Barriers in Closing Child Support Enforcement Cases
September 2002
OEI-06-00-00471
Office of Inspector General
Office of Evaluation and Inspections
Region VI E X E C U T I V E  S U M M A R Y  
PURPOSE 
To identify barriers confronted by State and local agencies in closing child support enforcement 
cases. 
BACKGROUND 
In 1999, the Office of Child Support Enforcement (OCSE) revised Federal regulations by 
adding flexibility, which now allows State agencies to close child support enforcement cases for 
any one of 12 reasons.  Closure of cases ends all State enforcement action in these cases. 
Regulations require that a case meet one of these 12 closure reasons, and that the State provide 
clients with a 60-day advance notice of closure under 9 of the reasons. In the report Use of 
Federal Child Support Case Closure Regulations, OEI 06-00-00470, February 2002, we 
estimated a 32 percent national child support enforcement case closure error rate, due primarily 
to inadequate notification. 
When conducting on-site data collection for the above cited report, we also gathered 
information from child support enforcement managers familiar with case closure practices in 10 
randomly selected States. We conducted a standardized interview with one or more managers 
in each State regarding their agencys closure processes. We also examined the procedural 
steps involved in closing cases, documentation of closure activities, and written notices used by 
these States to inform clients of intended closures.  The findings presented in this report are only 
representative of the 10 sample States, but the insight we gleaned from site visits and interviews 
will likely benefit other State child support enforcement agencies as they attempt to improve 
case closure procedures. 
FINDINGS 
Sample States are Hindered in Properly Closing Child Support Enforcement 
Cases by Scarce Resources, Inconsistent Local Procedures, and Complex State 
Legal Requirements 
While State child support enforcement managers report that they find the additional flexibility 
allowed by the 1999 regulations helpful, a number of barriers hinder State case closure 
activities. Local office managers cannot always devote sufficient staff time to identifying and 
reviewing potential closures because other enforcement tasks often take priority.  At the same 
time, lack of automated processes and human error result in clients not being notified of 
impending closures. Even when provided, advance closure notices used by 6 sample States do 
not contain all the information needed, and States cannot 
ii 
Barriers in Closing Child Support Enforcement Cases  OEI-06-00-00471  always verify that notices are received by custodial parents. Among other problems, ineffective 
prompting systems contribute to closure improperly occurring too early. Use of overly complex 
State coding schemes and the need to coordinate with the courts complicate closures for child 
support enforcement staff.  We also found that closures involving current and former TANF 
recipients and those closed for reasons of client non-cooperation, lost contact, and client-
request pose particular difficulties for staff. 
Sample States Attempt to Avoid Improper Closures Through Training, Monitoring, 
and Reopening Child Support Enforcement Cases Closed in Error 
Sample States appear to be addressing the challenges of only closing cases with no potential for 
successful enforcement. States train caseworkers about case closure regulations and 
procedures, and provide special guides or manuals which instruct workers about how to 
perform each function of closure. Monitoring tools, such as State self-assessments, assist 
managers in identifying problems and improving closure processes. Finally, managers report 
that reopening any cases closed in error is easy, because States do not purge electronic 
records. 
OPPORTUNITIES FOR IMPROVEMENT 
Based on our analysis of the experience of these States, we offer to the Administration for 
Children and Families (ACF) and State child support enforcement agencies the following steps 
to improve case closure processes. 
Develop a model advance closure notice for States to use as a template. 
Provide technical assistance and encourage States to improve their case closure 
processes by States incorporation of the following strategies: 
<	 Simplifying State child support enforcement case closure codes by aligning them 
with the 12 Federal closure reasons. 
<  Automating State processes for identifying and closing cases. 
<  Performing routine monitoring of State child support enforcement case closure 
activities. 
<  Targeting problematic child support enforcement case types and case closure 
reasons for further staff review. 
<  Training local State child support enforcement staff to avert troublesome 
procedural variation and to ensure that clients receive advance notice of closure. 
iiii 
Barriers in Closing Child Support Enforcement Cases  OEI-06-00-00471  T A B L E   O F   C O N T E N T S  
PAGE

EXECUTIVE SUMMARY ...................................................... i

INTRODUCTION .............................................................1

FINDINGS

Identifying Cases for Closure  ................................................5

Reviewing and Coding Closures ..............................................7

Providing Advance Notice ..................................................8

Closing Cases  ...........................................................9

Particularly Challenging Cases  ..............................................10

Strategies for Improving Case Closure Procedures ...............................12

