Department of Health and Human Services 
OFFICE OF 
INSPECTOR GENERAL 
USE OF FEDERAL CHILD SUPPORT 
CASE CLOSURE REGULATIONS 
JANET REHNQUIST 
Inspector General 
FEBRUARY 2002 
OEI 06-00-00470  OFFICE OF INSPECTOR GENERAL 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, is to 
protect the integrity of the Department of Health and Human Services programs as well as the health 
and welfare of beneficiaries served by them.  This statutory mission is carried out through a nationwide 
program of audits, investigations, inspections, sanctions, and fraud alerts. The Inspector General 
informs the Secretary of program and management problems and recommends legislative, regulatory, 
and operational approaches to correct them. 
Office of Evaluation and Inspections 
The Office of Evaluation and Inspections (OEI) is one of several components of the Office of Inspector 
General. It conducts short-term management and program evaluations (called inspections) that focus 
on issues of concern to the Department, the Congress, and the public. The inspection reports provide 
findings and recommendations on the efficiency, vulnerability, and effectiveness of departmental 
programs. 
OEI's Region VI prepared this report under the direction of Judith V. Tyler, Regional Inspector 
General. 
Principal OEI staff included: 
DALLAS  HEADQUARTERS

Blaine Collins, Project Leader
 Joan Richardson, Program Specialist

Amy Ashcraft

Ruth Ann Dorrill, Team Leader

Jennifer Kahende
 BALTIMORE

Clark Thomas

Nancy Watts
 Barbara Tedesco, Mathematical Statistician

Scott Whitaker

Lisa White

To obtain copies of this report, please call the Dallas Regional Office at 214-767-3310. 
Reports are also available on the World Wide Web at our home page address: 
http://www.oig.hhs.gov/oei  E X E C U T I V E  S U M M A R Y  
PURPOSE 
To assess the use of Federal child support case closure regulations, and to identify any 
problems or vulnerabilities related to improper case closure. 
BACKGROUND 
OCSE revised Federal regulations in 1999, allowing State child support agencies to close cases 
for twelve reasons, such as when an order has been paid in full or the noncustodial parent 
cannot be located, and requiring a 60-day advance notice of closure to the client under nine of 
the reasons. Case closure can help States concentrate resources on cases with a greater 
likelihood of success, maximize Federal incentive funding, and reduce data management 
demands. However, some advocates voice concern that States could be motivated to 
improperly close difficult-to-work cases.  We reviewed records of a nationally representative 
sample of child support cases closed over a three-month period in 2000.  We examined these 
records on three factors: 1) whether cases met one or more of the Federal closure reasons; 2) 
whether the recipient of services (typically a custodial parent or another State) was provided 
advance written notice of the agencys intent to close the case; and 3) whether this notification 
occurred 60 days prior to closure as required. Federal regulations regarding State self-
assessment establish a performance benchmark that allows for a case closure error rate of 10 
percent. 
FINDINGS 
We estimate a national case closure error rate of 32 percent, due primarily to 
inadequate notification 
Three types of errors comprise the 32 percent error rate. Because some cases contained more 
than one error, the percentages for these three types do not total 32 percent. 
Ten percent of cases did not meet a Federal closure reason.  Closing child support cases 
that do not meet one of the Federal closure reasons effectively halts enforcement action in cases 
deemed workable by Federal regulations. 
Twenty-five percent of cases requiring notice of closure did not have notice provided. 
Notice to clients of the agencys intent to close the case is required to insure that clients are 
aware of the agencys intended action in the case, and may prompt a client to supply additional 
information that could result in successful enforcement. 
Eleven percent of cases that received notice of closure were closed before the full 60 
days had elapsed.  The 60-day advance notice is designed to provide clients sufficient time to 
react to the agencys action. 
i 
Use of Federal Child Support Case Closure Regulations  OEI 06-00-00470  Cases with public assistance clients contained more errors. For reasons unknown, we 
found that closure errors occurred in a significantly greater proportion of cases involving current 
or former Temporary Assistance for Needy Families (TANF) recipients than cases of clients 
never enrolled in the TANF program. 
Six reasons account for 94 percent of closures and 96 percent of closure errors 
The six reasons are:

C  Inability to Locate Noncustodial Parent or Alleged Father

C  Inability to Establish Paternity 

C  No Enforceable Order, and Arrearage Less Than $500

C  Non-TANF Client Requests Closure 

C  Non-TANF Client Uncooperative 

C  Lost Contact with Non-TANF Client

Thirty-one percent of cases were closed because the child support agency does not have

enough information to locate the noncustodial parent or alleged father, or to establish paternity. 

