Department  of Health and Human Services 
CHILD  SUPPORT  AND  THE  MILITARY 
JUNE  1993  OEI-07-90-02250  EXECUTIVE  SUMMARY

PURPOSE 
To  determine  what  barriers  exist in the  collection  of child  support  payments  from 
absent  parents  in the  U.S. military  service. 
BACKGROUND 
A  1989 Management  Advisory  Report,  A-12-89-00154,  issued  by the  Office  of Audit 
Services  (OAS)  identified  42,000 military  personnel  in arrears  on their  child  support 
payments.  These  payments  totalled  over  $176 million.  The  OAS  identified  these 
military  cases  through  a match  of the  1989 Office  of Child  Support  Enforcement 
(OCSE)  tax intercept  file and  military  personnel  data.  About  64 percent  of the 
payments  were  related  to  support  for Aid to Families  with  Dependent  Children 
(AFDC). 
Persons  serving  in the  U.S. military  semices  are  expected  to pay their  financial 
obligations  in a timely  manner,  including  the  support  of dependent  children. 
The  U.S. Department  of Army  regulations,  32 CFR  Part  584.2, requires  soldiers  to 
provide  financial  support  to family  members,  obey  court  orders,  and  comply  with  all 
court  imposed  obligations.  More  specifically,  Army Regulation  608-99,  Chapter  2-la, 
requires  soldiers  to provide  financial  support  to family members  and  to obey  court 
orders  on child  custody.  The  Navy, Air Force  and  Marines  have  similar  regulations 
which  also  require  their  members  to pay their  financial  obligations,  including 
dependent  support. 
We  selected  eight  States  and  360 cases  for inclusion  in this inspection,  using  a two-
stage  stratified  cluster  sample.  States  were  then  selected  in the  first  stage  using  a 
stratified  random  sample.  Forty-five  cases were  selected  in each  State  with  random 
sampling  for  a total  of 360 cases. 
In addition,  we interviewed  Child  Support  Enforcement  (cSE)  caseworkers  in two 
local  CSE  offices  and  at a military  installation  in each  of the  eight  States.  We  also 
interviewed  legal  staff in each  of the  four  Defense  Finance  and  Accounting  Service 
Centers.  Our  preliminary  findings  were  discussed  with the  Department  of Defense 
and  their  comments  are  incorporated  in the  report. 
FINDINGS 
States  do  not  collect  child  support  payrnen~  in more  than  half  of the sample  military 
cases.  Projected  national  savings to the  AFDC  and  Medicaid  programs,  if courts 
orders  for  child support  were  established  and/or  enforced  in these  cases,  totals  $54.1 
million. 
1  Locating  absent  parents  is the greatest  barrier.  The  transient  nature  of military 
assignments  and  the  fact  that  military  personnel  are  often  stationed  at installations  for 
short  periods  of time  often  complicates  the  location  of absent  parents.  That,  coupled 
with  difficulties  in obtaining  Social  Security  numbers  for  absent  parents,  often  makes 
locating  absent  parents  in the  military  virtually  impossible. 
The  CSE  stafl  have  not  been properly  trained  to handle  miiltary  cases.  The  CSEstaff 
are  unfamiliar  with  military  policies  and  procedures  which  can become  red tape.  A 
handbook  issued  by the  Administration  for Children  and  Families  (ACF)  entitled 
Child Support  Enforcement  in the  Military was effective  but  not  widely  distributed  to 
CSE  caseworkers  and  staff. 
Mi.litaq  Finance  Centem  identi~  reasons  for  delaying  the processing  of wage  withholding 
oniem  The  Defense  Finance  and  Accounting  personnel  interviewed  indicated  that  the 
delay  in processing  wage  withholding  orders  is often  the  result  of handling  many 
orders  more  than  once,  and  that  many  orders  are  returned  to CSE  agencies  because 
they  lack  the  proper  documents  and/or  information  required  for processing.  The  lack 
of standardized  forms  for  submission  of wage withholding  orders  also  delays  processing 
which  is consistent  with  a finding  in a previous  Office  of Inspector  General  (OIG) 
report. 
RECOMMENDATIONS 
1.  The  ACF,  Office  of Child  Support  Enforcement  should: 
a.	 provide  technical  support  to State  CSE  offices  to improve  Social  Security 
number  identification; 
b.	 evaluate  the  usefulness  of information  available  through  the  Federal 
Parent  Locator  Service,  and  provide  necessary  assistance  to local  CSE 
offices  searching  for  military  absent  parent  Social  Security  numbers; 
c.	 continue  to promote  the  Child Support  Enforcement  in the  Military 
handbook;  and 
d.	 establish  and  require  the  use of a standard  form  and  a checklist  for 
submission  of wage  withholding  requests  to the  Defense  Finance  and 
Accounting  Service  Centers. 
2.	 The  ACF  and  the  Social  Security  Administration  (SSA)  should  collaborate  to 
develop  a better  mechanism  to assist CSE  staff in obtaining  Social  Security 
numbers  for  absent  parents.  In doing  so, it is essential  that  safeguards  remain 
in place  to protect  individual  privacy  and  the  integrity  of the  Social  Security 
system. 
ii  We received  comments  on the  draft  report  from  ACF,  SS~  and  the  Assistant 
Secretary  for Planning  and  Evaluation.  They  concurred  with  our  recommendations. 
ACF  identified  several  actions  that  they have  taken.  However,  we feel  continued 
actions  on each  of our  recommendations  are  warranted.  The  full text  of their 
comments  are  included  in Appendix  D. 
... 
111  TABLE  OF  CONTENTS

Page 
i

EXECUTIVE  SUMMARY  . . . . . . . . . . 
. . . . . . . . . . ...  oooo  Q  o  o 
1

INTRODUCTION  . . . . . . . . . . . . . . . . . . . . ....  00.co.. 
FINDINGS  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  3

o.-oc.-0 
Uncollected  supportpayments.  . . . . . . . . . . . . . . . . . . . ....  . .  3

support  inmilita~cases  . . . . . . . . . . . . . . . . . . . . .  5

CSE  staff  training  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  7

Military  finance  centers  . . . . . . . . . . . . . . . . . . . . . .......  . . . . . . . . . . . . .  7