OPPORTUNITIES FOR IMPROVEMENT  ...................................... 14

ENDNOTES ................................................................ 16

ACKNOWLEDGMENTS ..................................................... 17

Barriers in Closing Child Support Enforcement Cases  OEI-06-00-00471  I N T R O D U C T I O N  
PURPOSE 
To identify barriers confronted by State and local agencies in closing child support enforcement 
cases. 
BACKGROUND 
Federal law has long recognized that State child support enforcement agencies must have the 
capability to close cases for various reasons. For example, States close cases in which a child 
support order is no longer enforceable because the child has reached the age of emancipation. 
States may also wish to close cases with little likelihood of successful enforcement, such as 
cases in which the custodial parent provides no useful information about the noncustodial parent 
or alleged father.  Because child support will not be enforced once a case is closed, States must 
exercise care in closing these cases. Federal regulation is designed to ensure that cases are 
closed only after they are completely resolved or determined to be unworkable. 
Federal Regulations 
Under the 1988 Family Support Act, the Office of Child Support Enforcement (OCSE) 
established case closure criteria allowing States to close certain cases.1 However, these 
regulations were criticized by some who argued the regulations made it too difficult to close 
certain unworkable cases. In response to the complaints, OCSE formed a review committee in 
1996 comprised of staff and elected officials from local, State, and Federal governments to 
review the regulations. The committee review led to revised Federal child support enforcement 
case closure regulations that became effective April 9, 1999.2 According to the final rule, the 
new regulations balance [OCSEs] concern that all children receive the help they need in 
establishing paternity and securing support, while being responsive to administrative 
concerns for maintaining caseloads that include only those cases in which there is 
adequate information or likelihood of successfully providing support.3 The 1999 rule 
added flexibility that generally made it easier for States to close more cases. It also enhanced 
client safeguards designed to ensure that States notify child support enforcement clients before 
closing cases. 
Current regulations allow, but do not require, State child support enforcement agencies to close 
cases that meet one of the 12 Federal child support enforcement closure reasons.  Four of the 
closure reasons cannot be used to close cases involving current recipients of Temporary 
Assistance for Needy Families (TANF).  Nine of the 12 closure reasons require that the 
recipient of services (typically a custodial parent or another State) be notified of the State child 
support enforcement agencys intent to close the case. 
11 
Barriers in Closing Child Support Enforcement Cases  OEI-06-00-00471  Twelve Allowable Closure Reasons Under Federal Regulations 
Notice Required 
No Enforceable Order and Arrearages Less Than $500