We found some errors in cases closed for these reasons because of a lack of required location

efforts and client interviews, but most errors associated with the use of these two closure

reasons were due to a lack of adequate notification. Twenty-six percent of cases were closed

for having no enforceable support order and little or no arrears, and these cases also often

lacked adequate advance notice to clients. Cases closed for reasons that apply only to non-

TANF clients also contained errors involving notice.  This was particularly true for cases closed

because the agency had lost contact with the non-TANF custodial parent. 

CONCLUSION 
It is noteworthy that the vast majority of child support case closures met at least one of the 
Federal closure reasons. However, inadequate provision of advance notice to clients appears 
to be largely responsible for preventing achievement of the 90 percent performance benchmark. 
We encourage OCSE to work with States to undertake efforts to reduce the error rate. It 
would be especially useful to focus on improving processes for providing advance notice of 
closure, particularly related to use of the six most frequently used closure reasons. A 
companion report, Challenges in Closing Child Support Cases (OEI 06-00-00471), 
describes effective practices States use to reduce errors and improve their case closure 
activities, and provides specific recommendations to OCSE and States. 
AGENCY COMMENTS 
The Administration for Children and Families (ACF) generally agreed with the findings and 
conclusions of this report, and described on-going and planned reviews that could assist States 
in improving case closure through automation. 
ii 
Use of Federal Child Support Case Closure Regulations  OEI 06-00-00470  T A B L E   O F   C O N T E N T S  
PAGE

EXECUTIVE SUMMARY
 i 
INTRODUCTION
 1 
FINDINGS

Case Closure Accuracy
 5 
Use of Closure Reasons
 7 
Conclusion
 9 
ENDNOTES
 10 
APPENDIX A:  Case Closure Regulations 45 CFR Sec. 303.11  A-1

