Department  of Health  and Human  Services 
OFFICE  OF 
INSPECTOR  GENERAL 
CHILD  SUPPORT  FOR  CHILDREN  IN 
STATE  FOSTER  CARE 
OEI-04-91-00980  OFFICE  OF  INSPECTOR  GENERAL 
The  mission  of the  Office of Inspector  General  (OIG),  as mandated  by Public  Law 95-452, as 
amended,  is to protect  the integrity  of the Department  of Health  and Human  Services (HHS) 
programs  as well as the health  and welfare  of beneficiaries  served  by those  programs.  This 
statutory  mission  is carried  out  through  a nationwide  network  of audits,  investigations,  and 
inspections  conducted  by three  OIG  operating  components:  the  Office of Audit  Services,  the 
Office of Investigations,  and the  Office of Evaluation  and Inspections.  The  OIG  also informs 
the  Secretary  of HHS  of program  and management  problems  and recommends  courses  to 
correct  them. 
OFFICE  OF AUDIT  SERVICES 
The  OIGS Office of Audit  Services  (OAS)  provides  all auditing  services for HHS,  either  by 
conducting  audits with its own audit  resources  or by overseeing  audit work  done  by others. 
Audits  examine  the  performance  of HHS  programs  and/or  its grantees  and contractors  in 
carrying out  their  respective  responsibilities  and are intended  to provide  independent 
assessments  of HHS  programs  and operations  in order  to reduce  waste,  abuse,  and 
mismanagement  and to promote  economy  and efficiency throughout  the  Department. 
OFFICE  OF INVESTIGATIONS 
The  OIGS  Office of Investigations  (01)  conducts  criminal,  civil, and administrative

investigations  of allegations  of wrongdoing  in HHS  programs  or to HHS  beneficiaries  and of

unjust  enrichment  by providers.  The investigative  efforts  of 01  lead to criminal  convictions,

administrative  sanctions,  or civil money  penalties.  The  01  also oversees  State  Medicaid  fraud

control  units which investigate  and prosecute  fraud  and patient  abuse  in the  Medicaid  program.

OFFICE  OF EVALUATION  AND  INSPECTIONS 
The  OIGS  Office of Evaluation  and Inspections  (OEI)  conducts  short-term  management  and 
program  evaluations  (called  inspections)  that  focus on issues of concern  to the Department, 
the  Congress,  and the public.  The  findings  and recommendations  contained  in these  inspection 
reports  generate  rapid,  accurate,  and up-to-date  information  on the  efficiency, vulnerability, 
and effectiveness  of departmental  programs. 
OEIS Atlanta  Regional  Office staff prepared  this report  under  the  direction  of Jesse  J. 
Flowers,  Regional  Inspector  General  and Christopher  Koehler,  Deputy  Regional  Inspector 
General.  Principal  OEI  staff included: 
Atlanta Region  Headquartm 
Maureen  Wilce, Project  Leader  David Wright