Noncustodial Parent is Deceased

Paternity Cannot Be Established

Noncustodial Parents Location is Unknown

Noncustodial Parent is Disabled, Institutionalized, or Incarcerated

Noncustodial Parent is a Foreign Citizen

Agency has Lost Contact with a Non-TANF Client

A Non-TANF Client is Non-cooperative

An Initiating State is Non-responsive in an Interstate Case

Notice Not Required 
Agency has Completed Locate-only Services in Non-TANF Case

Non-TANF Custodial Parent Requests Closure

A Good Cause Exception has Been Granted

Notice must be provided in writing 60 days before closure of a child support enforcement case 
is allowed in 9 of the 12 allowable reasons for closure. A case must be kept open if, within 60 
days, new information becomes available which could lead to the establishment of paternity or a 
support order, or to enforcement of an existing order.  Once a case is closed, the recipient of 
services may request that the case be reopened, if circumstances change and enforcement 
becomes possible. 
Earlier, we estimated the extent of errors in closing child support enforcement cases through a 
nationally representative sample of child support cases closed over a three-month period in 
2000.  Our report, Use of Federal Child Support Case Closure Regulations, OEI 06-00-
00470, February 2002, contains the full results. Our review revealed an estimated national 
case closure error rate of 32 percent, due primarily to inadequate notification. 
State Incentives To Close Child Support Enforcement Cases 
State incentives for closing child support enforcement cases include freeing staff to concentrate 
on cases with greater likelihood of success and maximizing the Federal incentive funding. 
Closing unworkable cases may allow States to allocate their limited resources to cases with 
greater potential for successful enforcement.  States may also improve their child support 
enforcement performance indicators, upon which much of the Federal incentive funding is 
based, by reducing the total number of cases in their caseload.4 While these incentives are 
legitimate reasons for closing unworkable child support enforcement cases, some advocates 
have voiced concern that States could be motivated to close difficult-to-work cases even 
though they may not meet a Federal closure reason. 
22 
Barriers in Closing Child Support Enforcement Cases  OEI-06-00-00471  Monitoring Case Closures of Child Support Enforcement Cases 
Until the mid-1990s, OCSE conducted compliance audits of State child support enforcement 
cases, which included an analysis of closed cases. With passage of the Personal Responsibility 
and Work Opportunity Reconciliation Act, OCSE replaced compliance audits with a 
requirement that State child support enforcement agencies conduct annual self-assessments of 
their own performance.5 State agencies were required to begin reporting the results of their 
self-assessments, and any corrective actions proposed or taken, to OCSE in Fiscal Year 
1998.6  State agencies are encouraged to use their self-assessments as management tools to 
identify any weaknesses, non-compliance with regulations, and opportunities for improvement. 
Closure of cases is one of eight required categories that State agencies must assess.  Federal 
self-assessment regulations require that at least 90 percent of closed child support enforcement 
cases reviewed by States meet the Federal regulations.7 
State self-assessments provide information about child support enforcement case closure 
activities in individual States. The reports for Fiscal Year 1999 (the most recent assessment 
period at the time of our studys pre-inspection) showed many States had improperly closed at 
least some child support enforcement cases, and State agencies proposed a variety of 
corrective actions.  These reports helped to identify both potential vulnerabilities related to 
closing cases and effective practices.8 However, there has been no national review since the 
new regulations were issued in 1999. 
METHODOLOGY 
Study Focus 
This report identifies barriers to proper case closure confronting 10 State child support 
enforcement agencies. Our observations and the experiences of managers described in this 
report are only representative of those 10 State child support enforcement agencies. 
Nevertheless, the insight we gleaned from site visits and interviews will likely benefit other State 
child support enforcement agencies as they attempt to improve case closure procedures. 
Sample of States 
We randomly selected 10 States using a stratified sampling method. In selecting the States, we 
stratified the 48 contiguous States9 and the District of Columbia into two groups:  one stratum 
included the eight States with the largest child support enforcement caseloads, which are known 
as the Big 8 States and have about 50 percent of the nations child support enforcement 
caseload;10, 11 and the other stratum included all other States.  This stratification ensured that 
our sample contained some of the Big 8 States as well as States with smaller caseloads.  We 
randomly selected four States from the large-caseload stratum: California; New York; Ohio; 
33 
Barriers in Closing Child Support Enforcement Cases  OEI-06-00-00471  and Pennsylvania, and six States from the other stratum: Alabama, Connecticut, Mississippi, 
Montana, New Mexico, and South Carolina. 
Data Collection 
We gathered information about closure processes from managers of all 10 State child support 
enforcement agencies.  To gather this data, we interviewed at least one manager familiar with 
case closure procedures. Other agency personnel, such as the State child support enforcement 
agency director and information technology staff, also participated in some interviews. We 
used a standardized interview protocol to obtain information about various methods of 
identifying cases for closure, use of automation in the closure process, staff responsibilities, any 
problems experienced in closing cases, and vulnerabilities that could potentially lead to 
improper closure.  We also examined the procedural steps involved in closing cases in these 
States and how agencies document closure activities. We also obtained examples of written 
notices used by the 10 States to inform clients of intended closures, and discussed their use with 
managers. 
Analysis 
To better understand the potential improvement opportunities, our data in this report consists of 
qualitative information about State case closure processes and procedures, and examples of 
advance written notices sent to clients.  Our analysis identifies commonalities and differences in 
State experiences in closing cases. We present trends among the 10 States in closure 
procedures, practices, and barriers, as well as unique State problems and strategies. We also 
determined the information that was needed in advance notices to fully inform clients of an 
impending closure and whether notices used by the 10 State child support enforcement 
agencies contained this information. 
