. .
Department of Health and Human Servces 
OFFICE OF  GENERA 
INSPECTOR 
CHILD SUPPORT FOR CHILDREN IN IV
FOSTER CARE 
Richard P. Kusserow 
INSPECfOR GENERA 
MAY 199  . .
. '
l '

GEN 
li;:!.I  'lm 
OFFCE OF INSPECfOR 
The miion of the Offce of Inpetor General (OIG), as mandate by Public Law 95-452, as 
' (HS) . 
amended, is to protect the integrty of the Department of Health and Human ServceTh. 
programs as well as the health and welfare of beneficiaries served by those program. 
statutory miion is carred out through a nationwide network of audits, investigations, and 
, the 
inpections conducted by three OIG operating components: the Offce of Audit Servce
The OIG also inorm 
Offce of Investigations, and the Offce of Evaluation and Inpections. 
recmmends courses to 
the Secretary of HHS of program, ' and management problems, and 
correct them. 
OFFCE OF AUDIT SERVICE 
The OIG's Offce of Audit Servce (OAS) provides all auditing servce for HHS, either by 
conducting audits with its own audit resource or by overseeing audit work done by others. . 
Audits examine the performance of HHS programs and/or its grantee and contractors in 
independent 
carrg out 
their respetive responsibilties and are intended to provide 
, abuse, and 
and operations in order to reduce waste
asesments of HHS programs 
mismanagement and to promote ecnomy and effciency throughout the Department. 
INGATIONS 
OFFCE OF 
, civil, and admitrative. 
The OIG's Offce of Investigations (01) conducts criminal
investigations of allegations of wrongdoing in HHS programs or to HHSc breinaeflic iaries and of 
01 lead to  convictions, 
unjust enrchment by providers. The investigative effort of 
civ money penalties. The 01 also oversee State Medicaid fraud 
administrative sanctions, or 
control units which investigate and prosecute fraud and patient abuse in the Medicaid program. 
AN 
INSPECTONS 
OFFCE OF EVALUATION 
term management and 
The OIG's Offce of Evaluation and Inpections (OEI) conducts short-
the Departent, 
program evaluations (called' inspections) that focus on isues of concern to 
contained in these inpection 
the Congres, and the public. The fidings and recmmendations 
, accurate, and up-to-date information on the effciency, wlnerabilty, 
report generate rapid
and effectivenes of departmental programs.

OEI's Atlanta Regional Offce staff prepared thi report under the direction of Jese 
Inpetor 
Flowers, Regional Inpector General and Chrstopher Koehler, Deputy Regional 
General. Pricipal OEI staff included: 
Heaquars 
Atlanta Region 
Susan Hardwick 
Ron Kali, Project Leader 
Penny Thompson 
Maureen Witce, Lead Analyst  Krhat
Wm. Mark 
Paula Bowker 
Jean Dufresne  + .
"" 
Department of Health and Human Servces 
OFFICE OF 
GENERA 
INSPECTOR 
CHILD SUPPORT FOR CHILDREN IN IV
FOSTER CARE 
"'''c.. 
Richard P. 
Kusserow 
OEI-091-O530  EXECUTIVE  SUMMARY 
PUR 
To determine the extent States collected child support from biological parents of 
chidren in Title IV-E funded foster care as required by the 1984 Chid Support 
Amendment Act. 
BACKGROUN 
Foster care is temporary removal of a chitd to live with someone other than a parent 
durig a time of crisis. Title IV-E Foster Care applies only to children who are or 
would be eligible for assistance from the Aid to Families with Dependent Children
(AFC) 
program if they were stil in the home of their birth parents. In Fiscal Year 
(FY) 1986 there were an estimated 110,749 children in IV-E Foster Care. By FY 1990 
the number had swelled to an estimated 173 152, representing a 56 percent increase in 
the 4-year period. 
The 1984 Child Support Amendment Act required State Title IV-D Child Support 
agencies to collect chid support from biologica parents on behalf of chidren receivig 
foster care maintenance payments under Title IV-E Foster Care ''where appropriate. 
MEODOLOY 
In conducting the study, we randomly selected eight States. Within each State, we 
selected 40 cases of children who were receivig IV-E Foster Care funds for a total of 
320 cases. We also intervewed State and local administrators of foster care and chid 
support programs. We conducted our review between February and May 1991. 
FIINGS 
Few chid support collecons are made on behal of Foster Cae chidren 
Collections are being made on behalf of 5.9 percent of foster care children in our 
sample. 
Few foster cae caes are referred to Chd Support agencies for possible collecons 
lV-D Child Support records exist on just 22 percent of parents of sampled IV-
Foster Care children. No records existed at IV-D Child Support agencies for 78 
E Foster Care. 
percent of the parents of children in lV- Empha on collecg chid 
support is low 
Policies are vague for when to intiate 
collections. Coordination between IV-
E Foster
Care and IV-D Chd Support agencies is lited. 
Efece referr 
by Foster Cae agencies to Chd Support agencies improve succ
in collecg chid support 
Chid support collections are low 
natiQnally, but a few localities have developed
effective referral practices resulting in collections on behalf of 48 percent of IV-
Foster Care children. 
REMMATIONS 
Recmmendation 1. As a 
condition of receivig Federal matching funds for foster
care admistration under Title IV-
, the Administration for Children and Familes
(ACF) should require States to develop and implement: 
criteria and procedures to assure that Foster Care agencies refer all 
appropriate IV-E Foster Care cases to IV-D Chid Support Enforcement
agencies for establishing child support orders and collecting chid support; and 
Memorandum of Understanding between IV-
E Foster Care agencies and
IV-D Child Support agencies with respect to 
determinig "appropriate" cases
for referral, and gathering and exchanging data. 
Recmmendation 2. In support of 
such State initiatives, ACF should provide guidance
and plans for coordination between the IV-
E Foster Care and IV-D Child Support
Enforcement agencies. 
Implementation of these recommendations wil improve the well being of foster care 
children. They can lead to 
establishing paternity and locating absent parents
, as well
as establishing support orders with both cash and medical benefits for the chid. 
Ths
may encourage some parents to become more responsible for their chidren --
consistent with the Secretary 
s theme of "personal responsibility. 
Initiatives by ACF could substantially increase child support collections from biological 
parents of IV-E Foster Care children. It is not possible to calculate with great
precision how much additional savings would accrue. However
, we conservatively
estimate up to 74 milion dollars could have been collected 
in FY 1990. Additionally,
the amount will increase each year as the number of children in IV-
E Foster Care
rises. Such collections wil offset Federal and State tax dollars spent for care and 
maintenance of IV-E Foster Care children. Federal and State 
governments could
achieve additional savings by requiring parental medical support of their children
, thus
offsetting expenditures on Medicaid.  Recmmendation 3. The ACF should ensure that the Federal share of chid support
dollars collcted on behalf of IV-
E Foster Care chidren is correctly distnouted to the
IV-E Foster Cae program rather than the IV-
A AFDC program. 
COMM 
The ACF agreed with our recommendations and has intiated steps to improve 
coordination between child support and foster care agencies. The ACF has also 
initiated steps to remedy inappropriate distribution of child support dollars. Likewise 
the Assistant Secretary for Management and Budget (ASMB) concurred with our 
recommendations on both programmatic and financial grounds. 
The Assistant Secretary for Plannig and Evaluation 
(ASPE) agreed that more could
be done to coordinate the provision of IV-
D Child Support for IV-
E Foster Care.
The ASPE noted that better communication and 
coordination is needed and should be 
encouraged, but que tioned the extent that child support can or should be pursued. 
We agree that child support should only be pursued in "
appropriate" cases. However
we continue to believe that the majority of children in foster care can benefit from 
IV-D Child Support servces, such as paternity establishment and locating absent
parents. We hope our report increases the awareness of a need to integrate these
servces. Many of the issues and problems cited by ASPE will be solved as States gain 
more experience in collecting child support on behalf of foster care children. The 
effective practice" sites which we examined demonstrate that this can happen. 
We thank ACF, ASMB and ASPE who commented on the report. We present the 
full text of comments in appendix E. 
iij  . . . . . . . . . . . . . ..  ..  ..  ..  ....    ....    .....     ......     . .... ..  ..   ..   .  ..... ..   . " .."."..  .   .   
..  ..  ..  ..  ..  ...   ...   ...   ...   ...   ...   ...   ...   ...   ...   ...   ...   ...   ...   ...   ...   ...   ...   ...   ...   ...   ...   ...   ...   ...   ...   ...   ...   ...   ...   ..  ..  ..  ..  ..  . . .. 
TABLE OF 
CONTENTS 
EXCU SUMy 
INODUCTON. . 
FIINGS. . 
Few Child Support Collections Are Made 
On Behalf Of Foster Care Children. . . . . . . . . . . . . . . . . . 
Few Foster Care Cases Are Referred To