Ron  Kalil, Team  Leader  W. Mark  Krushat

Ruth  Reiser

Paula  Bowker

For additionalcopies of thii repoq please contact the Atlanta RegionalOffice by telephone, at 
(404) 331-4108, or by FM,  at (404) 730-2308.  EXECUTIVE  SUMMARY 
PURPOSE 
To  determine  potential  for  collecting  child  support  from  biological  parents  of children 
in State  foster  care  programs. 
BACKGROUND 
Foster  care  agencies  are  required  torefer  the  biological  parents  of children  infester 
care  to child  support  enforcement  agencies,  mdjijachilds  care  is funded  by Title 
IV-E  of the  Social  Security  Act.  To be  eligible  for Title  IV-E  foster  care,  a child must 
have  been  removed  from  a low income  family that  is eligible  for Aid to Families  with 
Dependent  Children  (AFDC).  However,  more  than  260,000 children  in foster  care 
nationwide  are  not  in the  Title  IV-E  foster  care  program.  These  children,  non-IV-E 
foster  care  children,  have  been  removed  from  homes  where  the  familys income  may 
be  substantially  higher  than  the  AFDC  limit.  Non-IV-E  foster  care  is funded  partially 
through  Title  IV-B in addition  to State  monies.  We  had  previously  issued  a report 
regarding  IV-E  children.  It is the  non-IV-E  children  who  are  the  subject  of this 
report. 
METHODOLOGY 
We  asked  nine  States  to  sample  children  in non-IV-E  foster  care  and  send  us basic 
identifying  information.  We  traced  this information  to State  child support 
enforcement  agencies  to determine  the  extent  of child support  collections.  We  also 
searched  Social  Security  Administrations  (SSA) Earning  Reference  Files  (ERF)  to 
calculate  the  potential  for biological  parents  of non-IV-E  foster  care  children  to pay 
child  support. 
FINDINGS 
Child Support  Was Collected  On Behalf Of 9 Percent  Of Non-IV-E  Foster  Care 
Children 
During  1991, Child  Support  Enforcement  agencies  collected  child support  payments 
from  parents  of 7 percent  (42) of the  593 non-IV-E  foster  care  children  in our  sample. 
This  represents  9 percent  of non-IV-E  foster  care  children  nationally. 
State Emphasis  On Collecting  Child Support  Is Low 
State  foster  care  agency  records  are  inadequate  for pursuing  child support  because 
foster  care  agency  caseworkers  do not  routinely  and  systematically  collect  basic 
information  needed  for pursuing  child support.  Only 35 percent  of parents  are 
referred  to child  support  enforcement  agencies  for possible  collections.  Since  few 
i  referrals  are  made,  and  information  on the  parents  is often  inadequate,  child support 
orders  are  established  for only about  12 percent  of non-IV-E  foster  care  children. 
StatesHave  Potential To  Increase Child Support  Collections  For Non-IV-E  Foster 
Care Children 
Many  parents  of children  in non-IV-E  foster  care  have  financial  resources  to pay child 
support  on behalf  of their  child.  Since, unlike  traditional  child support  cases,  children 
in foster  care  have  two absent  parents,  States  can increase  collections  by pursuing 
child support  from  both  parents.  States  also can  increase  child support  collections 
through  better  management  of the  child support  collection  process.  Management  of 
the  process  should  include  collecting  information  on all parents  of children  in 
non-IV-E  foster  care,  referring  the  parents  to  child support  agencies,  establishing 
support  orders  and  actually  collecting  child support  payments.  If child  support 
collections  were  made  on behalf  of just  half  of the  children  in non-IV-E  foster  care, 
$193,8 million  would  have  been  collected  in 1991.  Administrative  costs  of collecting 
child  support  would  reduce  the  amount  of collections  available  for improving  child 
welfare  services.  However,  the  administrative  costs to child support  enforcement 
agencies  can be  lessened  if foster  care  agencies  (1) obtain  adequate  information  on 
parents  when  a child enters  the  system,  and  (2) refer  all appropriate  cases  for  services. 
CONCLUSION 
Failure  to collect  child  support  on behalf  of non-IV-E  foster  care  children  decreases 
opportunities  to obtain  needed  resources  for providing  child welfare  services.  Since  no 
Federal  policies  mandate  that  child support  services  be  pursued  for children  in non-
IV-E  foster  care,  many  may believe  that  child support  cannot,  or should  not,  be 
pursued  on behalf  of these  children.  Because  of this, children  are  being  denied 
important  services,  such  as locating  absent  parents  and  paternity  establishment  which 
allows a child to have  inheritance  and  insurance  rights.  Additionally,  biological  parents 
may be  able  to provide  medical  insurance  which  covers  a childs medical  expenses. 
RECOMMENDATIONS 
We believe  foster  care  agencies  need  to  review  each  foster  care  case  to  determine  if 
pursuing  child  support  collections  is in  the  best  interest  of a foster  care  child.  Then, 
for those  foster  care  children  for whom  child support  is appropriate,  foster  care 
agencies  should  work  cooperatively  with  child support  agencies  to pursue  child support 
as a routine  part  of the  process  of building  parental  responsibility.  To  this end,  we 
have  two recommendations. 
The Administration  for Children and Families (ACF)  should encourage  States to 
extend child support  services to all children in foster care, regardless of the funding 
source  for a childs foster care.  They  can  do this by instructing  States  to improve  data 
gathering  and  referral  systems.  ACF  can provide  States  with  guidance  and  plans  to 
improve  coordination  between  foster  care  and  child support  programs.  ACF  can  also 
ii  seek  legislation  to require  child support  on behalf  of &l foster  care  children,  where 
appropriate.  Such legislation  should  be  the  same  as that  presently  in place  for 
children  in IV-E  foster  care. 
Other organizations  interested in foster care and child support  should also encourage 
States to seek child support  for non-IV-E  foster care children whenever  appropriate. 
Such  organizations  include,  but  are  not  limited  to, the  National  Governors  Association, 
the  National  Association  of State  Budget  Officers,  the  National  Conference  of State 
Legislatures,  the  National  Council  of State  Human  Services  Administrators  of the 
American  Public  Welfare  Association  (APWA),  and  the  Child  Welfare  League  of 
America  (CWLA). 
AGENCY  COMMENTS 
We  thank  ACF,  ASPE,  CWLA,  and  the  States  of Washington  and  New York  through 
the  APWA  for their  comments  on our  report.  They  agreed  with  our  findings  and 
recommendations,  although  ACF  and  ASPE  noted  that  whether  or not  to pursue  child 
support  collections  should  be  determined  on a case-by-case  basis.  We  made 
appropriate  revisions  in the  report  based  on their  comments.  We  present  the  full text 
of comments  in appendix  D. 
... 
111  TABLE  OF  CONTENTS