This study was conducted in accordance with the Quality Standards for Inspections issued by 
the Presidents Council on Integrity and Efficiency. 
44 
Barriers in Closing Child Support Enforcement Cases  OEI-06-00-00471  F I N D I N G S  
We gathered information from child support enforcement managers familiar with case closure 
practices in 10 randomly selected States regarding the procedural steps involved in closing 
cases, documenting closure activities, and written notices used by these States to inform clients 
of intended closures. We found that barriers to proper closure include scarce resources, 
inconsistent procedures, and complex legal requirements. Closing certain types of cases also 
poses particular difficulties to staff. Agency managers are largely aware of these barriers and 
appear to be making efforts to improve processes through staff training and monitoring. 
IDENTIFYING CASES FOR CLOSURE 
Child support enforcement agencies from the 10 sample States reported closing 198,483 cases 
over a three-month period in 2000. These closures represent approximately 3.5 percent of the 
total 1999 child support enforcement caseload of the 10 States.12 Managers from all 10 
sample States report their agencies have established procedures to identify unworkable child 
support cases potentially eligible for closure. 
As child support enforcement agencies in sample States increasingly attempt to 
close cases, they find the added flexibility of the 1999 regulations helpful 
Child support enforcement managers from the 10 sample States generally report aggressively 
seeking to identify cases that are eligible for closure and suggest that the 1999 regulation 
changes make closure easier.  Believing that their caseloads contain far more unworkable cases 
than are currently being closed, managers generally express a desire to close more cases. 
Closing unworkable cases reportedly allows caseworkers to concentrate their activities on 
cases with greater likelihood for successful enforcement.  By removing unworkable cases from 
the automated work lists, closure allows workers to focus on cases with more potential for 
collections. Managers also view case closure as an increasingly important tool for improving 
performance.  The removal of unworkable cases from caseloads reportedly improves the 
numerical performance measures that determine Federal incentive funding to States. 
Child support enforcement agencies in all sample States use various automated 
techniques in identifying cases for closure 
Child support enforcement agencies in the 10 sample States use a number of automated 
techniques to initially identify cases that are potentially eligible for closure. Some of the more 
effective techniques involve automated queries of State caseload databases, both as special 
initiatives and routine reports.  An example of a special initiative is a project conducted in a 
large metropolitan county in one sample State. For this initiative, 
55 
Barriers in Closing Child Support Enforcement Cases  OEI-06-00-00471  computer programmers queried the automated system to identify cases in which the agency had 
been unable to locate the noncustodial parent or alleged father, and cases with dependents who 
had reached the age of emancipation. More than 60,000 cases were identified as potentially 
eligible for closure, and the State eventually closed most of these cases. Sample States also use 
automated systems to produce daily and periodic reports which alert caseworkers to review 
cases for potential closure. Examples of automated reports include prompts indicating that 
location efforts have been unsuccessful for one or three years, a dependent has reached the age 
of emancipation, or paternity cannot be established because of the age of the dependent. 
Cases identified through these reports are often added to daily work lists, providing 
caseworkers with a steady stream of cases to review for closure. 
Identification and closure of child support enforcement cases is hindered 
somewhat because local offices do not all have the same resources or 
procedures for conducting closure activities 
Many local offices reportedly do not have sufficient staff to devote time to identifying and 
closing cases. Some of these staff resource constraints can be mitigated by the use of 
automation. For example, the most advanced automated systems reportedly allow computer 
queries to identify a large number of cases eligible for closure with enough precision to avoid 
identifying cases that do not meet a closure reason.  These systems can also send the 
appropriate closure notice to the client and close the case at the end of the waiting period, with 
little additional human effort.  Managers express a great deal of satisfaction with these advanced 
systems and report very few persistent problems.  However, less advanced automated systems 
do not have the same capabilities to identify and process closures. In addition, some closure 
reasons are not conducive to fully-automated closure, such as closures involving the death of a 
noncustodial parent. Therefore, some potential closures only become apparent through routine 
casework or by staging special initiatives to manually find cases in the system.  Yet even when 
cases are identified as eligible for closure, staff must often choose between handling the closure 
or conducting other work. Caseworkers may decide that undertaking enforcement efforts in 
other cases, such as setting up wage withholding, are a better use of their time. 
Procedures for identifying and closing child support enforcement cases also reportedly vary by 
locality. For example, a single staff member handles all case closure activities in some local 
offices, while individual caseworkers handle closure of cases in their assigned caseload in other 
local offices. Under the latter arrangement, staff are reportedly more likely to need to choose 
between devoting their attention to case closure or other tasks. 
To overcome these local office barriers to properly closing cases, at least one sample State 
child support enforcement agency supplements local efforts by assigning central office staff to 
conduct special case closure projects.  Another sample State agency has created a special task 
force to help local offices more consistently process closures. 
66 
Barriers in Closing Child Support Enforcement Cases  OEI-06-00-00471  REVIEWING AND CODING CLOSURES 
Errors may occur if caseworkers do not review child support enforcement cases 
prior to closure 
Once a case is identified as eligible for closure for a particular reason, caseworkers are usually 
responsible for reviewing the case to validate that it meets the closure reason.  Closure reviews 
typically involve a caseworker reading case diaries, checking dates of events, confirming 
previous enforcement efforts, and examining court orders, payment histories, and account 
balances. This is largely a perfunctory step if eligibility for closure was initially identified by the 