RECOMMENDATIONS  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...  9

APPENDIXES 
A.  Projected  Case  Characteristics  . . . . . . . . . . . . . . . . . . . . . . . . ....A-l 
B.  State  Level  Data  . . . . . . . . . . . . . . . . . . . . . . . . . . . .......  ...B-l 
c. 
Projected  Program  Savings  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..C-l 
D.  Agency  Comments  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .*.-D-l  INTRODUCTION

PURPOSE 
The  purpose  of this study  is to determine  what  barriers  exist in the  collection  of child 
support  payments  from  absent  parents  in the  U.S. military  service. 
BACKGROUND 
A  1989 Management  Advisory  Report,  A-12-89-00154,  issued  by the  Office  of Audit 
Services  (OAS)  identified  42,000 military  personnel  in arrears  on their  child  support 
payments.  These  payments  totalled  over  $176 million.  These  military  cases  were 
identified  through  a match  of the  1989 Office  of Child  Support  Enforcement  (OCSE) 
tax intercept  file and  military  personnel  data.  About  64 percent  of the  payments  were 
related  to support  for Aid to Families  with Dependent  Children  (AFDC). 
Persons  serving  in the  U.S. military  services  are  expected  to pay their  financial 
obligations  in a timely  manner,  including  the  support  of dependent  children. 
The  U.S.  Department  of Army  regulations,  32 CFR  Part  584,2, requires  soldiers  to 
provide  financial  support  to family members,  obey  court  orders,  and  comply  with  all 
court  imposed  obligations.  More  specifically,  Army  Regulation  608-99, Chapter  2-la, 
requires  soldiers  to provide  financial  support  to family members  and  to obey  court 
orders  on child  custody.  The  Navy, Air Force  and  Marines  have  similar  regulations 
which  also  require  their  members  to pay their  financial  obligations,  including 
dependent  support. 
METHODOLOGY 
We  selected  eight  States  and  360 cases  for inclusion  in this inspection,  using  a two-
stage  stratified  cluster  sample.  States  were  then  selected  in the  first  stage  using  a 
stratified  random  sample.  Forty-five  cases were  selected  in each  State  with  random 
sampling  for  a total  of 360 cases. 
The  sample  frame  for the  first stage  consisted  of the  50 States.  These  States  were 
rank  ordered  and  categorized  into  quartiles  based  on the  1990 average  annual  AFDC 
caseload  information  listed  on the  OCSE-56  form.  Three  States  were  randomly 
selected  from  each  of the  four  strata  - two sample  States  plus one  alternate.  Three  of 
the  initially  selected  sample  States  were  unable  to provide  us with  a list of AFDC 
cases  which  included  absent  parent  information.  We  replaced  these  three  States  with 
the  selected  alternate  States  for  the  respective  quartile.  The  eight  States  selected  for 
inclusion  in this  study were  Arkansas,  Georgia,  Illinois, Massachusetts,  New  Jersey, 
Nevada,  Oklahoma  and  South  Dakota. 
Using  the  lists provided  by the  State  Child Support  Enforcement  (CSE)  agencies,  we 
identified  the  AFDC  child  support  cases  in which  a branch  of military  service  was 
1  listed  as the  absent  parents  place  of employment.  Then  we randomly  selected  45

cases  from  the  military  cases  identified  in each  State,  for a total  of 360 cases.  We

reviewed  275 of these  cases,  We  did not  review  the  other  85 cases  based  on  our

determinations  that  the  absent  parents  were  not  in the  military,  had  been  discharged

from  military  service,  paternity  blood  tests were  negative,  or the  AFDC  portion  of the

case  had  been  closed.

Through  our  review  of the  sample  AFDC  case  files, we obtained  the  information

necessary  to determine  if the  absent  parents  had  been  located,  if paternity  had  been

established,  if court  orders  had  been  issued,  and  whether  or not  child  support

payments  were  being  collected.  We were  also  able  to determine  the  extent  of contacts

between  CSE  staff  and  military  personnel,  and  the  success  of the  contacts.

In addition  to our  review  of the  sample  cases, we interviewed  CSE  caseworkers  and

military  staff  in each  of the  selected  States,  and  each  of the  Defense  Finance  and

Accounting  Service  Centers.  We  interviewed  CSE  caseworkers  in two local  CSE

offices  in each  of the  eight  States.  One  CSE  office in each  State  was located  within  50

miles  of a military  installation,  and  the  other  located  more  than  50 miles  from  any

military  installation.

We  interviewed  military  personnel  at one  military  installation  in each  of the  sample

States.  The  selection  of CSE  offices  and  military  installations  to be  included  in our

sample  was conducted  with the  assistance  of both  State  CSE  and  Department  of

Defense  (DOD)  personnel.  In total,  four  Army,  three  Air Force,  and  one  Naval

installation  were  included  in the  sample.  The  militaxy personnel  interviewed  varied

from  installation  to installation,  and  included  staff from  the  Inspector  Generals  office,

the  Family  Support  Center,  Personnel,  Payroll,  Accounting  and  Finance,  Legal

Assistance,  and  Chaplains.  We  also  conducted  interviews  with legal  staff  in each  of

the  four  Defense  Finance  and  Accounting  Service  Centers.

Our  preliminary  findings  were  discussed  with DOD  and  they  provided  comments,

advice,  and  input  regarding  sampling,  design,  and  issues which were  incorporated  into

the  report.