APPENDIX B:  Additional Statistics  B-1

APPENDIX C:  Agency Comments  C-1
 I N T R O D U C T I O N  
PURPOSE 
To assess the use of Federal child support case closure regulations, and to identify any 
problems or vulnerabilities related to improper case closure. 
BACKGROUND 
Federal law has long recognized that State child support 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 emancipates.  States may also wish to close cases 
with little likelihood of successful enforcement, such as cases in which the custodial parent 
provides little or no 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 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 Federal 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 unworkable cases. In response to the complaints, in 1996 OCSE formed a review 
committee comprised of staff and elected officials from local, State, and Federal governments 
to review the regulations. The committee review led to revised Federal 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 generally made it easier for States to close more cases.  It 
also enhanced client safeguards designed to insure that States notify clients before closing 
cases. 
Current regulations allow States to close cases that meet one or more of twelve reasons. Nine 
of the twelve closure reasons require that the recipient of services (typically a custodial parent 
or another State) must be notified of the agencys intent to close the case. 
1 
Use of Federal Child Support Case Closure Regulations  OEI 06-00-00470  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 
This notice must be provided in writing 60 days before the case may be closed.  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.  All records for closed cases must be retained for a 
minimum of three years.  The Federal case closure regulations are reprinted in Appendix A. 
State Incentives To Close Cases 
States have at least three apparent incentives for closing cases: concentrating resources on 
cases with greater likelihood of success; maximizing Federal incentive funding; and reducing 
data management demands. Closing unworkable cases allows States to allocate their limited 
resources to cases with greater potential for successful enforcement.  States can also improve 
their child support enforcement performance indicators, upon which much of Federal incentive 
funding is based, by reducing the total number of cases in their caseload.4 Additionally, case 
closure can help States reduce data management demands by eliminating duplicate and 
outdated cases.  While these incentives are viewed as legitimate reasons for closing unworkable 
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. 
Monitoring Case Closures 
Until the mid-1990s, OCSE conducted compliance audits of State child support cases which 
included an analysis of closed cases. With the passage of the Personal Work and Opportunity 
Reconciliation Act, OCSE replaced compliance audits with a requirement that States conduct 
annual self-assessments of their own performance.5 States 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  States are encouraged to use their self-assessments as management tools 
to identify any weaknesses, non-compliance with 
2 
Use of Federal Child Support Case Closure Regulations  OEI 06-00-00470  regulations, and opportunities for improvement. Case closure is one of eight required 
categories States must assess.  Federal self-assessment regulations require that at least 90 
percent of closed cases reviewed by States meet the Federal regulations.7 Thus, this 
benchmark allows for a case closure error rate of 10 percent. 
State self-assessments provide information about child support case closure activities in 
individual States.  The reports for Fiscal Year 1999 showed many States had improperly 
closed at least some cases, and State child support agencies proposed a variety of corrective 
actions. These reports helped to identify potential vulnerabilities related to closing child support 
cases, as well as effective practices.8 However, there has been no national review since the 
new regulations were issued in 1999. 
METHODOLOGY 
To provide more comprehensive information, we reviewed the records of a nationally 
representative sample of child support cases closed over a three-month period in 2000.  The 
results of our case record reviews are presented in this report. Additionally, we interviewed 
State child support agency personnel in ten States to gain an in-depth understanding of their 
experience in using the 1999 case closure regulations.  We present our findings from these 
interviews in a companion report entitled, Challenges in Closing Child Support Cases (OEI 
06-00-00471). 
Study Focus 
Our case record reviews focused on both the case circumstances and the processes used by 
State child support agencies to close cases. We also examined case records to determine 
whether cases met one or more of the Federal closure reasons, whether the recipient of 
services was provided advance written notice of the agencys intent to close the case, and 
whether this notification occurred 60 days prior to closure as required. 
Sample Of Closed Cases 
To obtain a nationally representative sample of closed child support cases, we used a two-
stage, stratified-cluster sampling method.  We first stratified the 48 contiguous States9 and the 
District of Columbia into two groups:  one stratum included cases from the eight States with the 
largest child support caseloads (known as the Big 8 States);10 and the other stratum included 
cases from all other States.  We stratified in this manner to insure that our sample contained 
cases from some of the Big 8 States which have about 50 percent of the nations child support 
caseload,11 as well as cases from a number of States with smaller caseloads.  In each stratum, 
we considered a single States caseload as a cluster of cases. For the first stage of sampling, 
we randomly selected four States from the large-State stratum: California; New York; Ohio; 
and Pennsylvania. We also randomly selected six States from the other stratum: Alabama, 
Connecticut, Mississippi, Montana, New Mexico, and South Carolina.12 
3 
Use of Federal Child Support Case Closure Regulations  OEI 06-00-00470  To draw a sample of cases for review, we requested that each selected State provide a list of 
all cases closed during May, June, and July 200013 and the reason for closure.14  To focus our 
review on the twelve Federal closure reasons, we did not include in the sample frame cases 
closed because they were duplicate cases or were opened in error.15 The list of cases closed 
for a Federal closure reason made up our sampling frame for each State. At the second stage 
of sampling, we randomly selected 50 cases from each selected States sampling frame, for a 
total sample of 500 cases. This two-stage, stratified-cluster sample yields national estimates at 
a 95 percent confidence level, unless otherwise specified. Given our national focus for this 
study, and sampling method to achieve it, our resulting data does not allow precise analysis of 
individual States. 
Data Collection 
An OIG analyst visited each State to review the selected cases. We gathered the information 
needed primarily from official electronic records, supplemented by paper records as necessary 
to insure completeness.  States provided staff to train our analysts on navigating automated 
systems. Analysts entered case information into a standardized database on-site, which we 
later merged with all other case data. However, data-cleaning revealed that five cases did not 
meet our selection criteria because they were either duplicate cases or were opened in error. 
After eliminating these cases, we had complete data on 495 cases. 
Data Analysis 
We reviewed records to determine whether each case met all Federal case closure 
requirements.  We designated cases as having been closed correctly if the case record review 
revealed each of the following: 1) the case met conditions necessary to be closed for one or 
more of the twelve Federal closure reasons;16 2) the child support agency notified the recipient 
of services in writing of intent to close the case (required for nine closure reasons); and 3) 
closure occurred no sooner than 60 days after notification (when notice was required and 
provided).17 
We generated national estimates of the proportion of cases closed in accordance with all 
Federal regulations, and for each of the three factors.  We used statistical software to adjust for 
the stratified-cluster sampling method, and we weighted estimates based on the number of 
cases closed by each sampled State during the sample period.  Additionally, we generated 
statistics regarding the relative use of the twelve Federal closure reasons and the public 
assistance status of the recipient of services at the time of closure.  Records were available for 
all sampled cases, eliminating any non-response issues.  Descriptive statistics are expressed as 
percentages and, where appropriate, statistical differences between categorical variables were 
assessed using the appropriate test. 
This study was conducted in accordance with the Quality Standards for Inspections issued by 
the Presidents Council on Integrity and Efficiency. 
4 
Use of Federal Child Support Case Closure Regulations  OEI 06-00-00470  F I N D I N G S  
CASE CLOSURE ACCURACY 
Nationally, our sample indicates that while 90 percent of closures met at least one of the 
Federal closure reasons, 32 percent did not meet all Federal case closure requirements (Table 
1).  This overall performance level fell considerably short of the benchmark of a 10 percent 
tolerable error rate established by OCSE. However, most closure errors occurred due to a 
lack of adequate notification rather than because cases did not meet a Federal closure reason. 
Table 1: Case Closure Errors 
Percent of Cases 
Overall  with Error a 
Case did not meet all federal closure requirements (n=495)  32 % 
Type of Error b 
Case did not meet a federal closure reason (n=495)  10 % 
Notice was not provided to recipient of services (n=372)  25 % 
Closure occurred before 60-days had elapsed (n=267)  11 % 
a Confidence intervals provided in Appendix B.