Child Support Agencies For Possib1e Collections

Emphasis On Collecting Child Support Is Low . . . . . . . . . 
Effective Referrals Improve Success In 
Collecting Child Support. . . . . 
RE(X 
A110NS 
.................................... 12

Discussion. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
Agency Comments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
ENNOTE. . 
APPENICE 
A: Title IV-E Foster Care Process. . . . . . . . . . . . . . . . . . . . . . .. A
B: Information Collection Methods. . . . . . . . . . . . . . . . . . . . . . .. B
C: Description Of "
Effective Practice" Sites 
. . . . . . . . . . . . . . . " C
D: Projected Child Support Collections 
. . . . . . . . . . . . . . . . . . " D
E: Comments on Draft Report 
. . . . . . . . . . . . . . . . . . . . . . . . .. E- INTRODUCTION

PUROS 
To determne the extent States 
collected child support from biological parents of
children in Title IV-
E funded foster care as required by the 1984 Chid Support
Amendment Act. 
BACKGROUN 
Title IV-E Foster Cae 
Foster care is the temporary removal of a child to live with 
someone other than a
parent (or usual caretaker) during a time of 
crisis. The crisis may be caused by abuse
or neglect of the child. 
The Adoption Assistance and Child Welfare Act of 
1980 transferred admiistration of 
the Foster Care program for children from the 
to Families with Dependent
Children (AFDC) program (Title IV- Aid 
A of the Social Security Act) to the new Title
IV-E Foster Care program. Title IV-
E Foster Care applies only to chidren who are
or would be eligible for AFDC if they were stil in the home of their birth parents. 
Servces provided by the IV-
E Foster Care agencies are shown below. 
ACT 
E FOST CAR 
IV-
o Make Reaonable Efort to 
Prevent Remov 
o IT Unsuccful, 
Remove Chd from an Unse Home 
a Place Chd in 
Appropriate Foster Cae 
o Determe Eligibilty for IV-
o Refer Parent(s) and Chd to Servce 
o Plan for the 
Long Term Welfare of Chd 
In Fiscal Year (FY) 1986
, an estimated 110 749 children were in IV-
FY 1990 the number had swelled to an estimated 173  E Foster Care. By
152, representing a 56 percent
increase in 4 years. .  Title IV-D Chd 
Support Enorcement 
The Chid Support Act of 
1975 added Title IV-D to the Social Security Act. The goals
of Title IV-
D are to ensure that parents support their children to the extent possible 
family (parental) responsibilty increases
, and the cost of welfare to taxayers
decreases. The Act established child support enforcement 
agencies to help in
obtaining support orders and to collect child support monies to reduce Federal public 
assistance expenditures. Servces provided by the IV-
D Child Support agencies are
shown below. 
CH 
IV- SUPPORT SERVICE 
Lote 
Parents 
Establih Paternty 
Establih a Support Order 
Receive and Distribute Collecons 
Establihig Chd Support Collecons for Foster Cae Chdren 
Section 11 of the 1984 Child Support Amendment Act required States to secure and 
enforce child support collections on behalf of children receiving foster care 
maintenance payments under IV-
E Foster Care ' 
'where appropriate. 
The 1984 amendment required States to follow the same procedures for securing and 
enforcing support orders for appropriate children under IV-
E Foster Care as they do
for AFDC children. In January of 1985
, States were required to amend their Title
IV-E State Plans to insure cooperative efforts with child support 
agencies. 
The IV-D Child Support agencies are responsible for collecting and distributing 
payments from absent parents. An "
absent parent
" is a biological parent not residing
in the same home as a child.  Unle most chidren in the AFC 
program
who traditionally have one absent parent, 
chidren in IV-
E Foster Care have two absent 
biological parents and may receive IV-
Child Support collections from both.  Foster Care Children 
Have Two Absent Parents 
We found, based on our case record review 
that IV-E Foster Care children need chid 
support servces. These chidren are young. 
More than two-thirds (67 percent) are under
10 years of age. Although foster care is 
Foster Care  Child 
intended to be "temporary" removal from the
home, more than three-
quarters of the IV-
Foster Care children have been in foster care 
for more than a year. Ten percent of the 
children have been in foster care for over five 
years.  Biological  Biological
Father 
Mother 
Appendix A provides more detailed 
information about the process of placing a 
child in IV-E Foster Care and how the child 
is linked to IV-
D Child Support servces. 
dmini terig the Chd 
Support and Foster Cae Progr 
At the Federal level
, HHS operates both programs within the newly-created
Administration for Children and Famies (ACF). 
Care program is located in the Administration for CWhiitlhdirne nA CF, the Title IV-E Foster
(ACYF), and the Title IV- , Youth and Famiies
D Chid Support Enforcement program is in the Offce of
Child Support Enforcement (OCSE). 
Each State is responsible for establishing and operating the IV
IV-D Child Support programs under  E Foster Care and
provisions of Federal statutes and HHS
regulations. 
MEODOLOY 
We randomly selected eight States with probabilty proportional to size. The average 
number of children in the IV-
E Foster Care program in FY 1989 determned 
The eight States represent approximately 64 percent of children in IV siz.
in FY 1989. The eight States were: California E Foster Care
Kentucky, Michigan and Pennsylvania. We co,n Nduecwte Ydo orukr,  Mreivnineews obteat,w Aeerno Fneab,r uilianroy is
and May 1991.  With 
each State, we selected 40 caes of children who were receivig IV-
Care funds at the time of our review  E Foster
, for a total of 320 caes. We 
for each case at both the foster care agencies and IV  reviewed records
D Chd 
Support agencies. 
Using a standardized discussion gude
, we intervewed local and State foster care and
child support program representatives to gather facts and data. We also intervewed 
the Federal Regional Offce IV-
representing States in the sampleE.  Foster Care and IV-D Child Support staff
Appendix B describes information collection 