2
 FINDINGS

I.	 States  &  not  collect  chiiif support  payments  in more  than  hay  of the sample 
military  cases. 
No  child  support  payments  are  being  collected  in  143 of the  275 sample  cases 
reviewed.  Based  on a weighted  distribution,  these  cases  account  for  51 percent 
of the  360 included  in our  sample.  Child  support  orders  had  been  established 
but  no  current  payments  were  being  made  in 45 of the  cases  (12.7 weighted 
percentage),  causing  arrearages  to build.  NO support  orders  had  been 
established  in 98 other  cases  (37.8 weighted  percentage),  and  therefore  no child 
support  payments  were  being  made.  The  chart  below  shows the  weighted 
distribution  of the  360 sample  cases.  (See  Appendix  A for  more  details.) 
No Child Support Collected 
(51 Percent -Weighted  Distribution  of 360 Cases) 
 
u. Sqpxlcdleci 
 
P13ym*ntscumnt 
Projected  national  savings  to the  AFDC  and  Medicaid  programs,  if court  orders 
for  child  support  were  established  and/or  enforced  in these  cases,  total  $54.1 
million.  (See  Appendix  C for more  details.) 
No  current  child  support  pawn ents were  being  made  in 45 of the  sample  cases 
where  court  orders  for suPPort  existed. 
The  45 sample  cases  had  been  open  from  7 to 256 months,  averaging  51.7 
months.  The  recorded  number  of months  since the  absent  parent  had  made 
court  ordered  child  support  ranged  from  1 to 43 months,  averaging  12 months. 
The  average  recorded  arrearage  for these  cases was $4,590.  Recorded 
arrearages  totalled  $179,030.  Projected  nationally,  the  number  of cases  where 
no  current  child  support  payments  were  being  made  totals  5,114.  Savings  to 
3
 the  AFDC  program,  if existing  court  orders  for  child  support  were  enforced  in

these  45 cases,  projects  to $15.5 million  annually.

0fthe45  sample  cases  inwhich  absent  parents  were  delinquent  in their  court

ordered  child  support,  only 6 had  orders  containing  immediate  wage

withholding.  The  absence  of immediate  wage withholding  makes  the  collection

of delinquent  payments  difficult.  Because  immediate  wage  withholding  was not

included  in these  support  orders,  the  CSE  agency  must  encourage  absent

parents  to establish  voluntary  allotments,  process  garnishments  or serve  them

with  delinquency  notices  to  establish  involuntary  allotments.  Voluntary

allotments  must  be  established  by the  absent  parent  and  can  also be  canceled

by the  absent  parent  at any time.  Involuntary  allotments  require  delinquencies

of more  than  2 months  and  are  not  honored  by the  military  unless  the  order

specifies  a monthly  amount  to be  applied  to the  arrearage.

No court  order  for  child  support  had been  established  in 98 of the  sample

cas.
es

Of the  98 sample  cases  in which  no support  orders  had  been  established,  CSE

staff had  been  unable  to locate  the  absent  parent  in 47 cases.  In the  other  51

cases,  the  absent  parents  had  been  located  but  no  court  order  established  for  a

variety  of reasons,  including  the  fact that  the  absent  parents  were  out  of the

country  or on a ship,  paternity  blood  tests  were  pending,  or  CSE  staff  made  nO

militaly  contacts.  The  chart  below  provides  more  detailed  information

regarding  these  cases.

~d  which 
support  (%XS  in 
No Support Order had been Established 
Absent Parent  Absent  Parent 
case status  Not Located  Located 
No absent parent SocialSecurityNumber
 37 
CSEstaffmadeno militarycontacts
 12 
Absent parent abroad or on a ship
 11 
Paternhy blood tests were pending
 7 
No activityon case since absent parent located
 6 
MilitaryUncooperative(Due  to War  time

restrictions  of Desert  Storm)  4 
Custodial  parent/client  uncooperative  3 
CSE contacts  current  2 3 
CSE made  inappropriate  contacts  2 3 
Insufficient  information  to determine  status  3 
Absent  parent  was uncooperative  1 
CSE awaiting  military  response  1 
Absent  parent  discharged  by time  of contact  1 
Militaty  had no record  of absent  parent   
Totals  51 
4
 Ontheaverage  these  cases  had  been  open  27months,  over  2years.  The  actual 
time  they  had  been  open  ranged  from  3t0145  months.  Projected  nationally, 
these  cases  total  15,222.  The  projected  annual  savings tothe  AFDC  program  is 
$22,246,649  if court  orders  for child support  were  established  and  enforced  in 
these  cases. 
Medical  insurance  is available  to cover  demmdents  currentlv  receivirw  medical 
assistance  throu ti  the  Medicaid  Dromun. 
Medical  insurance  is available  to all military  personnel  and  their  dependents. 
In addition  to AFDC  program  savings, the  establishment  and  enforcement  of 
medical  support  obligations  for the  projected  number  of cases  in which  no 
court  orders  had  been  established  would  save  the  Medicaid  program 
$12,285,523  annually.  We  calculated  this savings  amount  by applying  the 
average  of $807.09  in medical  assistance  provided  to AFDC  children  by the 
Medicaid  program  to the  projected  number  of these  cases,  and  multiplying  it by 
12 months.  We  used  the  Health  Care  Financing  Administration  Form  2080 to 
determine  the  average  monthly  amount.  We  then  applied  the  $807 to the 
98 cases  in which  no court  orders  for child support  had  been  established. 
The  Medicaid  program  would  save an additional  $4,127,458  annually  if court 
orders  for  medical  support  were  enforced  in the  projected  number  of cases 
where  court  orders  already  exist.  The  combined  Medicaid  program  savings for 
both  types  of cases  totals  $16,412,981  annually. 
We  recognize  the  Federal  governments  liability  in the  Civilian  Health  and 
Medical  Program  of the  Uniformed  Services  (CHAMPUS)  and  Medicaid  and 
that  obtaining  health  care  coverage  for military  personnel  dependents  through 
CHAMPUS  would  not  necessarily  lead  to a reduction  in overall  Federal  health 
care  expenditures. 
2.  Locating  absent  parenti  is the greatest  barrier. 
The  CSE  staff were  unable  to locate  the  absent  parents  in 47 of the  sample 
cases  reviewed,  as shown  in the  chart  on page  4.  These  47 cases  account  for 
48 percent  of the  98 cases  in which no support  order  had  been  established.  We 
estimate  that  out  of the  population  studied  23.5 percent  of the  absent  parents 
would  be  difficult  to locate. 
The  transient  nature  of military  assignments  and  the  fact  that  military  personnel 
are  often  stationed  at installations  for short  periods  of time  often  complicates 
the  location  of absent  parents.  The  CSE  staff in  13 of the  16 CSE  offices 
visited  stated  they  had  encountered  problems  in locating  absent  parents  in the 
military.  The  staff  in 6 of the  13 offices  named  location  of the  absent  parents 
as the greatest  barrier  to  child support  enforcement  and  collection  in military 
cases. 
5
 As shown  in the  chart  on page  4, cases  in which  the  absent  parents  Social

Security  numbers  are  unknown  account  for  38 percent  (37 of 98) of the  cases  in

which  no  court  orders  have  been  established.  Since  the  milita~  uses  Social

Security  numbers  to  identi&  military  personnel,  they  are  imperative  in the

identification  and  location  of absent  parents  in the  military,  as well as in

processing  wage  withholdings  for court  ordered  support.  Without  a Social

Security  number,  locating  an  absent  parent  in the  military  is virtually

impossible.