PAGE 
s~y 
EXE~ 
.1

INTRODU~ION  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
HNDINGS 
5 
Few  Child  Support  Collections&e  Made  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
5 
State  Emphasis  OnCollectingIs  Low  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
8 
Collections  Potentially  CanBe  Increased  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
..12

CON~USION  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
.  13 
RECOm~ATIONS  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
.  14 
AGENm  COm~  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
APPENDICES 
. ..  A-I 
Methodology  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
.  B-1 
The  Foster  Care  Process  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
.  c-1 
Estimation  Of Potential  Collections  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
. .  D-1

Agency  Comments  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  INTRODUCTION

PURPOSE 
To  determine  potential  for collecting  child support  from  biological  parents  of children 
in State  foster  care  programs. 
BACKGROUND 
This  report  describes  the  potential  for  collecting  child  support  for  foster  children  who 
are  not  eligible  for  the  Title  IV-E  foster  care  program.  Tobe  eligible  for Title  IV-E 
foster  care,  a child must  have  been  removed  from  a low income  family that  is eligible 
for Aid to Families  with  Dependent  Children  (AFDC).  While  no requirement  exists 
to report  the  number  of children  in foster  care,  estimates  show that  more  than  260,000 
foster  children  nationwide  are  not  in the  Title  IV-E  foster  care  program.  These 
children,  non-IV-E  foster  care  children,  have  been  removed  from  homes  where  the 
familys income  may be  substantially  higher  than  the  AFDC  limit. 
The  Child  Support  Amendments  of 1984 require  foster  care  agencies  to refer  Title 
IV-E  foster  children  for child support,  where  appropriate.  No such  requirement  exists 
for foster  children  who were  removed  from  homes  where  income  may exceed  AFDC 
eligibility  limits,  and who  are,  therefore,  ineligible  for the  Title  IV-E  foster  care 
program. 
In May  of 1992 the  Office  of Inspector  General  released  a report  on Child  Support 
Collections  for IV-E  Foster  Care  Children  (OEI-04-91-00530).  That  report  described 
the  extent  to which  States  collect  child support  on behalf  of Title  IV-E  foster  care 
children. 
At  the  Federal  level,  the  Administration  for Children  and  Families  (ACF)  within  the 
Department  of Health  and  Human  Services  (HHS)  administers  both  foster  care  and 
child  support  enforcement  programs.  Foster  Care  is operated  under  the 
Administration  for  Children,  Youth  and  Families  (ACYF).  Child  support  enforcement 
is operated  under  the  Office  of Child  Support  Enforcement  (OCSE). 
What Is Foster Care 
Foster  care  is temporary  removal  of a child to live with  someone  other  than  a parent 
or usual  caretaker  during  a time  of crisis in a family. 
Each  State  is responsible  for establishing  and  operating  foster  care  programs  under 
provisions  of Federal  statutes  and  HHS  guidelines.  Foster  care  agencies  provide  the 
following  services. 
1
 FOSTER CARE SERVICES