in further detail. 
methods  FINDINGS 
CH 
CHRE 
FEW 
SUPPORT COlLONS AR MAE 
CAR  BEH 
ON 
OF
Collecons Were Made On Behal Of 5. 
Saple  9 Percent Of Foster Cae 
Chdren In Ou 
A case review tracing the biological parents of the sampled children in IV-
Care revealed very few pay child support. Only 19 of the 320 children sampled had
E Foster
any child support colJections made on their behalf. 
On 11.6 Percent Of Sampled 
Chdren In Foster Cae Were 
Support Order 
Included In A Chd
A child support order must be established to 
IV-E Foster Care children. Yet very few childcolJect child support from parents of 
Foster Care children. Only 37 of the 320 samplesdu pcphoritl dorredne rwse raer ei necsltuadbeldi sihne da nfo
 r IV-
established child support order. 
RE 
FEW FOST CAR 
CASES AR  CH 
AGENQE FOR  TO 
POSSmLE COLLCTONS  SUPPORT
No Recrds Exted At Chd 
Support Agencies For 78 Percent Of The Parents Of
Chdren In IV-
E Foster Cae 
Records existed at IV-
D Child Support agencies on just 22 percent of parents of
sampled IV-E Foster Care children. I The majority of the sampled children in Foster
Care lived with one or both of their parents before they were placed in foster care. 
Further, most have permanency plans to return the children to the home of their
parent(s). Yet
, few foster care agencies have effective policies or procedures to refer 
cases to a IV-D Child Support agency. 
Referr Are Crtica To Intiate The Chd 
Support Collecon Proc 
When the IV-D Child Support agencies we visited receive a referral 
provide all servces to IV-
, they tyically
E Foster Care cases. Yet
the clear majority of sampled children in IV  , because referrals are not made
E Foster Care are being deprived the
opportunity to receive IV-
D Chid Support servces they are entitled to receive.  For IV-E Foster Care children not referred
, IV-D Chid Support agencies cannot 
&tablih paternty 
without legally-established paternty, a 

ineritance rights or  chid cannot obtain
insurance rights. Also possibly vital information regarding
genetically-
lined medical problems wi not be 
known. 
Lote 
the absnt parent: without the 
cannot form social relationships with thaeb speanrte npat(rse)n.t (s) being located, the chid
parent or a close relative of an absent parent may beI na bsloem toe  acsassuems aen c aubsstoednyt  of 
the foster care child. 
&tablih a 
support order and collec chid support payments: when certain
criteria are met
, administering agencies may save portions of chid
payments collected from the parents for a child. The child support spuapypmoretnts from
parents may also be used to provide amenities such as clothing or enrollment in a 
class for a child while in foster care. The support order and established 
pattern may continue after a child 
collection
leaves IV-E Foster Care.

EMHAIS ON COLLCTG CH 
SUPPORT IS LOW 
Policies For When To Intiate 
Collecons Are Vague

Federal policies place no emphasis or focus on collectig child support for Foster Care 
children 
Until an April 1991 reorganition of HHS
Support programs were operated by two se,p tahrea tIeV -E Foster Care and IV-
D Child
divisions. The Offce of Human
Development Servces (OHDS) administered the IV 
Family Support Administration (FSA) administered thEe  FIoVster Care program and the
No one was directly responsible for insuring coordination beDtw Ceheinl db oStuhp pproorgt rparmogs.r am.
Although extensive Federal guidance requires the IV
regularly update cases to IV- A AFDC program to refer and
D Child Support agencies
OHDS and FSA concernig child support  , the only action issued from
collections on behalf of IV-
children was a "Memorandum of Understanding E Foster Care
" signed in May of 
memorandum only established procedures for reporting dollar amou1n9t8s6 o. fT choellections 
between OHDS and FSA. 
Within OHDS and FSA regional offces isolated 
initiatives have occurred since 1986 to
increase reported collections on behalf of IV-
E Foster Care children. However
uniform national strategy addresses this issue. 
, no 
The separation of the IV-
E Foster Care and IV-
D Child Support at the Federal level
is mirrored at State and local levels. In virtually every 
analysis, the two programs were administratively isolateSd tfarotem o er accohu nottyh einrc. luded in our , '
The only strong Federal focus is on compliance in reporting. Therefore 
collections on behalf of IV- , chid support
E Foster Care chidren is often little more than a 
bookkeeping function. 
Criteria concerning "
where appropriate
" are inadequate or non-
extent 
No Federal directive defines '
'where appropriate " yet the law uses the phrase to lit
conditions or circumstances where child support should be pursued. Only one State 
policy uses the term. This State policy 
are referred. Seven of the eight  defies "appropriate" so broadly that no cases
States have no wrtten criteria as to when chid
support should or should not be pursued. Without criteria 
little meaning to program staff.  'where appropriate" has 
Cordiation Between Foster Cae And Chd 
Support Agencies Is Lited 
Mission and roles are not clearly understood or accepted 
Few staff within IV-
E Foster Care and IV-
D Child Support agencies had a clear
understanding of their role in interrelating their different programs
servces can complement each other. The agencies  , or how their
regular meetings.  hold no formal cross trainng or
The focus and approach of IV-
E Foster Care and IV-D Child Support agencies varied
considerably. Foster care staff are oriented to and talk in terms of an individual chid. 
They form interpersonal relationships with the familes they serve. On the other hand
most IV-D Child Support staff view themselves as adversaries of "
The child support staff tend to be " absent parents.
bottom line oriented. 
Some foster care workers regard 
gatherig information for a referral to IV-
Support agencies as "paper pushing, D Chid
opinions that families of IV- " or as "not my job." These workers expressed
E Foster Care children are "
too poor to pay.
unaware of the range of servces IV-
" They are
D Child Support agencies can provide. Further
they are unaware of or underestimate the ability that Child Support 
demonstrated for collecting money in economically-similar AFDC  agencies have 
cases. 
Some foster care workers philosophically oppose pursuing child support. Some dread
an unpleasant confontation with the parent(s). Others 
child support wil be  may believe that enforcing
detriental to the 
parent!child relationship. They do not believe
that child support serves to stabilize the family unit and help insure its future integrty. 
Infonnalion is not shared or exchanged 
If a case is not referred to the IV-
D Child Support agency, and IV-
workers need to establish paternity or locate an absent parent(s) theEy  Fmousstet rd Co athreis 
themse)ves. Foster care workers are not trained in this work nor are they given 
to the information resources of IV- access 
D Child Support agencies.  .--
When a referral is made by a IV-
E Foster Care agency, inormation necessary for
pursuig chid support is seldom given. To begi the 
support a IV-D Chd  process of obtaing chid
Support agency must obtain tiely, accurate
inormation concernng the family. The inormation , and complete
, such as social security numbers
or employment information
, is often available in IV-
E Foster Care fies
by foster care workers , or is known
, but it is not shared in the referral. As a result, IV-
Support staff must gather inormation that a IV- D Chid
E Foster Care agency already has.
Although foster care workers track a family 
s status, few foster care workers
understand the importance of communicating status 
changes to a IV-D Chid Support
agency. For example
, as part of the servce to a family, a foster care worker might
learn that a previously incarcerated father has been released and become employed. 
Without the IV-
E Foster Care worker promptly 
inormng the IV-
agency, the IV- D Child Support
D agency must learn this critical information independently. Likewise
IV-D Child Support workers may obtain information on the family that foster care 
workers need. 
Almost 60 percent of the cases we reviewed had discrepancies between the two 
agencies' files. Some discrepancies were as uncomplicated as a current address. 
Others had more serious ramifcations. For example
, one IV-
stated the father was " E Foster Care cae fie
unknown.
" The IV-D Child Support
identifed the father and had an open case on  ' agency, however, had
him. In another case
Care case file stated the father was " , the IV-E Foster
unkown" and all parental rights involuntariy
termnated. The IV-
D Child Support agency, on the other hand
father and was on the brink of servng the man with a court orde, rh faodr  icdheilndt isfuepdp tohret 
payments. 
Such lack of communication and sharing of information may cause problems with the 
therapeutic relationship a social worker is building with a family. In one case 
parent and foster care worker established suffcient trust to allow a child to re,t uthren
home. However, at about the same time
, a IV-D Child Support agent served a
summons to bring the parent to court. The parent 
damaged the reunification process.  s anger at the "government Nineteen percent of the total child suppon dollars collected in our sample for Foster Care 
chilen were mistakenly distruted to the 
AFDC program 
Of the $22 524 collected in the. year prior to our review on behalf of the sampled IV-
Foster Care children
, $4 260 (19 percent) was not distributed to the IV-
agency to offset maintenance payments for the children.  E Foster Care
Many of the sampled children in IV-
E Foster Care were included in active AFDC 
grants before the time of removal from their home to a foster care placement. In 
some instances, AFDC agencies made a referral for IV-
D Chid Support servces whie
a chid was stil at home. In 
such instances, IV-D Child Support agencies had the case
classifed as an "AFDC case." In some localities
, communications were so ineffective
that the Child Support agency 
was not notified when a child was removed from an
AFDC grant and placed in IV-
E Foster Care. 
No one had "reclassified" 15 of the 640 cases (2.3 percent) for parents of 
our sample. These 15  chidren in
cases were classified as IV-
A AFDC cases rather than IV-
Foster Care cases at the IV-
D Child Support agencies. One State had no system to
notif the IV-D Child Support agency when an AFDC child enters IV
In other places, inadequate systems allowed cases to slip through improEp Feorlsyt ecrl aCssairfee.d.
In these situations any child support collections made on behalf of IV-
chidren were mistakenly distributed to the IV- E Foster Care
A AFC 
were used to offset Federal and State IV- program. These collections
A AFDC assistance payments rather than
IV-E Foster Care maintenance payments. 
EFCT REFE 
IMROVE SUCC  COlLCTG
IN 
SUPPORT 
Within our national review, a few IV-D Child Support programs dilgently pursue both
parents of aIJ cases received. Yet these programs are limited by 
few referrals being
made or the sketchy information provided in the referrals. IV-
D Child Support
agencies sometimes pursued cases of parents of children in IV-
E Foster Care without
the knowledge of the IV"E agency. 
While collections are low nationally, we found a few localities exceed the national 
average making collections on behalf of IV-
E Foster Care children. These programs
have demonstrated the abilty to 
refer most parents of IV-
E Foster Care children to a IV-
D Child Support agency, 
establish more support orders
, and 
collect more child support on behalf of rV-
E children. , "