The  CSE  staff we interviewed  indicated  few resources  are  available  for

obtaining  unknown  Social  Security  numbers.  They  have  been  directed  to use

the  Federal  Parent  Locator  Service  (FPLS)  to search  for unknown  absent

parent  Social  Security  numbers.  Likewise,  Social  Securi~  Administration  staff

have  been  directed  to refer  CSE  staff searching  for  absent  parent  Social

Security  numbers  to the  FPLS,  except  in emergency  situations.

However,  the  CSE  staff interviewed  indicated  that  since little  absent  parent

information  is available  to them  in many  of these  cases,  they  often  consider  the

FPLS  an  unproductive  source  for obtaining  a Social  Security  number.  To

obtain  a Social  Security  number  through  the  FPLS,  the  CSE  agency  must

accurately  complete  at least  three  of a number  of specified  data  fields.  These

fields  include  the  absent  parents  city of birth,  State  or country  of birth,  first

name,  middle  initial,  last name,  date  of birth,  sex, mothers  first name,  mothers

middle  initial,  or mothers  maiden  name.  The  information  included  in the

completed  fields  must  be  letter  perfect  to match  with Social  Security

Administration  information  available  through  the  FPLS.  Staff  in one  CSE

office  said  they  had  never  gotten  a Social  Security  number  through  the  FPLS.

Others  indicated  that  obtaining  a Social  Security  number  through  the  FPLS  is

very  unlikely.

Additionally,  CSE  staff  are  often  unfamiliar  with  other  locate  sources  available

to them  if the  Social  Security  number  is known.  One  such  source  is the

Worldwide  Military  Locator  Services  (wMLS).  Each  branch  of military  service

has  established  a WMLS  to provide  military  addresses  for military  personnel.

The  WMLS  information  is provided  to State  CSE  agencies  at no charge.

However,  CSE  staff  in four  of the  eight  offices visited  said they  seldom

contacted  a WMLS,  and  one  said they had  never  contacted  a WMLS.  In the

45 cases  where  CSE  staff had  contacted  a WMLS  for locator  information,  the

absent  parents  military  addresses  were  provided  in all but  four  instances.  In

three  of these  four  cases,  the  military  refused  to provide  the  information

requested  based  on the  privacy  required  by Operation  Desert  Storm.  In the

other  case,  the  military  refused  to provide  the  information  requested  by the

CSE  agency,  stating  that  the  records  requested  are  protected  from  disclosure

under  the  privacy  act.

6
 hothermilita~  locator  source  available  to CSEstaff  is base  locators.  Most 
military  installations  have  a base  locator,  who  can provide  the  ranks  and 
military  addresses  of military  personnel  assigned  to that  installation.  A base 
locator  can  also provide  CSE  staff with the  next  duty station,  in the  event  that 
the  person  in question  has been  transferred.  Even  though  CSE  staff  in  11 of 
the  16 offices visited  said they  sometimes  or almost  always used  base  locators, 
staff  in 3 offices  said they  seldom  or never  contacted  base  locators. 
Even  though  base  locators  often  serve  as an excellent  source  of locating  absent 
parents,  CSE  staff should  be  cautioned  in their  contacts  with  them.  Military 
personnel  at seven  of the  eight  installations  visited  indicated  they  do not 
forward  requests  for the  location  of absent  parents  to the  WMLS  in instances 
where  he/she  is not,  or has  not  recently  been,  stationed  at their  facility. 
Therefore,  CSE  staff  should  proceed  with  contacts  to the  WMLS  if contacts 
with  a base  locator  are  unsuccessful.  As with the  use of the  WMLS,  base 
locators  also require  the  absent  parents  Social  Security  number. 
3.  The  CSE  stafi  have  not  been properly  trained  to handle  milita~  cases. 
The  CSE  staff have  not  been  properly  trained  to handle  military  cases.  They

are  unfamiliar  with military  policies  and  procedures  which  can  become  red

tape  when  not  understood.  The  staff interviewed  expressed  concern  with  the

layers they  have  to go through  in obtaining  information  about  absent  parents

in the  military.  One  person  interviewed  said they  may write  off military  cases

because  it is so hard  to get the  absent  parents  served.  Others  said they  have

limited  information  regarding  the  military  and  need  training,  and  that  they

need  training  sessions  with military  personnel  who have  direct  knowledge  of

how the  system works.

The  handbook  issued  by the  ACF,  Office  of Child  Support  Enforcement,

entitled  Child Support  Enforcement  in the  Military was effective,  but  not

widely  available.  The  Office  of Child  Support  Enforcement  issued  the

handbook  in June  of 1991 to states  and  local  child support  enforcement  offices,

but  only 8 of the  16 local  CSE  offices we visited  had  a copy  of the  handbook  at

the  time  of our  interviews,  over  6 months  later.  In two of these  eight  offices

the  handbook  was available  in the  office, but  it had  not  been  distributed  to the

staff.  In these  two instances,  only one  person  on the  CSE  staff had  seen  a copy

of the  handbook.  The  CSE  staff  that  had  copies  of the  handbook  spoke  highly

of it and  said  they found  it helpful.

4.	 Militay  Finance  Centen  identi~  reasom  for  a!daying  the proc&g  of wage 
withholding  ordem 
The  CSE  staff inteniewed  indicated  that  processing  wage  withholding  in 
military  cases  takes  longer  than  non-military  cases.  They  said  military  wage 
7
 withholdings  take  from  2 to 4 weeks  longer  than  civilian  cases,  and  that  it is 
2 to  3 months  before  they  see  any payments. 
The  Defense  Finance  and  Accounting  personnel  interviewed  indicated  the  delay 
in processing  CSE  wage withholdings  is often  the  result  of the  office  handling 
many  wage  withholding  orders  more  than  once.  They  said  that  many  wage 
withholding  orders  are  returned  to  CSE  agencies  because  they  lack  the  proper 
documents  and/or  information  required  for processing.  Among  the  reasons 
listed  for  returning  wage  withholding  orders  to CSE  agencies  were  the  lack  ofi 
- a certified  copy of the  support  order;

- a certified  copy of the  arrearage  support  order;

- the  absent  parents  full name  and  Social  Security  number;

- the  full name  and  address  to whom  payment  should  be  made;  or

- legible  copies  of documents.