  Make Reasonable Efforts to Prevent Removal of Child From Parents 
  Remove Child from an Unsafe EnvironmentWhen Necessary 
  Place Child in Appropriate Foster Care 
b  Plan for Childs Long Term Welfare 
	 Where Appropriate, Refer Parent(s) and Child for Child Support 
serviees 
How Is Foster Care Funded 
Foster  care  is funded  through  Federal,  State  and  local promams.  Federal  funding  is 
available  primarily  under  two programs  -- Title  IV-E  and  ;itle  IV-B  of the  Social_ 
Security  Act. 
Title  IV-E  funds  foster  care  services  for  children  who would  be  eligible  to receive 
AFDC  if they were  living in the  home  of birth  parents  or specified  relatives  at the 
time  of removal  from  that  home.  Such funds  are  provided  to States  as an  entitlement. 
States  match  Federal  funds  for the  care  of each  Title  IV-E-eligible  child.  In FY  1991, 
the  Federal  share  reached  $1.8 billion. 
Title  IV-B funds  a variety  of State  child welfare  programs,  including  foster  care  for 
any child, regardless  of parents  income.  In FY  1991, the  Federal  government 
appropriated  $274 million  under  Title  IV-B for State  child welfare  service  grants. 
Each  State  grant  is based  on the  population  of children,  States  often  spend  Title  IV-B 
funds  on foster  care  for  children  not  covered  by Title  IV-E.  However,  State  and  local 
funds  are  the  primary  funding  mechanisms  for foster  care  for non-IV-E  eligible 
children. 
What Is Chili  Suppoti 
Child  support  is a monetary  payment  made  by an  absent  parent  to provide  for his or 
her  child.  An absent  parent  is one who is not  residing  in the  same  home  as a child. 
Each  State  establishes  and  operates  child support  programs  under  provisions  of 
Federal  statutes  and  HHS  guidelines.  Child  support  enforcement  agencies  open  a 
case  on an absent  parent  when  they receive  a request,  or referral,  for services  on 
behalf  of a child.  Once  a case  is opened  a child support  agency  provides  the  following 
services. 
2
 CHILD SUPPORT SERVICES 
  Locate Parents 
  EstablishPaternity 
  Obtain a Child Support Order 
  Colkxt and Distniute Child Support 
What Are Federal Requirements For I?.muing Child Support 
Title  IV-D  of the  Social  Security  Act  created  the  child support  enforcement  program 
in 1975.  This  legislation  authorized  child  support  agencies  to  obtain  support  orders 
and  collect  child support  on behalf  of all children  included  in an AFDC  grant.  The 
program  goals  are  to (1) increase  family  (parental)  responsibility,  and  (2) reduce  costs 
of public  assistance  for taxpayers,  especially  AFDC  costs. 
The  1984 Child  Support  Amendments  Act  required  child support  for  one  class of 
foster  care  children  -- those  that  meet  AFDC  eligibility  criteria  and  are,  therefore, 
covered  under  Title  IV-E.  The  1984 amendments  to the  Act  required  foster  care 
agencies  to refer  the  biological  parents  of children  in Title  IV-E  foster  care  for child 
support  where  appropriate.  Any child support  that  is collected  must  be  distributed 
to appropriate  State  and  Federal  foster  care  agencies  to offset  costs  of foster  care. 
The  1984 Amendments  also  allowed  child support  services  to be  extended  to  anyone 
requesting  the  services.  This  theoretically  allowed  services  to be  provided  to children 
in non-IV-E  foster  care,  provided  that  someone  requests  such  services.  However,  the 
1984 amendments  do not  reauire  foster  care  agencies  to refer  biological  parents  of 
non-IV-E  foster  care  children  for child support. 
Like  Title  IV-E  foster  care  children,  both  parents  of non-IV-E  foster  care  children  no 
longer  have  custody  of their  child.  Unlike  Title  IV-E  children,  the  parents  of non-lV-
E foster  care  children  may have  incomes  or assets  that  are  sufficiently  high so as to 
disqualify  them  for AFDC. 
METHODOLOGY 
To  determine  potential  for collecting  child support  for non-IV-E  foster  care  children, 
we randomly  selected  10 States  with probability  proportional  to size.  Title  IV-B 
allocations  to States  for FY  1991 determined  size.  Nine  States  responded  to  our 
requests  for information  within  our  study time  frame.  We  conducted  our  review 
between  March  and  November  1992. 
3