caseworker. However, these reviews are often integral to avoiding erroneous closures for 
cases identified by automated systems.  Managers report that the large volume of cases 
identified for closure through automated methods makes it difficult for workers to review every 
case, and that closure errors may occur when each case is not reviewed.  However, managers 
maintain that providing advance notice helps give clients an opportunity to avoid an unwanted 
closure, and if an error does occur, reopening an erroneously closed case is fairly easy. 
Complicated State coding schemes and use of generic codes sometimes lead to 
closure errors and to erroneous documentation in case records 
Once a case has been reviewed, caseworkers or managers typically must enter an appropriate 
closure code into their automated systems. Incorrect codes are reportedly entered because of 
confusing State coding schemes, which are only loosely aligned with the 12 closure reasons 
outlined in Federal regulations, or by the use of generic closure codes.  All sample States have 
unique, sometimes complicated, schemes for coding a closure reason. Three sample States 
have more than 20 closure codes, with one of these three using as many as 90 codes.  Not 
surprisingly, managers report that staff have difficulty dealing with so many codes. Two other 
States allow caseworkers to use a generic code, such as Other Closure Reason, rather than 
specifying the precise closure reason. When using a generic code, caseworkers sometimes add 
remarks to the case log that explain why it was closed. However, managers report instances in 
which no reason is documented in the records. 
Managers suggest that using a limited number of codes, which link directly to the Federal 
authority under which cases may be closed, helps reduce caseworker confusion and avoid 
potential errors.  Five sample States have closely aligned their closure codes with the 1999 
regulations, so that each State code matches a Federal closure reason. 
77 
Barriers in Closing Child Support Enforcement Cases  OEI-06-00-00471  PROVIDING ADVANCE NOTICE 
Clients are sometimes not provided notice of closure of their child support 
enforcement case due to lack of automated processes or human error 
State child support enforcement agency managers are largely aware of problems with providing 
notice, because deficiencies have previously been identified through monitoring and self-
assessment projects. Managers attribute notice problems to a lack of automation for generating 
notices and to human error. In one State, for example, staff reportedly use manual processes to 
bypass the automated document generating system designed to ensure that closure notice is 
provided. Where caseworkers must manually generate individual notices, managers report 
caseworkers sometimes take short cuts or skip notice altogether. Apparently, caseworkers 
sometimes think it is unnecessary to send notice when there is no longer a child support 
obligation, such as when the case has been paid in full, or when they assume a client already 
knows their case is being closed because of an obvious change in circumstances, such as when 
the child reaches the age of majority. 
Even when a written notice of child support enforcement case closure is mailed, 
notices may contain incomplete information and clients may not receive letters 
Based on content analysis of State case closure notices, we determined that clients need a 
minimum of six pieces of information to be fully aware of the agencys intended action and of 
the clients options in preventing an unwanted closure. 
Six pieces of information needed in advance notices 
1.  statement that the agency intends to close the case 
2.  specific closure reason 
3.  date of intended closure 
4.  procedures for requesting a case not be closed 
5.  contact name 
6.  contact telephone number 
Our analysis found that only the notices used in 4 of the 10 sample States provide clients with 
all of this information.  Notices used by the other 6 States omit important pieces of information, 
such as the closure reason, the date of closure, or how a client can request a case not be 
closed. We also found that notice letters used by one State contain inaccurate information 
about the length of the required waiting period before closure can occur. Two State closure 
notices provide all the necessary data plus additional information potentially useful to clients, 
such as a reminder that a case can be reopened at a later date or that clients may request that 
the agency close their case earlier than intended. 
88 
Barriers in Closing Child Support Enforcement Cases  OEI-06-00-00471  All 10 sample State child support enforcement agencies send closure notices via first-class mail. 
One State switched from certified to first-class mail following the 1999 Federal regulation 
revisions, a change that has reportedly eased the overall process of closure. However, some 
managers are pessimistic about using first-class mail because it does not ensure that the client 
actually receives the notice, whereas certified mail requires the signature of the recipient. It is a 
reportedly frequent occurrence that first-class mail closure notices are returned by the post 
office as undeliverable.  When this happens, staff sometimes take extra steps to inform a client 
of closure, such as attempting to obtain a new address through the Federal Parent Locator 
Service (FPLS), the postmaster, or the Internet.  However, managers report that staff 
sometimes simply view a returned notice as further indication that the case should be closed. 
CLOSING CASES 
When States have ineffective prompting systems, closure of child support 
enforcement cases may occur too early 
Once notice is provided to clients, agencies are required to ensure that no cases are closed 
before the 60-day notification period elapses.  Caseworkers without the assistance of 
automated systems for this function bear the entire burden of reminding themselves when the 
waiting period has passed. Rather than waiting 60 days, managers report that caseworkers 
sometimes choose to close a case on the same day as notice is sent, possibly because notice is 
not viewed as being needed under particular circumstances. However, caseworkers are often 
alerted that the waiting period has elapsed by automated systems that calculate 60 days from 
the date the notice is generated.  These automated prompts generally serve as effective 
reminders to complete the closure process, but they still sometimes contribute to early closure 
errors.  For example, managers from one State report that some caseworkers deliberately used 
their system to create early closure errors, because they believed that 60 days is too long to 
wait for closure. 
Coordinating with courts on closure of child support enforcement cases with 
existing orders can complicate closures for staff 
Once the notice period elapses, the steps of actually closing a case depend on the type of case. 