b Type of error percentages do not total 32 percent because some cases contain more than one

error.

About 10 percent of child support cases closed did not meet a Federal closure 
reason, halting enforcement of workable cases 
We estimate that approximately one out of every 10 child support cases closed in the nation 
during the sample period did not meet a Federal closure reason.  Closing cases for unallowed 
reasons creates a great vulnerability because Federal regulations deem these workable cases at 
the time of closure, without the need for additional information or substantial changes in 
circumstances. In a few of these cases, the case record reveals that the State child support 
agency recognized the case had been closed in error, and subsequently reopened the case. 
Most cases, however, were still closed at the time of our review.  While no payments were 
being made on any of these cases at the time they were improperly closed, it is possible that 
they could have become paying cases if further enforced. 
We also found an additional 11 percent of cases that did not meet the reason documented in 
the case record, but did meet another Federal closure reason.  If we had reviewed these cases 
only on the closure reason documented in case records, the proportion of cases not meeting a 
Federal closure reason would have approximately doubled. Based on our 
5 
Use of Federal Child Support Case Closure Regulations  OEI 06-00-00470  review, having the wrong closure reason in case records was sometimes due to simple data 
coding errors, while other errors appear to be due to staff misunderstanding or misapplying the 
Federal closure reasons. Clients in these cases, when notification occurred, were likely given 
the erroneous closure reason, potentially hindering their appropriate reaction. 
Clients were not notified in 25 percent of cases requiring advance notice, and 
were not given the full 60 days to respond in 11 percent of cases 
Records indicate that the recipient of services was not provided written advance notice of the 
agencys intent to close the case in 25 percent of cases requiring notification. Federal 
regulations require written notice 60 days prior to closure, partly to inform the client that the 
agency will no longer be working on the case.  Notification also serves to solicit additional 
information from clients that could lead to successful enforcement of some cases. About 10 
percent of cases lacking notification also did not meet a Federal closure reason, suggesting the 
clients in those cases had no opportunity to prevent the improper closure. While the remaining 
cases lacking notification appeared to meet at least one of the Federal closure reasons, it is 
unclear whether proper notification would have changed those circumstances. 
In 11 percent of cases for which notice was provided, closure occurred before the 60-day 
notification period had elapsed. In the final rule for the new case closure regulation, OCSE 
reiterated that the 60 calendar day time frame has worked well [to allow clients sufficient 
opportunity to prevent an unwanted closure], and believes it would be inappropriate to shorten 
the time frame.18 Among cases closed sooner than 60 days after notice, several closed on the 
same day or within a couple of days of notification.  In interviews, some State child support 
agency respondents explained that, despite Federal requirements, caseworkers may consider it 
more efficient to simply inform a client that their case has been closed rather than provide 
advance notice. Respondents added that it is fairly easy to reopen a case should the parent 
respond to a final closure letter with more information. 
Higher error rates among closures involving TANF recipients could hinder 
enforcement for vulnerable families 
Our review found some type of closure errors in 43 percent of cases involving current and 
former Temporary Assistance for Needy Families (TANF) clients, compared to only 21 
percent among never-TANF clients.  This represents a significant difference in outcomes for the 
two groups.19 The reasons for this difference are currently unclear and may warrant additional 
research. Improper closures for current and former TANF recipients are of particular concern 
because child support payments can often mean the difference between reliance on public 
assistance and self-sufficiency.  Closing cases that do not meet allowable reasons, or not 
providing adequate advance notice of closure, could stop enforcement efforts on workable 
cases involving families who could benefit greatly from successful enforcement. 
6 
Use of Federal Child Support Case Closure Regulations  OEI 06-00-00470  USE OF CLOSURE REASONS 
Six closure reasons account for 95 percent of all case closures 
As shown in Table 2, we estimate that six Federal closure reasons account for the vast majority 
of child support case closures, and two of these reasons are used in about half of closures. 
Many closed cases were never fully enforced, such as cases closed because the agency could 
not locate a noncustodial parent or alleged father. Other cases were closed because they had 
been successfully enforced, such as when an obligation had been paid in full and there was no 
longer an enforceable order.  The following findings discuss improper closures under these six 
prominent closure reasons. 
Table 2: Distribution of Federal Closure Reasons20 
Percent of Cases 
Federal Closure Reason  Using Reason* (N=495) 
No enforceable order, and arrearage less than $500  26 % 
Unable to locate noncustodial parent or alleged father  24 % 
Non-TANF client requests closure  18 % 
Non-TANF client uncooperative  12 % 
Lost contact with non-TANF client  8 % 
Unable to establish paternity  7 % 
All other reasons  5 % 
* Percentages reflect weighted values. 
About 26 percent of cases were closed for having no enforceable support order 
and little or no arrears, but these cases often lacked adequate notification 
Many different kinds of cases are eligible for closure under this single Federal closure reason. 
In more than half of cases closed for this reason, the child emancipated or the obligation was 
paid in full. Another large proportion of these cases were closed after a substantial change in 
family arrangements, including reconciliation of the parents, a change in custody, or an 
adoption. Other cases were closed using this reason when their orders were deemed 
unenforceable under individual State rules. Examples include when the noncustodial parent had 