  From  each  of the  nine  State  foster  care  agencies,  we requested  a random  sample  of 70 
non-IV-E  foster  care  children,  as of December  31, 1991.  The  9 States  furnished  the 
names  of 630 foster  care  children.  Thirty-seven  of the  sampled  children  did not  meet 
our  criteria,  leaving  us with  a sample  size of 593 children. 
Next, we determined  if child support  was pursued  for the  sampled  children.  We  used 
a standardized  data  collection  instrument  to request  names,  Social  Security  numbers 
and  dates  of birth  for sampled  foster  care  children  and  their  biological  parents.  After 
receiving  the  information,  we contacted  each  State  child support  enforcement  agency 
to  determine  if any parents  of the  children  had  been  referred  to a child  support 
enforcement  agency  and  the  status  of any cases  that  had  been  referred.  If collections 
were  made,  we requested  information  on how the  money  was distributed. 
To  determine  1991 earnings  by parents  of sampled  foster  care  children,  we matched 
each  parents  Social  Security  number,  when  available,  with Social  Security 
Administrations  (SSA)  Earning  Reference  Files  (ERF).  We  then  calculated  the 
amount  of funds  available  to foster  care  agencies  if they  pursued  child  support  from 
biological  parents.  We  used  a child support  formula  of 17 percent~  of earnings  to 
estimate  potential  funds  available  for child support.  To  estimate  potential  child 
support  collections  nationwide,  we weighted  our  sample  results  to represent  non-IV-E 
foster  care  children  nationally. 
Appendix  A fully describes  our  data  collection  and  analysis  methods. 
We  conducted  our  review  in accordance  with the  Quality Standards for Inspections 
issued  by the  Presidents  Council  on Integrity  and  Efficiency. 
~Federal guidelines  allow States wide latitude  in what formula  to use in collecting 
child support.  As  a result, States have selected  a wide variety of formulas,  and  we could 
not find  a child support formula  that  was applicable  in all States.  Therefore, to estimate 
potential  for  collecting child support for  non-%E  foster  care children,  we chose one of 
the simplest  child support formulas  - 17percent  of earnings,  T}zisfo~mula  is currently 
being used in Wisconsin.  Actual  child support collections  will vaiy by State  depending  on 
their respective child support formulas  and specific factors  of each foster  care case. 
4  FINDINGS

