.	 For more information on cooperation requirements, please refer to our companion report 
entitled, Client Cooperation with Child Support Enforcement: Policies and Practices, OEI 
06-98-00040, 2000. 
19