low income or was receiving public assistance at the time of closure, and when the custodial 
parent moved out of the State or local jurisdiction. 
Our review revealed that cases closed for having no enforceable support order and little or no 
arrearages had the highest incidence of errors among all closure reasons.  While most cases met 
the Federal closure reason, over one-third of cases closed for this reason did not include 
written notice of the agencys intent to close the case.  Advance notice might be particularly 
important in such cases as when an emancipated child is still attending high school or college 
and potentially eligible to continue collecting support payments. In 
7 
Use of Federal Child Support Case Closure Regulations  OEI 06-00-00470  such cases, it would be important for the custodial parent to communicate with the child support 
agency regarding the teenagers academic enrollment. However, the nature of some cases 
closed for this reason, such as those involving reconciliation of the parents, provides partial 
explanation for why an agency might not have deemed it necessary to provide notice. 
Thirty-one percent of cases were closed because of an inability to locate the 
noncustodial parent or to establish paternity 
Twenty-four percent of cases were closed because the agency did not have enough information 
to locate a noncustodial parent or alleged father. Federal regulations require child support 
agencies to attempt to locate an absent parent for at least one year before closing the case in 
situations where little information exists. If the noncustodial parents or alleged fathers name 
and Social Security number are known, the agency must continue automated locate efforts for 
at least three years before closure. We found that in about one-fifth of cases closed for this 
reason, States either did not continue location efforts as long as required, or did not follow-up 
on recent locate information. 
States closed seven percent of cases because paternity could not be established. These 
closures mostly consisted of cases in which the client had not named an alleged father, or the 
man named was excluded by genetic testing and no additional names were provided.  When the 
identity of the biological father is unknown, Federal regulations require State child support 
agencies to interview the recipient of services at least once prior to closing the case using this 
reason. While at least one interview occurred in almost every case involving this closure reason 
that we reviewed, case records indicate that a few clients were not re-contacted to provide an 
additional name when an alleged father was excluded by genetic testing. 
Most of the errors associated with the use of these two closure reasons involved lack of 
adequate notification. Notification of the agencys intent to close the case is considered to be 
particularly crucial in cases such as these where insufficient information has been provided by 
the custodial parent. Notice could serve as a clients last chance to relay any information they 
have about a noncustodial parent or alleged father. Additionally, families involved in cases 
closed for these reasons are potentially among the most vulnerable in the child support 
caseload. In our sample of cases closed for these reasons, most clients were current and 
former TANF recipients. 
Cases closed for reasons that apply only to non-TANF clients also contain errors 
involving notice 
Eight percent of cases were closed due to a loss of contact with the non-TANF recipient of 
services.  In such cases, Federal regulations require at least one attempt to contact the client by 
mail. If the agency receives no response within 60 days, it can then mail to the clients last 
known address the 60-day advance notice of its intent to close the case.  In nearly all cases 
closed for this reason, the agency either did not make the first contact attempt, did not provide 
advance notice of its intent to close the case, or did not wait one 
8 
Use of Federal Child Support Case Closure Regulations  OEI 06-00-00470  or both of the required 60-day time periods prior to closure. Some managers reported being 
confused by the language of the regulations regarding this closure reason, while others indicated 
that the resulting two 60-day waiting periods seemed unreasonable considering that the agency 
has lost contact with the non-TANF client. 
Twelve percent of cases were closed because the agency had documented that the non-TANF 
client was not cooperating, typically by failing to respond to a letter, failing to appear for an 
interview or court hearing, or not providing additional information about the noncustodial parent 
or alleged father as requested.  We generally found that the clients non-cooperation was well 
documented, but many of these cases lacked adequate notification.  Eighteen percent of cases 
were closed because the non-TANF client requested closure.  Notification is not required 
when using this reason, and we found few errors with its use. 
CONCLUSION 
It is noteworthy that the vast majority of child support case closures met at least one of the 
Federal closure reasons. However, inadequate provision of advance notice to clients appears 
to be largely responsible for preventing achievement of the 90 percent performance benchmark. 
We encourage OCSE to work with States to undertake efforts to reduce the error rate. It 
would be especially useful to focus on improving processes for providing advance notice of 
closure, particularly related to use of the six most frequently used closure reasons. A 
companion report, Challenges in Closing Child Support Cases (OEI 06-00-00471), 
describes effective practices States use to reduce errors and improve their case closure 
activities, and provides specific recommendations to OCSE and States. 
AGENCY COMMENTS 
The Administration for Children and Families (ACF) generally agreed with the findings and 
conclusions of this report. ACF described that on-going systems certification reviews and 
planned Level of Automation reviews could assist States in improving case closure through 
automation.  We agree that improvements in automated system capabilities can certainly help to 
reduce future case closure errors. In the meantime, considering that case closure is not fully-
automated in many States, we encourage ACF to work with States to reduce errors generated 
through their current procedures.  ACF comments are provided in their entirely in Appendix C. 
9 
Use of Federal Child Support Case Closure Regulations  OEI 06-00-00470  ENDNOTES