The  Defense  Finance  and  Accounting  personnel  also indicated  that  the  lack  of 
standard  forms  for the  submission  of withholding  orders  delays  the  processing 
of wage  withholding  orders,  which  in turn  delays  payment.  The  wage 
withholding  forms  they  receive  vary by State,  and  many  times  from  one 
jurisdiction  to another  within  a State.  They  indicated  that  standardization  of 
wage  withholding  documents  would  speed  their  document  review  time,  leave 
less room  for errors,  and  could  serve  as a checklist  for  CSE  staff  to use  in 
preparing  wage withholding  packages.  This finding  is consistent  with  a previous 
Office  of Inspector  General  (OIG)  report  which found  that  formats  and 
language  in court  order  forms  are  not  standardized  among  State  CSE  agencies. 
The  report  recommended  requiring  all jurisdictions  to use  standardized  forms 
when  issuing legal  processes  for child support  to employers.1 
1
An Employer  Perspective  Fragmentation  of State  Practices  Impair  Ability  of Employers  to 
Effectively  Implement  Wage Withholding  Process, A-12-91-00016. 
8  RECOMMENDATIONS

1.  The  ACF,  Office  of Child  Support  Enforcement  should: 
a.	 provide  technical  support  to State  CSE  offices  to improve  Social  Security 
number  identification; 
b.	 evaluate  the  usefulness  of information  available  through  the  Federal 
Parent  Locator  Service,  and  provide  necessary  assistance  to local  CSE 
offices  searching  for military  absent  parent  Social  Security  numbers; 
c.	 continue  to promote  the  Child Support  Enforcement  in the  Military 
handbook;  and 
d.	 establish  and  require  the  use  of a standard  form  and  a checklist  for 
submission  of wage  withholding  requests  to the  Defense  Finance  and 
Accounting  Service  Centers. 
2.	 The  ACF  and  the  Social  Security  Administration  should  collaborate  to  develop 
a better  mechanism  to assist  CSE  staff in obtaining  Social  Security  numbers  for 
absent  parents.  In doing  so, it is essential  that  safeguards  remain  in place  to 
protect  individual  privacy  and  the  integrity  of the  Social  Security  system. 
AGENCY  COMMENTS  AND  OIG  RESPONSE 
We  received  comments  on  our  draft  report  from  ACF,  the  Assistant  Secretary  for 
Planning  and  Evaluation  (ASPE),  and  SSA.  The  full text  of their  comments  are 
included  in Appendix  D. 
The  ACF  concurred  with  our  recommendations,  agreeing  that  processes  for  collecting 
child support  payments  from  absent  parents  in the  military  need  to be  improved, 
particularly  in locating  the  absent  parents.  They  noted  several  past  and  future 
initiatives  to enhance  efforts  to locate  and  establish  support  requirements  for  absent 
parents  in the  milita~.  However,  we believe  continued  actions  on  each  of our 
recommendations  are  warranted. 
The  ACF  suggested  that  we incorporate  data  collection  instruments  into  the  report. 
For  reasons  of efficiency  and  clarity,  we generally  do not  do this.  However,  we are 
more  than  happy  to provide  a copy  of the  instruments  to ACF. 
The  ASPE  agrees  that  OCSE  and  child  support  enforcement  agencies  could  undertake 
additional  administrative  actions  to improve  establishing  and  enforcing  child  support  in 
cases where  the  absent  parent  is in the  military. 
9  However,  ASPE  raised  several  points.

The  ASPE  agrees  that  military-provided  insurance  could  potentially  reduce  Medicaid

costs but  pointed  out  that  would  not  reduce  Federal  health  care  expenditures.  The

medical  bills would  be  paid  by CHAMPUS,  the  Federal  program  which  pays  for health

care  of military  personnel  and  their  dependents.  We  agree  and  have  made  this point

on page  5 of our  report.

The  ASPE  mentions  that  AFDC  (and  Medicaid)  program  savings  are  computed  as if

all of the  absent  parents  could  be  located,  so the  potential  program  savings should

reflect  a more  realistic,  less than  100 percent,  locate  rate.  We  agree  that  our

estimates  are  premised  on the  100 percent  locate  rate  and  that  this is not  likely to be

achieved,  However,  we believe  that  this should  be  the  goal  and  that  a locate  rate

approaching  100 percent  is feasible.  Furthermore,  we have  no way to accurately

predict  any other  rate.

The  ASPE  feels  that  some  of the  problems  related  to wage-withholding  stem  from

inconsistencies  between  the  Federal  law permitting  garnishment  in the  military  (passed

in 1982) and  the  general  child  support  wage withholding  statutes  (passed  in 1984 and

1988) and  that  it may be  impossible  to eliminate  confusion  between  military  personnel

and  CSE  until  the  1982 law is amended  and/or  military  regulations  are  brought  into

conformance  with  subsequent  legislation.  However,  we did not  encounter  this

problem  in our  study.

Regarding  developing  a better  mechanism  for obtaining  Social  Security  numbers,

ASPE  indicated  that  safeguards  have  to remain  in place  to protect  individual  privacy

and  the  integrity  of the  Social  Security  system.  We  agree  and  have  included  such

references  in the  report.

The  SSA agreed  that  it should  collaborate  with ACF/OCSE  to develop  a better

mechanism  to  obtain  Social  Security  numbers  for absent  parents.

The  SSA also  raised  several  questions  regarding  our  statistical  calculations.  We

selected  our  sample  using  stratified  two-stage  cluster  design.  The  data  from  the  eight

States  were  assigned  weights  appropriate  for the  design.