CHILD  SUPPORT  WAS  COLLECTED  ON  BEHALF  OF  9 PERCENT  OF 
NON-IV-E  FOSTER  CARE  CHILDREN 
During  1991, Child  Support  Enforcement  agencies  collected  support  payments  from 
parents  of 7 percent  (42) of the  593 non-IV-E  foster  care  children  in our  sample.  This 
represents  9 percent  of non-IV-E  foster  care  children  nationally.2  About  4 percent 
(52)  of the  1186 biological  parents  of the  593 foster  children  paid  child  support.  Both 
parents  paid  child  support  for only 10 of the  42 children.  For  the  remaining  32 
children,  only one  of their  parents  paid  support  on their  behalf. 
Some  States  were  more  successful  than  others  in collecting  child  support  from  parents 
of non-IV-E  foster  care  children.  Two  of the  nine  States  in our  sample  accounted  for 
about  71 percent  of the  child support  collected.  Three  States  accounted  for 29 
percent  and  4 States  collected  no child support  for sampled  non-IV-E  foster  care 
children. 
STATE  EMPHASIS  ON  COLLECTING  CHILD  SUPPORT  IS LOW 
State Foster Care Agency Recor&  Are Inadequate For l%rsuing Ckikl Support 
Foster  care  agency  caseworkers  do not  routinely  and  systematically  collect  basic 
information  needed  for pursuing  child support.  To  illustrate,  State  foster  care 
agencies  could  provide  us with  the  names  of about  70 percent  (830)  of the  1186 
parents  of foster  care  children  in our  sample.  Likewise,  they  had  dates  of birth  for 
only 57 percent  of the  parents  and  Social  Security  numbers  for only 48 percent  of the 
parents. 
Child  support  enforcement  staff  often  had  more  information  than  foster  care  agency 
staff on parents  of foster  care  children.  In some  instances,  child support  enforcement 
agency  staff had  established  a child support  case  before  a child was placed  in foster 
care,  To  illustrate,  child support  enforcement  agencies  were  able  to supply  us with  52 
names  of parents  who were  listed  as unknown  by appropriate  foster  care  agencies. 
Further,  child support  enforcement  agencies  furnished  us with  26 dates  of birth  that 
appropriate  foster  care  agency  staffs could  not  provide. 
2 In our sample,  we did not select the number  of cases in each  State propotiionate  to 
the number  of children in non-IV-E  foster  care.  To obtain  a more  accurate  national 
estimate,  our data  was weighted during analysis to reflect the variance  in non-IV-E  foster 
care populations. 
5
 Such basic  information  is essential  for collecting  child support,  and  for providing  other 
services  to the  families  of children  in foster  care  such as counseling  and  parental 
training.  Failure  to share  such needed  information  can limit  child support  that  helps 
defray  public  assistance,  and  it adversely  affects  the  provision  of child support  services 
to foster  care  children.  Further,  independently  collecting  the  same  information  results 
in inefficient  use  of staff time  and  resources  in both  foster  care  and  child support 
agencies. 
lldrty-jive Percent of Parents Are Referred To Chiki Support Enforcement Agencies  For 
Possible Collections 
Foster  care  agencies,3  a biological  parent,  AFDC  eligibility  offices,  or courts  referred 
29 percent  (349)  of the  1186 parents  of sampled  non-IV-E  foster  care  children  for 
child support.  This  projects  to 35 percent  of parents  nationally.  This  means  that  no 
attempt  was made  to collect  child support  from  65 percent  of the  parents  of non-IV-E 
foster  care  children.  Without  a referral,  child support  enforcement  agencies  cannot 
provide  services,  including  establishing  paternity,  locating  parents,  and  evaluating  a 
parents  potential  for contributing  to the  support  of his or her  child. 
35 Percent  of Parents Are  Referred 
To  Child Support Agencies 
ferred  35% 
Not  Referred  65 
Chikl Support Ordem Are Established For 12 Percent ~Non-IV-E  Foster Care Chikiren 
A child support  order  must  be  established  to collect  child  support  from  biological 
parents.  Child  support  agencies  had  established  support  orders  for  11 percent  (67) of 
the  593 non-IV-E  foster  care  children  in our  sample.  This projects  to  12 percent  of 
3 Records  at foster  care agencies were inadequate  for determining  the precise  number 
of referrals.  In practice,  child suppoti  agencies often  initiate  child support services without 
a referral from foster  care agencies. 
6  non-IV-E  foster  care  children  nationally.  A total  of 89 parents  were  ordered  to pay 
support  on behalf  of sampled  children.  This  represents  about  25 percent  of the  349 
parents  who were  referred  to child support.  Both  parents  were  ordered  to pay child 
support  on behalf  of 22 of the  67 children  for which  support  orders  were  established. 
i%wrzty-eightPercent Of Ihe  Refenvd  Foster Care Cases Are  Open But Incorrect& 
Classified 
Of the  349 parents  referred  to child support  enforcement  agencies,  28 percent  of the 
cases were  open  but  not  correctly  classified.  The  foster  care  agency was not  named  as 
the  custodia;  of the  child,  and,  therefore,  could  not  be  the  ulti%at;  recipient  of 
collections  made  on a childs behalf.  Some  of the  9 States  in our  sample  classified 
zero  cases  correctly  while  other  States  classified  as high as 92 percent  correctly. 
Thirty  percent  of the  cases were  closed  and,  therefore,  inactive.  Although  we did not 
assess reasons  for closure  as part  of this review,  some  cases  may have  been  closed 
because  pursuing  child  support  was not  considered  to be  in best  interests  of a child. 
The  remaining  42 percent  were  open  and  classified  as foster  care  cases.  For  these 
cases,  child  support  enforcement  agencies  indicated  that  services  were  appropriately 
provided.  The  chart  below  summarizes  the  classification  of sampled  non-IV-E  foster 
care  cases  referred  to  child support  enforcement  agencies. 
Status Of Non-IV-E  Foster  Care Cases Referred 
To  Child Support  Agencies 
Cases  Open  But  Incorrectly  Classified  28% 
Closed  Cases  30% 
Cases  Open  as Non-IV-E  Foster  Care  Cases  &J 
100% 
Correct  classification  helps  ensure  that  monies  collected  on behalf  of foster  care 
children  are  correctly  distributed  to the  foster  care  program.  Ultimately,  incorrect 
classification  resulted  in child support  paid  by 17 percent  of parents  being  incorrectly 
distributed.  We  describe  the  distribution  of child support  collections  in a companion 
management  advisory  report  titled  Incorrect  Distribution  Of Child  Support  Collected 
On  Behalf  Of Non-IV-E  Foster  Care  Children  (OEI-04-91-00981). 
7
 STATESHAVE POTENTIAL  TO  INCREASE  CHILD  SUPPORT  COLLECTIONS 
FOR  NON-IV-E  FOSTER  CARE  CHILDREN 
Many Parents Of Children In Non-IV-E  Foster Care Have Financial Resources  To Pay 
Chiki Support On Behalf Of Their Chiki 
The  children  in our  sample  were  not  eligible  for foster  care  under  Title  IV-E.  This 
may be  because  their  family income  and  assets  exceeded  AFDC  eligibility  limits. 
The  biological  parents  of about  44 percent  (263 of 593) of our  sampled  non-IV-E 
foster  care  children  reported  earning  a total  of 2.4 million  dollars4 in 1991.  To 
estimate  potential  child  support  we used  17 percent  of gross income.  Based  on  17 
percent  of their  income,  the  parents  of the  263 children  should  have  paid  a total  of 
$403,000  per  year  in child support  for their  children.  However,  they  actually  paid  a 
total  of $19,521.  This  represented  about  45 percent  of the  total  child  support 
collected  during  1991 for our  sampled  children. 
We were  unable  to determine  the  extent  that  parents  had  income  such  as disability 
compensation,  interest  income,  or dividend  income.  However,  55 percent  of the  total 
child support  actually  paid  for  7 percent  (42 of 593) of our  sampled  children  was paid 
by parents  who  either  reported  no earnings,  or whose  records  were  inadequate  to 
determine  earnings.  Child  support  from  these  parents  totaled  $23,386. 
States Can Increase Collections By Pumuing Child Support From Both Parents 
Most  States  historically  pursued  child support  from