1. OCSE Action Transmittal 89-15, August 4, 1989. 
2. Federal Register, Volume 64, No.46, March 10, 1999, pp. 11810-11818. 
3. Ibid., page 11811. 
4. Federal Register Volume 64, No.195, October 8, 1999, pp. 55073 - 55102. 
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. 
6. 45 CFR Sec. 308.1 (e). 
7. 45 CFR Sec. 308.2 (a). 
8. At the time of our study, States 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 if they had been selected. 
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. Office of Child Support Enforcement, Dear Colleague Letter 97-26, May 19, 1997. 
12. Resources limited us to sampling from only 10 clusters.  We considered that including cases from 
half of the Big 8 States (4 clusters) was reasonable, which left 6 clusters for the other stratum. 
13. Field work revealed that seven cases in one State actually closed in August, 2000, and we kept 
these cases in our final sample. Another State provided a list of cases in which the closure process 
began in May, June, and July, 2000, rather than the actual closure occurring in that time period, and we 
used these cases as the sampling frame for that State. We do not believe these deviations had a 
substantial effect on our findings. 
14. The automated systems of California and New York would not allow inclusion of closure reasons at 
the time of sampling, although we were later able to determine the reason for closure during fieldwork. 
To insure that our sample included cases closed for one of the Federal closure reasons, we over-
sampled in these States and then randomly selected which cases would be reviewed once we obtained 
information about the closure reason. 
15. States reported using the duplicate case closure reason in situations such as when two local 
jurisdictions had a case open for the same parties. Closing one of the cases simply eliminates the 
duplication, while the parties continue to have an open case in the State.  The open in error closure 
10 
Use of Federal Child Support Case Closure Regulations  OEI 06-00-00470  reason is typically used to correct data-entry mistakes in State automated systems. 
16. We only evaluated cases on a closure reason other than the one designated in the case record when 
conditions were not met for closure under the designated reason.  If such a case met the conditions for 
closure under another reason, we considered that it met Federal requirements. We did this to 
differentiate between cases closed improperly, and those in which a closure code may have been 
inadvertently input in an automated system but the case could have legitimately been closed. In such 
cases, notification was evaluated on the reason for closure that the case legitimately met rather than the 
one the State recorded. 
17. In a few cases, the recipient of services received notification and contacted the State agency to 
agree to close the case sooner than 60 days. We considered that these cases met the 60-day 
requirement. 
18. Federal Register, Volume 64, No.46, March 10, 1999, page 11817. 
19. The Cochran-Mantel-Haenszel Chi-Square Test was significant with a P-value of 0.0714, 
representing a statistical difference at a 90 percent confidence level. 
20. The frequencies and percentages in Table 2 include the 55 cases for which we reassigned the 
closure reason. 
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Use of Federal Child Support Case Closure Regulations  OEI 06-00-00470  APPENDIX A