The  SSA is correct  that  States  having  a large  number  of child support  cases  in which  a

military  branch  was listed  as the  absent  parents  place  of employment  had  a higher

percentage  of cases  where  no child  support  is being  collected  than  the  small

enrollment  States.  We  include  State  level data  in Appendix  B.  SSA also pointed  out

a discrepancy  in the  precision  level  of one  item  on our  table  of projected  case

characteristics.  We  made  the  corrections.

10
 APPENDIX  A

Projected  Case  Characteristics 
Distribution  with  resmect to whether  child support payments  were  delinquent.
. 
-1-.  . 
Delinquent  Cases  Non-Delinquent  Dropped  out  of 
Cases  the  Sample 
Estimate  12.7%  59%  28.3% 
9070 Confidence  Interval  9.770-15.7%  54%-64%  23.3V0-33.3% 
Relative  Precision  23.6%  8.3%  17.770 
Distribution  with  respect  to whether  or not  a support  order  was established. 
.  .-
No Support  Support  Order  Dropped  Out  of 
Order  Established  Established  the  Sample 
Estimate  37.8%  33.970  28.3Y0 
90%  Confidence  Interval  239?0-52.6T0  16.5% -51.39Z0  23.3% -33.3?Z0 
Relative  Precision  I 39%  I 51.3%  I 17.7%  II 
Distribution  with  respect  to whether  or not  the  absent  parent  could  be  located. 
Unable  to Locate  Located  Dropped  Out  of 
the  Sample 
Estimate  23.5%  48.2%  28.39Z0 
90%  Confidence  Interval  20.5%-26.5%  38.7%-57.7%  23.3%-33.3% 
Relative  Precision  12.8%  19.7%  17,7% 
Distribution  with  respect  to whether  or not  the  case  was a paternity  case. 
Paternity  Case	 Non-Paternity  Dropped  out  of 
Case  the  Sample 
Estimate  55.2%  16.59Z0  28.3% 
9090 Confidence  Interval  45%-65.4%  7%-26$Z0  23.3%-33.3% 
Relative  Precision  18.4%  57.6%  17.7% 
A -1
 APPENDIX  B

State  Level  Case  Data 
I 
Cases  98 Cases 
cases  in  in  Cases  No Order  45 Cases 
Universe  Sample  Reviewed  Established  No  Payment 
Strata 1 
GA  4,068  45  32  21  6 
IL  664  45  29  1  5 
Strata  2 
MA  90  45  31  2  6 
NJ  708  45  33  9  6 
Strata  3 
414  45  35  20  4 
OK  127  45  40  26  3 
Strata 4 
NV  178  45  33  18  6 
66  45  42  1  9 
6,315  360  275  98  45 
* 
B-1  APPENDIX  C

Projected  Program  Savings 
(dollar  amounts  in millions) 
Order  Established/  No  Order  Total  Number  of 
Payments  Established/  Cases Receiving 
Delinquent  No Payments  No Payment 
Number  of Cases in 
Sample  45  98  143 
Number  of Case 
Projected  Annually  5,114  15,222  20,336 
AFDC  Program 
Savings  $15.5  $22.2  $37.7 
Medicaid  Program 
Savings  $4.1  $12.3  $16.4 
Total  $19.6  $34.5  $54.1 
 
Confidence  Intervals  and  Precision 
(dollar  amounts  in millions) 
Order  Established/  No Order  Established/ 
Payments Delinquent  (45 cases)  No Payments  (98 Cases)
I 
AFDC  I  Medicaid 
Estimate  $22.2  I  $12.3 
9070 Confidence  $13.2-$31.2  $7.5 -$17.1 
Interval 
*  ;l 
Precision  29%  I  23.6%  39%  39?40 
c-1  APPENDIX  D

Agency  Comments 
We  received  comments  on our  draft  report  from  the  Administration  for Children  and 
Families  (ACF),  the  Assistant  Secretary  for Planning  and  Evaluation  (ASPE),  and  the 
Social  Security  Administration  (SSA).  Their  responses  follow. 
D-1
 ., 
.J~$    L*.  .L.  A .1  . .  . .  .  . .  ..&.  .L.  .  .  --.....1- L------- ---
; 
<> 
ADMINISTRATION  FOR CHILDREN  AND  FAMILIE 
370 LEnfant  Promenade,  S.W. 
Washington,  D.C.  20447 
Date:  April  1,  1993 
To:  B  ell 
P  ty Inspector  General 
From:  L 
A  nt  Secretary  for 
Children  and  Families 
Subject:  Comments  on  OIG  Draft  Report  tChild  Support  and  the 
Military  OEI-07-90-02250 
We agree  that  there  is  a  need  to  improve  the  processes, 
particularly  location,  to remove barriers  that  exist  in the 
collection  of child  support  payments  from absent  parents  in  the 
military. 
The report  finds that:  1)  States  did not collect  child support 
payments  in more  than half  of the sample of military  cases;  2) 
locating  absent  parents  is the greatest  barrier  to the collection 
of support  payments;  3) Child Support  Enforcement  (CSE) staff 
have not been properly  trained  in handling  military  cases;  and  4) 
military  finance  centers  identified  reasons  for delaying  the 
processing  of wage withholding. 
The report  indicates  that OIG staff  interviewed  CSE staff and 
military  personnel  in each  of the eight States.  However,  the 
report does  not mention  the process  for identifying  and selecting 
the persons  to be interviewed  nor does it include  the questions 
posed.  We suggest  that  the data collection  instruments  be 
incorporated  as exhibits  to the report. 
Comments  on the specific  OIG recommendations  follow: 
OIG  Recommendation: 
I.a. The ACF,  Office  of Child  Support  Enforcement  should provide 
technical  support  to State CSE offices  to improve  social 
security  number  identification: 
ACF Comment: 
We concur. 
In September  1991,  at  the  First  Annual  National  Child