only one  parent,  usually  the  father.  Non-IV-E

foster  care  children  potentially  have  two biological 
9

parents  who  may contribute  to their  support.  Child 
Foster  Care  Child

support  may be  collected  from  either  the  biological

mother,  the  biological  father,  or, in some  situations,

both  parents.  Nationally,  our  sample  shows that

some  States  do not  consider  or pursue  child support 
h+

payments  from  mothers.  However,  the  States  in

Blologlcal 
our  sample  that  are  most  effective  in collecting  child  Blologlcal

Father  Mother 
support  were  those  that  collected  from  both 
parents. 
4 Because  of inadequate  records, we could not determine  incomes for  the parents  of 
the remaining  56 percent  of our sampled  non-W-E  foster  care children. 
8  Sates  Can Increase Child Support Collections  lhrough Better Management  of the l+ocess 
Regardless  of the  type  of foster  care,  the  process  for collecting  child support  includes 
four  major  steps.  They  are 
o	 collecting  basic  information  on biological  parents,  such as name  and  Social 
Security  numbers, 
o  referring  parents  of foster  care  children  to child support  enforcement  agencies, 
o  establishing  child support  orders,  and 
o  collecting  child support. 
Appendix  B provides  detailed  information  on the  process  of placing  a child in foster

care  and  collecting  child support.

Failure  to carry  out  any one  of the  first three  steps  has  a direct  relationship  to the

amount  of child support  collected.  Despite  the  ability  of many  parents  to pay  child

support,  foster  care  agencies  frequently  do not  (1) collect  adequate  information  for

pursuing  child  support,  or (2) refer  foster  care  cases for  child  support  collection.  In

instances  where  foster  care  agencies  did refer  biological  parents  to child  support

agencies  for possible  collections,  child support  agencies  obtained  support  orders  for

only about  25 percent  of the  parents.  As a result,  States  collected  child  support  for

only about  9 percent  of non-IV-E  foster  care  children.

Two  of the  nine  States  in our  sample,  Washington  and  North  Carolina,  showed  that

better  management  of each  step  in the  process  does  increase  overall  collection  of child

support.  For  example,  each  of the  2 State  foster  care  agencies  recorded  basic

information  such  as parents  name  for over  90 percent  of the  parents  as compared  to

70 percent  for the  States  overall.  They  also referred  almost  60 percent  of the  parents

to child support  agencies  for possible  collections  as compared  to 29 percent  overall  for

the  9 selected  States.  As a result,  child support  agencies  in the  2 States  collected  child

support  from  over  15 percent  of the  parents  of non-IV-E  foster  care  children.

Overall,  the  9 States  in our  sample  collected  child support  from  about  4 percent  of the

parents  of non-IV-E  foster  care  children.

9
 The  following  chart  illustrates  the  potential  for improvement  in each  of the  four  key 
steps  for collecting  child support  on behalf  of non-IV-E  foster  care  children.  Based  on 
our  sample,  the  blackened  area  shows States  current  performance  in each  step  toward 
collecting  child  support  on behalf  of foster  care  children.  The  white  area  shows the 
extent  of opportunity  to improve  performance. 
Opportunity  to Improve 
Child Support  Collections 
% 
100 
8.Q.....4~.... ........l...... .......................
...............................
60 
....4...... .............. ......... ........ 
4
40	
89% 
93% 
20 
0 
Names  SSNS