Code of Federal Regulations 45 
Sec. 303.11 Case Closure Criteria. 
(a) The IV-D agency shall establish a system for case closure. 
(b) In order to be eligible for closure, the case must meet at least one of the following criteria: 
(1) There is no longer a current support order and arrearages are under $500 or unenforceable 
under State law; 
(2) The noncustodial parent or putative father is deceased and no further action, including a levy 
against the estate, can be taken; 
(3) Paternity cannot be established because: 
(i) The child is at least 18 years old and action to establish paternity is barred by a

statute of limitations which meets the requirements of Sec. 302.70(a)(5) of this chapter;

(ii) A genetic test or a court or administrative process has excluded the putative father

and no other putative father can be identified; or

(iii) In accordance with Sec. 303.5(b) of this part, the IV-D agency has determined that

it would not be in the best interests of the child to establish paternity in a case involving

incest or forcible rape, or in any case where legal proceedings for adoption are

pending;

(iv) The identity of the biological father is unknown and cannot be identified after

diligent efforts, including at least one interview by the IV-D agency with the recipient of

services;

(4) The noncustodial parent's location is unknown, and the State has made diligent efforts using 
multiple sources, in accordance with Sec. 303.3, all of which have been unsuccessful, to locate 
the noncustodial parent: 
(i) Over a three-year period when there is sufficient information to initiate an automated

locate effort, or

(ii) Over a one-year period when there is not sufficient information to initiate an

automated locate effort;

(5) The noncustodial parent cannot pay support for the duration of the child's minority because

the parent has been institutionalized in a psychiatric facility, is incarcerated with no chance for

parole, or has a medically-verified total and permanent disability with no evidence of support

potential. The State must also determine that no income or assets are available to the

noncustodial parent which could be levied or attached for support;

(6) The noncustodial parent is a citizen of, and lives in, a foreign country, does not work for the

Federal government or a company with headquarters or offices in the United States, and has no

reachable domestic income or assets; and the State has been unable to establish reciprocity

with the country;

(7) The IV-D agency has provided location-only services as requested under Sec.