Support  Training  Workshop,  the  Office  of  Child  Support

Enforcement.  (OCSE)  conducted  a  track  on  location  training

for  72  participants  (mainly  State  child  support  trainers)

from  28  States.  Improvement  of  social  security  number  (SSN)

identification  was  included.  Each  of  the  participants
 Page 
2 - Bryan  B.  Mitchell 
and  the  non-attending  states  were provided  with  a  sample 
curriculum  for  location  training.  Our  follow-up  to  the 
conference  indicates  that  several  States  have  conducted 
location  training  using  this  curriculum. 
OCSE staff  have  conducted  on-site  location  training  (with 
SSN  identification  as  an  integral  part  of  the  training)  i.n 
Arizona,  Indiana,  Michigan,  Prince  George~s  County,  and 
Philadelphia.  OCSE  staff  also  presented  sessions  on 
location  at  State  child  support  conferences  i.n  Alabama, 
California,  and  Florida.  Training  workshops  on  the  location 
function  were  also  conducted  at  the  two  largest  national 
training  conferences:  the  National  Child  Support 
Enforcement  Associations  and  the  Eastern  Regional  Child 
Support  Associations  Annual  Training  Conferences. 
In 1992,  OCSE  developed  a  program  review  protocol  which  was 
issued  in December to all Regional Offices for use in 
conducting program reviews of the location  function  (and  SSN 
i.dentifi.cation)  with  follow-up  technical  assistance  where 
appropriate. 
OCSE has recently  notified  State  CSE offices  of their 
ability  to submit  through  the Federal  CSE office  to the 
Social  Security  Administration  (SSA) SSN8S  for verification 
in SSAS Enumeration  Verification  System  (EVS) .  There  are 
two systems  offered  by the SSA that the States  may use.  The 
first is System  2121which will  provide  a State with 
multiple  SSNS  for an individual  who has been  legally  issued 
more than one SSN.  To date, System  212 has identified 
14,000 multiple  SSNS.  The second is l~System220fwhich 
will provide a corrected SSN in cases where the State has 
made a transposition or slight error in the SSN that they 
currently have for that individual.  To date, System 220 has 
provided 30,000 corrected SSN8S. 
OIG Recommendation: 
lb. The ACF, Office  of Child Support  Enforcement  should  evaluate 
the  usefulness  of  information  available  through  the  Federal 
Parent  Locator  Senice  (FP123),  and  provide  necessary 
assistance  to  local  CSE  offices  searching  for  military 
absent  parent  social  security  numbers. 
ACF Comment: 
We  concur in that we are constantly evaluating the 
usefulness of the information available through the FPLS. 
However,  the usefulness of the Lcapation  information is  . . 
Page 3 - Bryan  B. Mitchell 
dependent on several factors including the currency of the 
data received from other Federal agencies and how successful 
states are in following up on the information. 
Most Federal 
agency data bases that the FPLS accesses are updated at 
least annually. 
The FPLS receives SSN information from the Social Security 
Administration and address and employer information from the 
Internal Revenue,Senice,  the National Personnel Records 
Center, the Department of Defense, the Department of 
Veterans Affairs, the Selective Senice  System and the State 
Employment Security Agencies.  If SSA records indicate the 
person is in the military, the FPIS will automatically send 
the case to DOD. 
On an ongoing basis, OCSE provides technical assistance to 
local child support enforcement offices in the 
identification of SSNS, from automated matches with IRS and 
SSA, for all absent parents including those in the military. 
OIG Recommendation: 
l.c. The ACF,  Office  of Child  Support  Enforcement  should  continue 
to promote  the Child  Support  Enforcement  in the Military 
handbook. 
ACF Comment: 
We concur. 
With  two  inhouse  printings,  OCSE has distributed  the  lChild 
Support  Enforcement  in the Militaryihandbook to all State 
and local child support offices and has made copies 
available to military family senice  centers, and to 
worldwide offices of the American Red Cross.  This 
publication is included in OCSES list of available 
publications.  In an effort to further promote the handbook, 
OCSE arranged in 1992 for the handbook to be marketed and 
sold by the U.S. Government Printing Office. 
OIG Recommendation: 
l.d. The ACF, Office of Child Support Enforcement should 
establish and require the use of a standard form and a 
checklist for submission of wage withholding requests to the 
Defense Finance and Accounting Senice  Centers. 
ACF Comment: 
We  concur.  . 
Page 4 - Bryan B. Mitchell 
OCSE has identified a work group to develop a standardized 
form for wage withholding.  The work  group  consists  of  CSE 
staff at the Federal, Regional, 
State, and local level, as 
well as appropriate associations. The OCSE plans to submit 
the form to OMB for approval this fiscal year. 
OIG Recommendation: 
2. The ACF and the.Social Security Administration should 
collaborate to develop a better mechanism to assist CSE 
staff in obtaining social security numbers for absent 
parents. 
ACF Comment: 
we  concur.

Through  SSA,  the  FPLS  can  identify  SSN~s,  addresses,  and

employer  information.  Additionally,  as  previously

indicated,  SSNS  can  be  verified  through  the  SSA~s

Enumeration  Veri.ficati.on  System.