Although such localities were outside the scope of our sample 
viewed as "effectve practce , we visited two that we
County, Miesota.2 These c" osuintetsi e-s Lhaanvcea ttaekre nC otuhnet iyn,t iaPteinvnes tyol vdaenvae laonpd  pOrolmgsratmeasd for 
effectively referrng cases and utilg 
foster care workers to collect and exchange
necessary inormation to pursue chid support. In these 
received chid support collections on behalf of 48 percenct oouf ncthieilsd rIeVn-.E Foster Care
Based on a case record review
, the following chart compares national performance
averages to the performance average found at the " 
effective practice
" sites. 
IV-D Child Support For 
Foer 
IV - E 
Care Children 
Ca88 For Mothers 
70%  Ca$88 For Fahers 
70% 
80% 
&8% 
80% 
50% 
50% 
40%  38%  42% 
35% 40% 
30% 
30% 
1&% 
1:%  20% 
10% 
Supprt Colle 
Ion.  Ro",. 
Order.  Support CoI18.tlono
81 IV.O  Orer. 
Naiona Iwr8Q8 
B8t PraclcAlrag. 
As the chart shows  effective practice
" sites consider a higher percentage of both
mothers and fathers able to support their children. Although " 
refer just under twce the percentage of cases to the IV- effective practice
" sites
our national sample D agency as did the sites in
, they issue orders on five times as many mothers and almost four
times as many fathers. The "
effective practice" sites also collect on a higher ratio of
support orders when compared to our national sample.  We attributed the signcat 
priciples,  collections at the "effective practice" sites to the followig
Considerig Chd Support 
a Priority

Havig Efece 
Pattern of Communcation 
Progr  Between IV-E and IV-
Being More Awae of Both Biologica 
Parents' Income Source 
Havig One 
Person or Ofce to Cordiate IV-E Foster Cae Referr 
Including Medca Support in More Support Orders 
Reportg 
Collecons to the IV-
E Foster Cae Agency 
Appendix C highlights program operations in Lancaster and Olmstead counties. 
A recent study completed by the Region II ACF also 
shows a high level of collections
is possible. The study examined child support collections for children in IV-
Care in New York City. The study  E Foster 
showed many of the same problems we 
encountered concernng the agencies
' failure to exchange important inormation and
inadequate policies concernng referrals. Over 70 percent of referrals to New York
City' s Child Support agency had "
incomplete data and/or documents 
percent had "inconsistent or conflcting data.  " and almost 20
The ACF study showed
, despite the problems, 42 percent of the cases opened at the
IV-D Child Support agency had active support orders. Of these 
, 62 percent were
receivig monthly collections. Of the non-
payig cases 80 
percent had a tax offset
made in the past year
, so at least some money was collected. Many of the cases
without active support orders were improperly referred or contained outdated 
information.  RECOMMENDATIONS 
Recmmendation #1 
As a condition of receiving Federal matching funds for Foster Care administration 
under Title IV- , ACF should require States to develop and implement: 
criteria and procedures to assure that Foster Care agencies refer all appropriate 
IV-E Foster Care caes to IV-
D Child Support Enforcement agencies for
establishing child support orders and collecting child support; and 
a Memorandum of Understanding between IV-
E Foster Care agencies and IV-
Child Support Enforcement agencies with respect to determning "
appropriate
cases for referral
, and gathering and exchanging data. 
Recmmendation #2 
In support of such State initiatives
, ACF should provide guidance and plans for 
coordinating the IV-E Foster Care and IV-D Child Support Enforcement programs.
ACF could: 
Develop training and technical assistance modules to assist States in implementing 
new policies and procedures on child support for children in IV-
E Foster Care. 
Publish a compendium periodically of the techniques used by successful States in 
increasing their collections. 
Publish periodic report showing statistics nationally and by State on the IV-
Foster Care and lV-
D Child Support initiative. 
- Direct regional offces of ACF to monitor States in their region using performance 
standards and monitoring mechanisms. 
As discussed below, we believe these first two recommendations will increase: the 
number of support orders; the number of collections; the 
average amount collected
per case; and the number of children receiving medical support. 
Recmmendation #3 
The ACF should ensure that the Federal share of child support dollars collected on 
behalf of IV-E Foster Care children is correctly distributed to the IV-
E Foster care
program rather than the IV-A AFDC program.  DISCUSSION 
We found few foster care caes are referred for chid support servces. When referrals 
are not made
, the clear majority of sampled foster care children are being deprived of
an opportnity to 
receive servces they are entitled to receive. IV
servces can be beneficial to a child. For example 
D Chid Support
child can obtain inheritance rights or insurance rig,h wtsh. eCnh piladt esrunpitpyo irst  aegsteanbcliisehs ed a
location procedures can assist foster care agencies in dilgently searching for absent 
parents. When an absent parent is located 
appropriate social relationships with the pa,r ae nfto. sItne rs ocamree  ccahsides m  ay be able to fonn
close relative of an absent parent may be able to assume custody of a foster care
an absent parent or
child. When a support order is 
established and child support collections are being
made, administerig 
agencies may, when certain conditions are met, use a
the payments to provide amenities for a child while in foster care. 
portion of
may also provide important medical insurance for a child. 
The support order 
When parents cooperate with child support agencies and assume fiancial 
responsibilty for their chid while in foster care 
building parental responsibility. 
it  can be an  important  step toward 
A Federal effort is needed to insure that child support servces are provided to benefit 
children in IV
E Foster Care and to increase 
Such action clearly responds to the Secretary  support collections on their behalf. 
child 
responsibilty toward their children and the community byre mgaarkdiinngg parental
initiative 
for their chidren 
s financial support. The recent HHS reorganiztipoanr einnttes grreastpinognsible
OHDS (responsible for the Title IV-
the Title IV- E Foster Care program) and FSA (responsible for
D Child Support program) into the Administration for Children and
Famies provides 
an opportunity to improve the management of IV-
for children in IV- DChid 
E Foster Care.  Support 
Based on Our representative sample
, we believe a Federal initiative could increase
IV-D Child Support collections on behalf of IV 
tax dollars spent for care and maintenance of IVE  Foster Care children thus offsetting
possible to calculate with great precision how mucEh  aFdodsitteior nCala rsea vcihniglsd rweonu. lIdt  iasc cnroute. 
The final result 
wi depend on many 
factors including 
- the number of children in IV-
E Foster Care 
- the percentage of support orders issued on behalf of IV 
E Foster Care children 
- the amount of support ordered 
- the amount actually collected
, and 
- the administrative cost of collecting 
support. 
child  However, we believe our proposals would increase the number of support orders and 
the number and amount of collectons. The simplifed ilustration below 
shows
possible estimated collectons if the percentage of children for whom collections are
made were increased to various levels.
Posible Collecons at Varous Rates 
(in millions)