Examination of State child support enforcement agency case closure procedures in the 10 
sample States reveals that cases that still need paternity or order establishment are fairly simple 
to close.  Closing a case with no order may be as simple as changing a code in the automated 
system and moving a paper file to a different file cabinet. Additionally, electronic records are 
sometimes automatically updated once the notice period elapses, unless a caseworker takes 
steps to stop the automated closure process. 
Closing cases with existing support orders, however, often involves suspension of enforcement 
remedies, such as wage withholding, IRS intercept, and liens. Typically, all 
99 
Barriers in Closing Child Support Enforcement Cases  OEI-06-00-00471  enforcement measures must be ended in order for the case to be properly closed, and any 
remaining balances must also be removed from case records. For example, some closures 
involve the client forgiving money that is owed to them, and possibly the agency forgiving a 
small amount of arrears assigned to the State. Ending enforcement actions and clearing 
balances often require action by the courts, which is achieved through fairly routine procedures 
for gaining judicial approval of closures. 
Despite the existence of routine procedures, obtaining a court order can sometimes be difficult, 
and the child support enforcement agency and courts may disagree about whether a case 
should be closed. For example, one manager explains that their State agency routinely initiates 
closure when requested by a non-TANF client, but judges sometimes will not dismiss the order, 
because they think the noncustodial parent will not live up to independent payment 
arrangements. Closure is reportedly complicated in another State, because most child support 
enforcement clients have cases with both the county clerks of court and the State child support 
enforcement agency. Both of these cases must be closed to end all obligations, requiring 
coordination between agency staff and clerks of court. In another State, closure is reportedly 
sometimes delayed because the noncustodial parent must petition the courts to terminate an 
order. Managers in that State were considering a more simplified method at the time of our 
data collection, whereby State child support enforcement agency staff can directly petition the 
court for closure, when needed. 
PARTICULARLY CHALLENGING CASES 
Child support enforcement cases involving current and former TANF recipients, 
and those closed for reasons of client non-cooperation, lost contact, and client-
request, reportedly complicate closure 
Cases Involving Current and Former Recipients of TANF. Managers explain that staff 
tend to more aggressively close child support enforcement cases with non-cooperative clients, 
and that this aggressiveness may account for increased errors.  Public assistance recipients are 
required to cooperate with child support enforcement agencies by providing information about 
the noncustodial parent.  TANF recipients can be sanctioned, and adults can lose Medicaid 
coverage, for not cooperating with the child support enforcement agency.  Managers report 
that some public assistance clients refuse to cooperate, and simply accept a sanction. Staff 
reportedly find it frustrating that they must attempt enforcement in these cases without the 
benefit of cooperation. Managers report that this frustration may lead caseworkers, who see 
little likelihood of success without client cooperation, to close cases, even if they do not 
technically meet a closure reason. 
Non-Cooperation. Some cases appear to be closed for non-cooperation despite the State 
child support enforcement agency having sufficient information to allow automated location 
efforts. States can immediately initiate case closure if a client, who is not 
1100 
Barriers in Closing Child Support Enforcement Cases  OEI-06-00-00471  currently a TANF recipient, does not cooperate with the child support enforcement agency 
when that cooperation is necessary for continued enforcement. Clients can be considered non-
cooperative, if they fail to provide needed information, submit to genetic testing, appear in 
court, or keep appointments with caseworkers. It appears that in some cases closed for this 
reason, State child support enforcement agencies may have sufficient information to proceed, 
but can also document client non-cooperation.  For example, managers report that staff 
sometimes send clients, who are leaving the TANF program, a letter to request more 
information about the noncustodial parent.  If clients do not respond to these letters, perhaps 
because the clients have already provided all the information they know, staff reportedly 
sometimes immediately initiate closure for non-cooperation.  Some managers defend such 
closures because they believe that the 60-day advance notice is an effective tool for getting 
clients to provide more information. Other managers feel that while it is permissible to close 
such cases for non-cooperation, cases with sufficient information to allow automated location 
efforts should not be closed, unless they meet requirements for theunable to locate reason. 
Lost Contact. Regulations regarding lost contact with a client, who is not currently a TANF 
recipient, reportedly frustrate some child support enforcement staff. States can close cases, if 
the child support enforcement agency is unable to contact a non-TANF client for 60 days, after 
making at least one attempt to contact the client by first-class mail at the last known address. 
Managers explain that the 60-day notice period seems too long in lost contact cases, given that 
staff have already sent a letter requesting contact and waited an initial 60 days. Also, if the first 
letter was returned by the post office, it seems to staff a waste of time to send the closure notice 
to the same, apparently invalid, address. Managers report that staff may simply not wait the full 
time, closing the case at the same time the closure notice is sent following the first 60 days, or 
when the letter is returned by the post office. As mentioned, managers report that rather than 
simply assuming they had lost contact with a client when a notice is returned, staff often attempt 
to obtain a new address by searching automated databases, such as the FPLS. 
Client-Request. State child support enforcement agencies can immediately close a case upon 
receiving a request from a client who is not currently a TANF recipient, as long as no debts are 
owed to the State.  Managers report that staff sometimes aggressively close such cases, but it is 
not clear that all closures represent an actual client request.  An example of this involves the 
continuation of services notices sent to child support enforcement clients who leave the 
TANF program in one sample State.  These notices reportedly explain that parents may choose 
to continue receiving child support enforcement services, and require that parents return a form 