.- FEB12!933
TO: Bryan B. Mitchell 
Principal  Deputy Inspector General 
FROM : Acting  Assistant  Secretary 
for Planning  and Evaluation 
. ., 
SUBJECT : OIG Draft Report:  Child Support  and the Military, 
0EI-07-90-02250 
We have  reviewed  the above mentioned  draft  report  and agree that 
there  are additional  administrative  actions  that OCSE and state 
child  support  enforcement  agencies  can undertake  to improve the 
establishment  and enforcement  of child  support  in cases where  the 
non-custodial  parent is in the military. 
However,  we have several  concerns  about the specific  findings  in 
the report  and would like to raise an additional  concern  about 
your recommendation  that ACF/OCSE  and SSA develop  a better 
mechanism  for obtaining  Social Security  numbers  of noncustodial 
parents. 
First,  while  we agree that whenever  possible,  the ~litary  non-
custodial  parent  should provide  for the health  care  needs of 
their children  and that such military-provided  insurance  could 
potentially  reduce Hedicaid  costs,  the report  should  clearly 
state  that obtaining  such health care coverage  Wo uld not lead to 
9 reducti~n  ~  federal health care  ex~end itures .  CHAMPUS,  the 
program  designed  to provide  health  care for military  personnel 
and their  families,  is 100 percent  federally-financed  and has a 
broader  package  of coverage  than some state Medicaid  programs. 
This would  mean  that the Federal  Government  would  likely pick up 
more  of the cost for health  care under  CHAKPUS  than  under 
Medicaid.  In the long run,  health  care coverage  through  CHAMPUS 
might  help  some families with  high health  care costs,  leave ATDC, 
because  Medicaid  coverage  is no longer  needed.  However,  in the 
short-term,  there is likely  to be a reduction  in the federal 
share of Medicaid  costs but an overall  increase  in Federal 
Government  costs  as a result  of increased  provision  of health 
insurance  and care through  the military. 
Second,  while  the report correctly  indicates  that  several  factors 
beyond  thecontrol  of the CSE program  make the location  of some 
non-custodial  parents in the military  virtually  impossible,  the 
AFDC  (and Medicaid)  program  savings  are  computed  as  if  ~  of 
these  absent  parents  could  be  located.  The  potential  program 
savings  should  reflect  the  less  than  100  percent  locate  rate  that 
the  report  elsewhere  indicates  is  realistic.  , 
. 
Page 2 - Bryan B. Xitchell 
Third, the report indicates that military personnel allege that 
the problems in processing wage-withholding orders are mainly the 
result of improper handling of the CSE agency.  What the report
fails to mention is that some of the problems related to wage-
withholding stem from inconsistencies between the federal law 
permitting garnishment in the military, which was passed in 1982, 
and the general child support wage withholding statutes passed in 
1984 and 1988. The,1982  statute only permd.tsgarnishment 
(involuntary wage-withholding) after 2 months arrears and places 
other limitations on enforcement action.  Under the 1988 statute, 
immediate withholding, without any accumulation of arrears, was 
mandatory in IV-D cases beginning in 1991.  An example of the 
confusion which might result from these separate statutes is that 
military personnel cite as  a  frequently missing item, a 
certified copy of the arrearage support order.  According to the 
1984 law, it is not necessary to go back to court for  such  an 
order,  and  according  to  the  1988  law,  it  i.s  not  necessav  for 
there  to  be  an  explf.cit  request  for  wage-withholding  in  the 
initial  support  order.  It  may  be  impossible  to  clear  up  the 
confusion  between  military  personnel  and  CSE staff until the 1982 
law is amended  and/or military  regulations  are brought  into 
conformance  with subsequent  legislation. 
Lastly,  the report recommends  that ACF  and SSA develop  a better 
mechanism  forobtaining  Social  Security  numbers  for absent 
parents.  While we support  any collaboration  which could  make the 
system work better, we would  like to point  out that safeguards 
have to remain  in place in order to protect  individual  privacy 
and the integrity of the Social Security  system.  Unknown  SSNS 
can be provided  only when  the CSE agency,  based on information 
from the,custodial  parent,  can furnish  several other pieces  of 
information  which are kept as part of the Social Security 
records.  These include some combination of: the non-custodial 
fathers legal name, his date of birth, his place-of birth, and 
the names of his mther  and father.  If the custodial parent does 
not know any of these items, release of a SSN or a number of 
possible SSNS, based solely on a name match, would be irresponsi
ble.  Attempts  to locate absent  parents  need to be balanced 
against  the reasonable  protection  of the privacy  of individuals 
within  the Social Security  system.   
If you have any questions, please  feel  free  to  call  Ann  Segal, 
Acting  Deputy  Assistant  Secretary  for  Human Services Policy 
(690-7148). 
..-...  r{ L 
_> 
+>+X .,,,, +a  Refer to  Memorandum 
Date: 
 .:=fzi!P/
. 
From: 
Acting  Commissioner  of ~ocial  Security 
Office of Inspector General Draft Report, Cthild Support and 
Subject: 
the Military  (OEI-07-90-02250)--INFO~TION 
To:  Bryan  B. Mitchell
Principal  Deputy  Inspector  General
Attached  is our response  to the subject  report. 
If we can be
of further  assistance,  please  let us know.
Attachment:
SSA Response
.  COMMENTS  OF THE  SOCIAL SECURITY  ADMINISTRA TION ON THE OFFICE  OF
INSPECTOR  GENERAL  DRAFT REPORT,  CHILD  SUPPORT AND THE MILITARY
(OEI-07-90-02250)
Office  of Inspector  General  (OIG) Recommendation
The Administration  for Children  and  Families  (ACF) and the Social
Security  Administration  (SSA) should  collaborate  to develop  a
better  mechanism  to assist  the Office  of Child Support
Enforcement  (OCSE) staff  in obtaining  Social  Security
numbers  (SSN) for absent parents.
SSA Response
We agree  and are currently  working  with  OCSE to develop  a better
mechanism  to obtain  SSNS for absent  parents.  The Federal  Parent
Locator  Service  (FPLS) within  OCSE  is conducting  a study  to see
if a different  SSA system  could  provide  SSNS to them.  The Alpha
Search  routines  of the Enumeration  Verification  System  may be a
better  mechanism  for locating  SSNS  for these  cases,  since  they
would  not require  as many data  elements  as the FPLS  system.
On January  6, 1993, representatives  from SSA met with  OCSE  to
explore  ways  to better  serve OCSE  in obtaining  SSNS  for absent
parents.  A number  of options  for enhancing  this process  through
data  exchange  and other methods  will  be shared with  OCSE  in the
near  future.
Other  Matters
There  appears  to be a problem  on page  3 of the report  with  OIGS
estimate  that  51 percent  of the  360 cases  reviewed  showed  no
child  support  payments  being  made.  Either  an error  was made  in
the calculation  or States  that  have  a large number  of child
support  cases  in which  a branch  of military  senice  was listed  as
the absent  parents  place  of employment  have a higher  percentage
of cases  where  no child support  is being  collected  than do the
small  enrollment  States.  The  pie chart  on page 3 shows  that
143 of 275 sample  cases  represented  a weighted  percentage  of
51 percent  and  132 of 275  represented  a weiqhted  ~ercentaae  of 
21 percent.  If this  is so, It would be ben;ficia~ to she; State 
level data  for the eight  States  or,  alternatively,  quartile  data, 
so that  the reader  of the report  would  be aware of 
this disparity
in results  for large enrollment  States  as compared  to small 
enrollment  States. 
Additionally,  on page A-1 of the appendix,  the relative  precision 
number  under  the Unable  to Locate  column  for absent  parent  should 
be 12.8 percent  rather  than  45.5 percent.  Also,  the  confidence 
intervals  for whether  or not  a support  order was established  seem 
to be wider  than  one would  expect.