Percent Of Chldren 
Year 
Net Federal
 Estimated 
For Whom Collections 
Collections  Share of  Federal 
Are Made 
(FY 1990)
 Collections  Savigs 
$15  $4.  $2. 
$30  $9.  $4. 
$45  $13.  $6. 
$60  $18.  $9. 
$74  $22.  $11. 
(Appendix D provides details concernng these estimated collections. 
We believe our estimate of possible collections 
is conservative. The estimate supposes
only 29 percent of all child support money ordered will be collected. In our "
practice" sites, 80 percent of the money parents are ordered to pay is collecteedff. eActive
study of recent IV-
E Foster Care referrals for child support enforcement in New York 
City showed over 60 percent of the open cases had current support payments. 
Also, Federal and State governments could achieve additional savigs by 
requirig
biological parents of IV-
E Foster Care chidren to provide medical support thereby
offsetting Medicaid expenditures. The average Medicaid costs per chid in 1990 
4 We found that in the two "  were
$811 per year.
effective practice
" sites 42 percent of the
children received medical support from a parent
, covering some of the costs. Ths
practice could be applied in other States and counties resulting 
in substantial savigs
nationally. 
Additionally, children who are removed from IV-
E Foster Care to the custody of
absent parents or their families represent Federal and State savings to the IV-
E Foster
Care program and a major benefit to a child. 
Further, 19 percent of the total child support dollars collected for our sampled IV-
Foster Care children was erroneously distributed to the IV-
A AFDC program instead
of the IV-
E program. A one-time correction of the "
misclassification" would transfer
an additional $2.5 milion to the IV-
E program. (See appendix D for 
details regarding
this estimated transfer.) -._  ..-.- -
COMM 
AGENCY 
We thank the Admstration for Chdren 
and Familes (ACF), the Assistant Secretary
for Management and Budget (ASMB) and the Assistant Secretary for Plannng and 
Evaluation (ASPE) who commented on the draft report. 
responses are summarized below. Appendix E shows the fTuhlle tier xcto omf mtheen ctso manmd eonutrs 
provided by ACF
, ASMB and ASPE. 
ACF Comments 
The Admiistration for Chidren and 
Families (ACF) agreed with our
recommendations to improve coordination between the child support and foster care 
programs. The ACF plans
, through its regional offces
, to examine the status of
coordination systems in each State. The 
ACF will include the issue of coordination in
its Joint Planning Guidance to be issued in fiscal year 
1992. The ACF has also
included the issue as part of their 1992 strategic 
Support Enforcement (OCSE) and the Administrpaltaion.n  fFourr Cthheirld, rtehne Offce of Chid
Families have already begun a joint initiative to improve coordinati,o Yn.o uth and
OCSE audits will more closely monitor the distribution of child support cAodlldeictitoionnalsl.y ,
Finally, OCSE will issue a letter to the States alerting them of the problem of
incorrect distribution.
OIG Response 
The ACF planned actions should improve communication and coordination between 
foster care and child support agencies and remedy inappropriate distribution of chid 
support dollars collected on behalf of children in IV-
E Foster Care. These 
should enhance parental responsibilty and directly benefit children in foster accatrieon. s
ASMB Comments 
The Assistant Secretary for Management and Budget (ASMB) concurred with the 
recommendations of the report from both a programmatic and fiancial 
The ASMB agreed that pursuit of child support for lV- viewpoint. 
the promise of both greater parental responsibility and Ed irFeocstt ebre nCeafriets  ctohi tdhree nc hhiodl.ds
The ASMB expressed some concern over different objectives of foster care and child 
support staff at the Federal level.
OIG Response 
Regarding ASMB's concern over the diferent objectives of child support and foster
care staff, we believe that as ACF implements its plan for better coordination and
monitorig the 
differences should be minimized.  ASPE Comments
The Assistant Secretary for Planning and Evaluation (ASPE) agreed that more 
coordination between foster care and chid support is needed. However
concerns about 1) the conflctig  , ASPE raised
objectives of child support and 
2) whether our savings projections included the cost of pursuing cfhaimldy s urepuponritc ation
how well actual collections compared to our projections.  , and 3) 
OIG Response 
1) Regarding ASPE'
s concern about collecting child support for children in IV-
Foster Care
, we agree that chid support should only be pursued in "
cases. However, we continue to believe that the majority of chidrena ipnp froosptreira cteare can
benefit from IV-
D Child Support servces
, such as paternity establishment and locating
absent parents. We hope our report 
increases the awareness of a need to integrate
these servces. Many of the 
issues and problems cited by ASPE will be solved as
States gain more experience in collecting child support on behalf of foster care 
children. The "
effective practice
" sites which we examined demonstrate that this can
happen. 
2) The ASPE commented that our projected 
pursuing child support. We agree. We did nosat vaidngjuss dt iodu nro t include the cost of
estimate of savigs to
account for the Federal share of State administrative cost 
determnig the  because of diffculties in
marginal cost of increasing collections. However
ASPE' s concerns we reduced the estimated savings by 50 percent,  tion  irnecsopropnosrea tteo 
consideration for the administrative cost of increasing 
collections. 
3) The ASPE commented that in fiscal year 
1990 OCSE collected $10.3 
behalf of children in IV-E Foster Care miion on
, but we projected collections of $8.
Our estimates were based on a random sample of foster care children. Th3e  vmariioanti.on 
between ours and OCSE estimates are probably the result of sampling error. ENNOTE 
Some States have an alternate system of 
obtaing chid support 
foster care. The cases usually are run through juvenile  for chidren in
a provision for child support as part of the original remcoovuarl to ardnedr .t Jyuicvaelnlyie  
include
do not use Federal child support guidelines when  court 
have collection powers (such as wage withholding)e asvtaabillaisbhlien gto o IrVde rs, nor do they
Support agencies. Of the few cases  D Chld
one had any collections. The total amino ouunrt  osafm tphlees er eferred to these systems
, only 
collections amounted to $180 
per year. 
We do not believe these two sites are the only " 
effective practice
they necessarily "best" of all sites in the nation.  " sites, nor are
Durig 
study, Federal and State program administrators explicitlsye nleacmtioend  othf ecsaes etws ofo r this
counties as "
atyical" for their exceptionally high level of collections and 
practices. To learn what " unique
atyical" practices might result in high collections
repeated the case review process and accompanying structured intervews  , we 
two counties. We reviewed " in these
universe" data for these counties to verify the validity
of the sample. 
Review of Child Su 
art Enforcement Title IV-
D and 
Foster Care Title IV-
Pro!!am Interface  ew Yor  Diane Schwart Willam Meltzer 
Jones. Administration for Children and Families (Region  and Allen 
June
II).  , 1991. 
Medicaid 1990 figure Courtesy of Health Care Financing Administration 
of Data Management and Strategy, Offce of Program Systems  , Bureau 
Medicaid Statistics.  , Division of  APPENDIX A
FOS CA PROC 
TI IV-
Afer a child is removed from a home - usually by the police or by child protection 
authorities - the chid is placed in some  care. A remov order 
tye of emergency 
signed by a court and a more permanent place for the child is found. Some States 
volunta 
and localities allow parents to  place their children in foster care. 
The preferred placement is in a "homelie" setting where a child will be cared for by 
foster pants. Usually foster parents are certifed volunteers who take chidren into 
their homes. The IV-E Foster Care program provides a Federal match (at the same 
rate as Medicaid) for States' expenses for foster care maitenance payments. These 
are costs directly related to care and lodging for eligible children. 
Local foster care agencies work with former cutodial parent(s) - usually the biological 
parent(s) who last had legal custody of a child - to develop a permanency plan. The 
permanency plan is a step-by-step action plan to determine what will happen with a 
child. In accordance with the Adoption  , the 
Assistance and Child Welfare Act of 1980
majority of permanency plans are designed to return a child to the former custodial 
parente s) as soon as possible. 
Occasionally, a foster care worker (or the parent) will determine that a chid can never 
return home. This determination is usually reached because the problems causing 
removal are so extreme or are insurmountable. For many such cases the permanency
plan will be adoption.
For adoption to take place, proper legal proceedings must terminate parenta rights of 
involuntary. If a parent is absent 
both parents. This termination can be voluntary or 
and their whereabouts are unknown, a "dilgent sech" must be made to satisfy legal 
requirements before a child ca be eligible for adoption. 
A child's case must be reviewed every six months and the permanency plan updated. 
The family s progress towards improving the home situation is tracked by an assigned 
, a child must be returned to 
foster care case worker. In cases of voluntary placements
the parent(s) upon his/her request. 
Coordination between IV-E Foster Care and IV-D Child Support programs begis 
with a referr from a foster care agency. The child support agency attempts to locte 
absent parent" is a biological parent not residing in the 
the absent parent(s). An "
home the chid is in. Paternty wi be establihed if necessary. The child support 
A support 
agency will go through the court proceedings to establish a support order. 
order is an order issued by a court requiring the absent parent(s) to provide chid 
support. The agency will then collec monies from the absent parent(s) and ditribute 
them in accordance with the court s ruling and Federal regulations.  APPENDIX B 
INRMTION COIL0N MEODS 
We analyzed a listing of Title IV-E Foster Care program population for each State in 
1989 to determine which States to include in our sample. We drew a two-stage cluster 
sample. First, we selected eight States at random with probabilty proportional to size. 
The average number of chidren in the IV-E Foster Care program in 1989 determed 
size." 
The selected States represented approximately 64 percent of the total average number 
of children in IV-E Foster Care in 1989. The eight States were: 
Arzona 
Californa 
Ilinois 
Kentucky 
Michigan 
Minesota 
New York 
Pennsylvania 
Second, we selected a sample of 320 IV-E Foster Care children. We randomly 
selected 40 children per State from the active lV-E Foster Care population. As 
necessary, we oversampled to compensate for cases which were not available at the 
time of our on-site visit (i.e., in court that day). The method of random sampling 
varied from State to State because of variations in administration and organition of 
lV-E Foster Care and IV-D Child Support programs in the sampled States. For State 
administered programs, we drew a random sample of all cases. In States where the 
IV-E Foster Care program is administered by counties, we selected two counties and 
drew a random sample of all cases within those counties. 
Once the cases were selected at lV-E Foster Care agencies, we gathered information 
on each case and the referral process via a uniform data gathering instrument. We 
gathered names, social security numbers, and other identifers, as available, on both 
parents and the IV-E Foster Care child. We then used these identiers at IV-D Child 
Support agencies to determine if the: 
Foster care agencies had referred a IV-E Foster Care case to IV-D Child Support 
agencies and the IV-D agencies had received it; 
IV-A AFDC agencies had referred a case to lV-D Child Support agencies on the 
parent(s) as an AFDC-eligible case; or IV-E Foster Care agencies had not referred the cae, but IV-D Chd Support
agencies had been able to open a correctly classifed IV-
E cae on the parent(s)
anywy (Le., the IV-D Chd Support agents independently search cour records). 
In these instances IV-E Foster Care agencies are unaware of IV-D Chd Support
agencies actions. 
When a IV-D Chid Support case corresponding to the IV-
E Foster Care case was 
found, we checked the IV-D case to see if it was correctly identifed as a IV-
E case (as
opposed to a IV-A case) and if any collections were being distributed to the IV-
Foster Care program. 
We gathered additional facts and data by intervewing people most directly 
knowledgeable about the extent child support is collected on behalf of children in 
IV-E Foster Care. We used structured intervew guides. Offcials in the eight-State 
sample included: foster care case workers
, eligibilty workers and their program
managers; child support staff, supervsors and court offcers; State IV-E Foster Care
and IV-D Child Support program managers and staff; and in the regions where the
eight sample States are located, Federal IV-E and IV-D program managers and staff.  APPENDIX C
"E 
SIT 
DESCRON 
OF  PRACTCE" 
Although their programs difer, Lancaster County, Pennsylvania and Olmstead County, 
Minnesota have developed successful programs, interrelating IV-E Foster Care and 
IV-D Child Support. 
Lacater  Pennlva 
County, 
The philosophical orientation and program organiztion make Lancaster County, 
Pennsylvania an "effective practice" site. First, the belief permeating the system is 
parental responsibility, including financial responsibilty. 
County managers encourage foster care servce workers to think about chid support
as part of overall therapy for a family. They gather 
necessary information on the chid
and family and refer it to the fiscal offcer for eligibilty determination and possible
child support. During all processes everyone assumes the parent(s) will shoulder some
of the financial responsibilty for their child while in foster care. Program managers
and staff believe that parents who are not asked to contribute will have a fiancial
not to strive for the return of their children. Parents must produce evidence
incentive 
that they are unable to financially support their child in order to be exempt from chid