requesting continuation if closure is not wanted.  This State reportedly considers the clients 
failure to return the form as a clients request for closure.  Managers of child support 
enforcement agencies in other States report that their continuation of services notices provide 
custodial parents with a form to request closure, but they keep the case open if the parent does 
not respond. 
1111 
Barriers in Closing Child Support Enforcement Cases  OEI-06-00-00471  STRATEGIES FOR IMPROVING CASE CLOSURE PROCEDURES 
Child support enforcement agency managers in sample States reportedly stress 
to staff that only unworkable cases should be closed 
Despite a desire to close cases, managers in sample States appear to place great emphasis on 
ensuring that staff only close cases with no potential for successful enforcement. Managers 
stress their awareness that, except in cases where child support obligations have been paid in 
full, closure often means families will go without needed support. To guard against unwarranted 
closures, managers explain that closure is normally avoided until all other options have been 
exhausted.  As a result of efforts to guard against improper closures, managers report that most 
closures involve only cases that meet a closure reason. 
Reopening any child support enforcement cases closed in error is easy, because 
sample State agencies do not purge electronic records 
Managers in the 10 sample States suggest that staff concerned about client protection may be 
more comfortable closing cases that could eventually become enforceable, because they know 
the case can easily be reopened. Our examination of case closure documentation revealed that 
reopening a closed child support enforcement case is typically easy, because the previous 
electronic case record is readily available to caseworkers. Managers argue that while keeping 
information about closed cases takes up data storage space, having easy access to old records 
is preferable to beginning a new case.  However, in one county-administered State, new cases 
appear to be created frequently when a client seeks services in a different county, because local 
staff do not have access to the electronic records in other counties within the same State. This 
practice appears to unnecessarily cause caseworkers to repeat work previously accomplished 
by others. 
Sample State agencies train staff to follow proper case closure procedures 
Managers report that case closure training typically includes information on closure regulations 
and procedures, and using the automated system for closures. Such training may involve 
caseworkers practicing the closing of sample cases in training labs, with special attention paid to 
unusual circumstances. Additionally, workers may be provided with special guides or cheat 
sheets and supervisors often continue on-the-job training of workers in the local offices. 
Computer-based policy and procedure manuals also help instruct workers about how to 
perform each case function of the closure process. Despite these efforts, managers explain that 
ongoing training may be needed, because staff may not become proficient at every task until 
they have months of experience.  Additionally, managers emphasize that even the best training 
cannot compensate for staffing shortages and high turnover rates. 
1122 
Barriers in Closing Child Support Enforcement Cases  OEI-06-00-00471  State child support enforcement agency officials view monitoring as an effective 
means of improving case closure processes 
Managers of our 10 sample child support enforcement agencies are almost universally positive 
about monitoring tools, such as State self-assessments.  They credit monitoring with identifying 
problems in providing closure notices, inadequately documenting closures in automated 
systems, and use of incorrect State closure codes. Once problem areas are identified, States 
can work with local office staff to implement corrective action plans. To further assist local 
offices, one State reports exploring the possibility of an Internet-based review tool to allow 
local managers to routinely monitor their offices performance in case closures and other areas. 
1133 
Barriers in Closing Child Support Enforcement Cases  OEI-06-00-00471  OPPORTUNITIES FOR IMPROVEMENT 
Based on our analysis of the experience of these 10 States, we offer to the Administration for 
Children and Families (ACF) and State child support enforcement agencies the following steps, 
which could improve case closure processes. 
Develop a model advance closure notice for States to use as a template. Using such a 
model notice can help States to ensure that each client is provided with all the information 
needed about closure of their child support enforcement case, while still affording States the 
opportunity to customize notices, as needed. 
Provide technical assistance and encourage States to improve their case closure 
processes by States incorporation of the following strategies: 
<	 Simplifying State child support enforcement case closure codes by aligning them 
with the 12 Federal closure reasons. Complex coding schemes appear to confuse 
caseworkers, potentially leading to errors or inaccurate information in case files. Use of 
generic closure codes could be discouraged. 
<	 Automating State processes for identifying and closing cases. By using computer 
queries of existing caseloads, State agencies could identify and close more unworkable 
cases. Automation of closure procedures, including providing notice and closing cases 
after notice, could help State child support enforcement agencies substantially reduce 
errors, while still allowing for manual review when needed. 
<	 Performing routine monitoring of State child support enforcement case closure 
activities. Such monitoring could provide information about existing problems and early 
warnings of developing vulnerabilities.  Monitoring could also allow State child support 
enforcement agency managers to evaluate improvement strategies. 
<	 Targeting problematic child support enforcement case types and case closure 
reasons for further staff review. Staff review of every closure does not appear 
necessary. However, targeted review could help State child support enforcement 
agencies to ensure that cases, involving current and former recipients of TANF and 
cases closed for problematic reasons, are handled properly. 
1144 
Barriers in Closing Child Support Enforcement Cases  OEI-06-00-00471  <	 Training local State child support enforcement staff to avert troublesome 
procedural variation and to ensure that clients receive advance notice of closure. 
Training elements likely to be most valuable to staff include information on Federal child 
support enforcement case closure regulations, State coding schemes, closure 
procedures, documentation of closure activities, and the importance of providing 
advance notice to clients in all cases where notice is required. 
1155 
Barriers in Closing Child Support Enforcement Cases  OEI-06-00-00471  ENDNOTES