302.35(c)(3) of this chapter;

(8) The non-IV-A recipient of services requests closure of a case and there is no assignment to

the State of medical support under 42 CFR 433.146 or of arrearages which accrued under a

support order;

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Use of Federal Child Support Case Closure Regulations  OEI 06-00-00470  APPENDIX A

(9) There has been a finding by the responsible State agency of good cause or other exceptions

to cooperation with the IV-D agency and the State or local IV-A, IV-D, IV-E, Medicaid or

food stamp agency has determined that support enforcement may not proceed without risk of

harm to the child or caretaker relative;

(10) In a non-IV-A case receiving services under Sec. 302.33(a)(1) (i) or (iii), the IV-D

agency is unable to contact the recipient of services within a 60 calendar day period despite an

attempt of at least one letter sent by first class mail to the last known address;

(11) In a non-IV-A case receiving services under Sec. 302.33(a)(1) (i) or (iii), the IV-D

agency documents the circumstances of the recipient of services's noncooperation and an action

by the recipient of services is essential for the next step in providing IV-D services.

(12) The IV-D agency documents failure by the initiating State to take an action which is

essential for the next step in providing services.

(c) In cases meeting the criteria in paragraphs (b) (1) through (6) and (10) through (12) of this section, 
the State must notify the recipient of services, or in an interstate case meeting the criteria for closure 
under (b)(12), the initiating State, in writing 60 calendar days prior to closure of the case of the State's 
intent to close the case. The case must be kept open if the recipient of services or the initiating State 
supplies information in response to the notice which could lead to the establishment of paternity or a 
support order or enforcement of an order, or, in the instance of paragraph (b)(10) of this section, if 
contact is reestablished with the recipient of services. If the case is closed, the former recipient of 
services may request at a later date that the case be reopened if there is a change in circumstances 
which could lead to the establishment of paternity or a support order or enforcement of an order by 
completing a new application for IV-D services and paying any applicable application fee. 
(d) The IV-D agency must retain all records for cases closed pursuant to this section for a minimum of 
three years, in accordance with 45 CFR part 74. 
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Use of Federal Child Support Case Closure Regulations  OEI 06-00-00470  APPENDIX B

Additional Statistics: Error Rate Estimates with Confidence Intervals 
95 Percent 
Errors  Proportion  Confidence 
Estimate  Interval 
OVERALL: Case Did Not Meet All Federal Closure Requirements  31.6 %  19.2% - 44.1% 
(n=495) 
Case Did Not Meet A Federal Closure Reason (n=495)  9.6 %  6.7% - 12.5% 
Notice Was Not Provided to Recipient of Services (n=372)  24.7 %  9.8% - 39.6% 
Closure Occurred Before 60-Days Had Elapsed (n=267)  10.9 %  0.2% - 21.7% 
Errors Among Current and Former TANF Cases (n=261)  42.8 %  26.7% - 58.9% 
Errors Among Never-TANF Cases (n=227)  20.6 %  12.0% - 29.2% 
Cases With Wrong Reason Documented in Record (n=495)  10.6 %  5.9% - 15.2% 
Additional Sampling Statistics 
State  Population of Cases  Cases Selected  States in Stratum 
Large State Stratum 
CALIFORNIA  18,348  50  8 
NEW YORK  30,731  50  8 
OHIO  11,773  50  8 
PENNSYLVANIA  91,591  50  8 
Other State Stratum 
ALABAMA  9,395  50  41 
CONNECTICUT  9,407  50  41 
MISSISSIPPI  13,584  50  41 
MONTANA  2,457  50  41 
NEW MEXICO  872  50  41 
SOUTH CAROLINA  10,325  50  41 
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