support. 
In preparig the eligibility porton of a case, the fiscal offcer is also preparing the 
chid support case. The fiscal offcer does most of the routine work in preparig a 
case for the court to issue a support order. When necessary, two IV-D Chd Support 
offcers work with the fiscal offcer to faciltate the process. 
Lines of communication are smooth, with the fiscal offcer acting as a liaison between 
the IV-E and IV-D programs. The computer system also ties in IV-A AFDC records 
IV-D Child Support records and the IV-E Foster Care records, so all information is 
instantly exchanged. 
The fiscal offcer also monitors changes in family status. During a six-month eligibilty 
review, the foster care staff and fiscal offcer reassess every case for child support. 
The fiscal offcer also monitors collections on the computer, printing out weekly and 
monthly reports. Program and county managers also review the monthly printouts. 
C - 1 APPENDIX D 
PROJE CH  COlL0NS 
SUPORT 
The followig projections are based on the premise that our study sample represent 
collection rate and amount, we estimated up to 
tyical cases. Based on the current 
$74 million could have been collected in FY 1990 from parents of chidren in IV-
Foster Care if support orders were issued for 50 percent of the cases. 
To calculate this estimate, we weighted the 320 sampled cases to reflect the 
percentage of total number of children in IV-E Foster Care nationally. With these 
weights assigned , we recalculated the percentages of parents ordered to pay support 
and percentages of parents actually paying support. 
National &tiates 
Mothers  Fathers  Total 
Percent With Support 
Orders  11.0%  11. 
Amount Ordered  088 000  $22 755 000  $28 844 000 
Percent Payig Child 
Support 
Amount Collected  $336 000  949 000  285 000 
. Due to the small number of orders and collecons and the wide range of amounts ordered 
and collected (collections ranged from $5 per month to $20 per month) the precion of thes 
estimates is low. 
From the estimate of collections, we project that approximately $255 miion might be 
available if every case had a support order and the entire amount of the average 
current order was collected. 
Acknowledging that collections are not made on every support order, we created a 
hypothetical sample where the percentage of children for whom collections are made 
on their behalf is increased. These percentages assume the current collection rate of 
29 percent remains constant. 
D - 1 Estiate of Potenti Collecons 
(in mions)
Percent Of Chdren  Estimated Child  Net Federal  Estimated 
For Whom  Support Collected  Share of  Federal 
Collections Are Made  (FY 1990)  Collections  Savigs 
$15  $4.  $2. 
$30  $9.  $4. 
$45  $13.  $6. 
$60  $18.  $9. 
$74  $22.  $11. 
ba 
The Federal share is  on the ratio of the Federal share to the total of child support 
collections made on behalf of AFC children, as reported by OCSE. The percentage in 199 
use for determining Federal share of collecions wa 30.38 percent 
We are unable to calculate the marginal change in administrative cots that might be 
attributable to additional collecons. Hower, to roughly estimate poible Federal savings, we 
arbitrarily reduce the net Federal share of collecons by 50 percent. 
We believe our estimates are conservative for the reasons summaried below. 
Ths 
The estimate reflects a 29 percent collection rate for current support orders. 
lited 
low rate reflects many of the problems detaied in this report such as the 
exchange of information between foster care -and child support workers. The 
effective practice" sites achieve an 80 percent rate of collections on current 
support orders. Support orders in effective practices sites are also frequently 
updated, so the average dollar amount per support order is higher than is shown 
in this estimate. 
The ACF Region 11 offce conducted a recent study of referrals of IV-E Foster 
Care children to IV-D Child Support servces in New York City and showed a 
high rate of collections is possible. That study also showed problems in the 
referral processes and a lack of information exchange. Yet, when the IV-D Chid 
Support agency correctly opened IV-E Foster Care cases, they achieved over a 60 
percent collection rate. 
A potential savings to the Medicaid program from parent s medical support 
of their IV-E Foster Care children exists. In 1990 the average cost per Medicaid 
of the 
child was $811 per year. Although medical support only covers a porton 
total Medicaid expenditures, signficant savings may be possible. In "effective 
practice" sites 42 percent of the children received medical support from a parent. 
We did not include potential savings such as these in our estimates above. 
D - 2
 A IV-D Chd Support agency occsionally locates an absent parent (such as an 
wig 
who is  and 
absent father for whom paternty had not been established) 
able to provide a home for their child. In our sample, the IV-D Chd Support 
agency had located the alleged father of a IV-E Foster Care child. A paternity 
test proved the man was. the child' s father. The father who had been unaware of 
the child's existence, was concerned with the conditions that forced the child to be 
placed in foster care. The man then requested the child corne live with him and 
his family. File records showed the man s request was in the process of being 
reviewed and the child was expected to soon leave foster care. This is an example 
of the benefits a child may experience if they receive appropriate, coordinated 
servces. It also  E program which we did 
represents a source of savings to the IV-
not include in our estimates. 
E Foster Care 
The amount collected will increase as the number of children in IV-
, based on
rises. We estimate the increase in children to be 12 percent per year
the average rate of increase between 1986 and 1990. Potential collections will also 
increase as dollar amounts of child support collected increase due to inflation and 
improved methods of collections (such as wage withholding and tax intercepts). 
The rate of increase established for AFDC and Foster Care cases in 1986-1990 
was 4.75 percent. Provided that these rates continue over the next five years
Federal and State governments could cumulatively collect over $1 bilion in child