1. OCSE, Action Transmittal 89-15, August 4, 1989.

2. 64 Federal Register, 11810-11818, March 10, 1999.

3. Ibid., page 11811.

4. 64 Federal Register, 55073 - 55102, October 8, 1999.

5. Ibid., pages 55102 - 55110. Federal audit requirements were changed to focus on data reliability

and to assess performance outcomes instead of determining compliance with process steps (p. 55103).



6. 45 CFR  308.1(e).

7. 45 CFR  308.2(a).

8. At the time of our study, State child support enforcement agencies had not yet standardized their

self-assessment methodologies enough for comparison across States.

9. Hawaii and Alaska were excluded from the sample frame because of the high cost of travel to those

States.

10. OCSE often targets technical assistance and evaluation efforts toward these Big 8 States because

their practices affect so many families.  New Jersey was added to OCSEs large State initiative, now

called Big 8 + 1, subsequent to our sample selection for this study.

11. OCSE, Dear Colleague Letter 97-26, May 19, 1997.

12. 1999 is the last year for which OCSE has published data on total child support enforcement

caseloads.

1166 
Barriers in Closing Child Support Enforcement Cases  OEI-06-00-00471  A C K N O W L E D G M E N T S  
This report was prepared under the direction of Judith V. Tyler, Regional Inspector General for 
Evaluation and Inspections in Dallas. Other principal Office of Evaluation and Inspections staff who 
contributed include: 
A. Blaine Collins, Team Leader  Linda Hall, Program Specialist 
Ruth Ann Dorrill, Program Analyst  Joan Richardson, Program Specialist 
Amy Ashcraft, Program Analyst  Barbara Tedesco, Mathematical Statistician 
Clark Thomas, Program Analyst 
Scott Whitaker, Program Analyst 
Lisa White, Administrative Officer 
1177 
Barriers in Closing Child Support Enforcement Cases  OEI-06-00-00471