E Foster Care children by 1996. We did not include such 
support on behalf of IV-
calculations in our estimates. 
Additionally a one time increase in collections would be realized if all cases 
misclassified" for distribution purposes were corrected. In our review, 19 percent of 
the total dollars collected on behalf of children in IV-E Foster Care was mistakenly 
distributed to the IV-A AFDC program. If this percentage is representative of the 
national rate of mistaken distribution, $2.5 milion should go to the IV-E Foster Care 
program. 
D - 3
 APPENDIX E 
COMM  DRA REORT 
ON 
E - 1  ,. .
.:  .-' . ." .-  ~~~ ..."  - :.::\
DEPARTMENT OF HEALTH &. HUMAN SERVICES 
ADMINISTATION FOR CHILDREN AND FAMILIE 
Office of the Assistant Secretary, Suite 600 
370 L' Enfant Promenade, S. 
Washington, D.C. 20447 
March 27, 1992
To:  Richard P. Kusserow
. Inspector General 
Jo Ane B. Barart 
From:  f" 
Assistant Secretary  \es. 
Children and Fami
Subj ect:(cid:1) Comments on the Offic  Of Inspector General' s Draft
Report: 
"Child Support for Foster Care Children,
OEI-04-91-Q0530 
Attached are the Administration for Children and Families 
"Child 
comments on your draft inspection report entitled: 
support for Foster Care Children. 
a need to improve coordination be Neen the 
Wce ahgreie lthdat  thserue pport and fois ster care programs. 
We have provided 
specific comments on each of the recommendations discussed on
page 12 of the report. We have also provided additional comments
on our plans to implement the recommendations.
Thank you for the opportunity to respond to the recommendations
in this draft report.
Attachment 
iI --
:J 0'- ". 
:l 
:!r 
\=83  COMtS  GE'  CHTTnRE AN FAMLI ON TH 
OFFICE OF OF ITHN ADSMIPISTERTICONT FOOR R  S DRA INSPECTON RERT--CHLD 
CA 
SUPORT FOR FOSTE  CHLDRE rOEI-04-91-0530\ 
Following are the Administration for Children and Families I 
comments on the recomendations discussed on page  12 of the 
above-captioned report. 
OIG Recommendation 
fuds for 
Foster
As a condition of receiving Federal matching 
Care administration under Title IV-E, the Administration for 
Children and Families (ACF) should require states to develop and
implement:
assue that 
criteria and procedures to  Foster Care agencies 
cae 
refer all appropriate IV-E Foster  cases to IV-D Child 
Support Enforcement agencies for establishing child support 
orders and collecting child support  and 
a Memorandum of Understanding between IV-E Foster Care 
agencies and IV-D Child Support Enforcement agencies with 
respect to determining " appropriate" cases for referral 
gathering and exchanging data between the units, cross 
training, and inter-unit consultation on cases. 
ACF Comment:
already 
We believe that the substance of this recommendation  is 
in place. The Administration for Children, Youth and Families 
(ACYF) sent policy issuances to all State agencies which 
administer or supervise the administrtion of titles IV-B and IV 
E of the Social Secuity Act. 
These policy issuances are 
described below: 
Program Instruction, ACYF-PI-85-l, dated January 1, 1985, 
which requires States to amend their title IV-E State plans 
to include an amendment for the collection of child support 
payments made on or after October 1, 1984, as required by 
(a) (17) of the social Security Act. 
section 471 
12, 
Information Memorandum, ACYF-IM-84-27, dated December 
1984 , which transmitted to State child welfare agencies the 
Office of Child Support Enforcement' s (OCSE) Notice of 
Proposed Rulemaking regarding the child support enforcement 
exlained 
amendments of 1984. The Information Memorandum 
the responsibilities of both the title IV-D Child Support 
Enforcement agency and the title IV-E Foster care agency for 
The issuance states 
implementation' of the requirements. 
that it is the responsibility of the title IV-E agency to 
refer all cases with assignents to the title IV-D agency 
and to ensure that funds collected are appropriately 
managed. Page 2

The Informtion Memorandum recommended that each state 
arange a 
title IV-E agency  meeting with the stataes signent 
title IV-D agency to clarify the procedures for 
of title IV-E cases and deterine whether and under what 
conditions the agency would pursue support payments for

cases not receiving Federal funding. This recommendation

was based upon the fact that there is variation in state

laws and regulations governing the operation of title IV-D

agencies. 
The Information Memorandum also states that each quarer,

states must report to ACYF the title IV-E foster care

collections made as an adjustment to exenditures, and that 
it is the responsibility of the state title IV-E agency to 
assignent of 
initiate the action that will result in the 
rights to support for a child receiving title IV-E foster 
adoption 
care maintenance payments. This does not apply to 
assistance payments made under title IV-E.

copies of these policy issuances, ACYF-PI-85-1 and ACYF-IM-84-

27, are attached.

In addition, we are undertaking the following activities:

Each regional office will be asked to examine the system 
for the coordination of title IV-D and title IV-E 
ACY 
requirements in each State, and report to the 
Commissioner on the status of each state, highlighting
problem and providing recommendations for regional and/or 
Central Office action; and

We will include this issue as an explicit effort to be

undertaken as a part of title IV-B joint planning in the

Joint Planing Guidance to be issued to regions in fiscal

year 1992.

OIG Recommendation 

guidance
In support of such state initiatives, ACF should provide

Child 
and plans for coordinating the IV-E Foster Care and IV-D

Support Enforcement program. ACF could:

Develop training and technical assistance modules to assist

states in implementing new policies and procedures on child

support for children in IV-E Foster Care.

Pulish a 
compendium periodically of the techniques used by 
successful States in increasing their collections. 
Pulish 
periodic reports showing statistics nationally and 
by state on the IV-E Foster Care and IV-D Child support
initiative.  Page 3 
Direct regional offices ofs tAaCFd toa  monitor States in their
performce 
region using  and monitoring
mechanism . 
ACF Comment: 
Our FY 1992 strategic plan addresses the need to improve 
coordination between the child support and foster cae program.
Top level staff from OCSE and ACY have already met to begin a
joint initiative between the two agencies, designed to encourge
progr 
mutual  coordination and outreach at the Federl level. 
Tentative plansp irncolgudre  briefing centrl and regional office
staffs of both  to improve knowledge of each others
, as well as pulicizing their linge 
mission and fuctions  with
aricles in 
Child Support Report newsletter, which is sent to
a national athue dience of individuas inolved or interested in 
child support. 
titleIV-E State 
As part of the review of  plans, ACY is
examining State policies and procedures for collecting and
reporting the collection  of child support fuds. 
Recommendation '3 
OIG 
The ACF should ensure that the Federal share of child support 
dollars collected on behalf of IV-E Foster care children is 
progr 
correctly distributed to the IV-E Foster Care  rather than
the IV-A AFC program. 
ACF Comment: 
The OCSE audit process looks at control over collections and 
numer of foster care 
distribution; however , due to the small 
cases  simlar to 
, the OCSE auditors have ndortf utn covered situations 
the ones described in the OIG  report. We are confident
that  numer of referrals 
, as the  , and this foster care cases in 
the system increases , the OCSE audit will more closely monitor
this programatic area. OCSE will, in the near future , issue a
. "Dear Colleague 
" letter to State child support agency directors 
urging them to take appropriate steps to remedy the problem 
uncovered by the OIG , if such action is appropriate in their
State.  -. 
.. 
"--,,
 !:: . .
..,nI, 
0t 
R1IiIMIJULTH 
. DEPA IL HUMAN SERVICES  at th  .b. y 
CiFF!CE OF i ISf'ECrC:= 
J(L. 
ef.: : ; 9: 59  W8Iin. D.C. 201 
I 6 
;::3 I G :
Richard P. Kusserow

Inspector General 

14. 
From 	
Arnold R. Tompkins 
Assistant Secretary for anagement 
Subject:	 OIG Draft Report: "Child Support
Children,  OEI-04-91-00530 
We have reviewed the subject draft report, and wish to concur

with comments. The recommendations in the report are well

advised on both programatic and financial grounds. Pursuit of 
child support for IV-E children holds the promise both of greater

parental responsibility for children (and potentially, investment

in, and conmitment to these children), and of direct benefits to

the children (e.g., paternity establishment, location of absent

parents, continued collections after a child leaves foster care) 

We offer the following comments on this report. The report

indicates that one reason collections are low is the divergent

orientation of the Foster Care and Child Support agencies at the

State and local level. Specifically, notes the report in regard

to State staff: 
Foster care staff are oriented to and talk in terms of an

individual child. They form interpersonal relationships

with the families they serve. 
On the other band, most IV-D

Child Support staff view themselves as adversaries of

absent parents.  The child support staff tend to be

"bottom line oriented.

We question whether, at the Federal level, there aren't similar 
problems which need to be addressed, and whether there are 
actions which ACF can take to reduce tensions between the goals 
he IV-D program (collecting funds to offset income 
of 
maintenance costs) and the IV-E program (using the benefits of 
the child support process, including paternity and support order 
establishment and parental involvement). 
In Appendix D, page 3, the report states that "Federal and State 
governents could collect  child support on 
over $1 billion  in 
" The report needs 
behalf of IV-E Foster Care children by 1996.
cumulative  amount over five years. 
to clarify that this is a 
currently stated, the report gives the impression that by 1996, 
collected annually. Finally, on 
be'  page 7 of 
$1 billion could 
sion 
ti.	 port, in the first paragraph under the be ding "Mi  . and 
" 1n the th1rd 11ne, 
rc:es are not clearly understood or accepted,
complgment. 
the wc=d compliment should be changed to " . --"-
. .-
. DEPARTMENT Of HEALTH &. HUMAN SERVICES 
Ofce of tho Secota 
W..hinglon. D.C. 20201

'00:
h....-
TO:  Richard Kusserow

Inspector General

FROM:  Assistant Secretary for

Planning and Evaluation

SUCT : 
OIG Draft Report: "Child 
Support for Foster care
Children 
" OEI-04-91-00530 
Thank you for the informtive draft report on 
the use of Child

Support services for children in foster care. 
I agree that much

more could be done to coordinate the provision of Child Support

Enforcement services for children entering the title IV-E Foster

Care system. Better 
communication and coordination between staff

in IV-D and IV-E agencies is certainly needed and should be

encouraged. 
However, I believe your draft does not address several important
issues, and therefore oversimplifies the exent 
to which Child
Support collections for foster care children can or should be

pursued. I strongly suggest that the report include a discussion

of the following issues along with a suggestion that they be 
resolved before additional requirements are placed on state

agencies. 
The report does not adequately address the real and

perceived conflicts between the activities and goals of

the IV-D program (maximizing collections) and those of
the IV-E program (maximizing family reunification).
Before ACF can provide guidance and states can develop

criteria, there needs to be some resolution of these

policy conflicts. Included in the list of issues which

could lead to conflicts are: pursuing child support

from a two-parent family; pursuing child support from a

custodial parent when a child was involuntarily removed

from the parent(s); pursuit of child support from a

parent receiving AFDC; pursuit of child support when

contact with and by the non-custodial parent could be
disruptive to the permanency planing or reunification
process involving the child and his or her (former)
custodial parent. Finally, 
in our jUdgment, the report
does not distinguish between financial support as a

strategy for family involvement and reunification, and

child support as pursued under state Child Support

Enforcement guidelines and enforcement procedures.

8il ;111;'; 0 I  ';;I Z

:'::is; 
Q =:n:f= 
G::/1i3:J31:  Page 2 - Richard XUserow
The amount of savings potential fro IV-E collections
cited in the report is overly optimistic. 
It does not

seem to take into account the cost of providing Child

Support Enforcement services. The 1990 Child Support

Anual 
Report to Congress reports that states spent

$947 million to collect $1.754 billion in child support

collections on behalf of AF 
recipients. This results

in an average cost-effectiveness ratio of 1.85. This

low cost-effectiveness ratio would reduce the savings

potential by about 45 percent.

Informtion on the actual level of child 
support
collections made on behalf of IV-E children was not 
included in the report. In Fiscal Year 1990, IV-D 
bealf of 
agencies collected $10.3 million on  IV-E 
children. This is 30 percent more than the amount

estimated in Appendix D, based on sample information.

If you have any questions, please call Jane Baird at 245-2409.

L- /
.L:l
Martin