Support 
Basic  Information  Referral  Collections 
On  Parents  Orders 
- current  I  I Potential  for 
Performance  Improvement 
10
 Estirnute ~  Potential Child Supp~  Collections 
our  sample  of 593 children  represented  over  260,000 children  in non-IV-E  foster  care 
nationwide.  Because  our  random  sample  was stratified,  each  of our  sampled  children 
represented  a different  percentage  of the  universe.  To  estimate  potential  child 
support  collections,  we weighted  our  sample  results  to represent  non-IV-E  foster  care 
children  nationwide.  The  following  chart  shows our  sample  and  weighted  results. 
Sampled  Weighted 
Results  Results 
Number  of Children  in Non-IV-E  Foster  Care  593  260,000 
Percent  of Children  on Whose  Behalf  Child 
Support  Is Collected  7%  9% 
Percent  of Children  Included  in a Support  Order  1170  12% 
I  I 
Percent  of Parents  Referred  to Child  Support  I  29V0  I  35940 
The  table  on the  next  page  shows possible  child support  collections  nationwide  that 
could  have  been  collec~e~ in  1991 if child support  wire  pursued  on behalf  of non-IV-E 
foster  care  children.  We  assumed  all parents  of foster  care  children  have  incomes  and 
ability  similar  to the  parents  of the  children  in our  random  sample. 
We  know,  however,  that  both  biological  parents  of every  child in non-IV-E  foster  care 
will not  be  identified  and  located.  Further,  some  parents  that  are  located  will be 
unable  to pay child support  because  of inadequate  income.  Finally,  in some  situations 
it is not  in the  best  interests  of a child to pursue  child support  collections.  For  these 
reasons  and  because  the  child support  collections  formula  varies  by State,  we 
conservatively  limit  our  estimate  of potential  child support  collection,  as shown  in the 
table  on the  next  page.  If child support  collections  were  made  on behalf  of half  of the 
children  in non-IV-E  foster  care,  $193.8 million  would  have  been  collected  in 1991. 
Administrative  costs of collecting  child support  would  reduce  the  amount  of collections 
available  for improving  child welfare  services.  However,  the  administrative  costs  to 
child support  enforcement  agencies  can be  lessened  if foster  care  agencies  (1) obtain 
adequate  information  on parents  when  a child enters  the  system,5 and  (2) refer  all 
appropriate  cases  for services. 
s T~te administrative  cost of collecting this information  would  be minimal  because 
foster  care caseworkers generally obtain  information  on biological paren~s as part  of their 
services to the family.  Howeveq  the caseworker  do not enter this info~mation  into a 
system which  can be accessed by child support enforcement  stajf 
11
 ESTIMATE  OF POTENTIAL  CHILD  SUPPORT  COLLECTIONS 
Percent  of Children  On 
Whose  Behalf  Child 
Support  Is Collected  50%  4090  30%  20%  15%  10YO 
Possible  Collections 
(in millions)  $193.8  $154.4  $115.8  $77.2  $57.!?  $38.6 
The  shaded  column  shows possible  collections  if all States  achieved  the  15 percent 
collection  rate  for non-IV-E  foster  care  children  that  2 States  in our  sample  are 
already  achieving.  However,  we believe  an even  higher  percentage  of parents  can  pay 
child support,  and  the  amount  of possible  collections  would  be  higher  as well. 
Appendix  C shows in detail  how we calculated  estimated  child support  collections. 
CONCLUSION 
Federal  law requires  pursuit  of child support,  where  appropriate,  from  parents  of 
children  in foster  care  who  are  removed  from  low income  families.  However,  no such 
law exists to require  child support  from  parents  with higher  incomes. 
Failure  to collect  child support  on behalf  of non-IV-E  foster  care  children,  where 
appropriate,  decreases  opportunities  to obtain  needed  resources  for providing  child 
welfare  services.  Since  no Federal  policies  mandate  that  child support  services  be 
pursued  for  children  in non-IV-E  foster  care,  many  may believe  that  child  support 
cannot,  or should  not,  be pursued  on behalf  of such  children.  Because  of this, children 
are  being  denied  important  services,  such  as paternity  establishment  which  allows a 
child to have  inheritance  and  insurance  rights.  Additionally,  biological  parents  may be 
able  to provide  medical  insurance  which  covers  a childs medical  expenses.  Even  in 
situations  where  child support  is pursued,  lack  of established  procedures  often  results 
in misclassification  of cases. 
Foster  care  agencies  should  review  each  foster  care  case  and  determine  if pursuing 
child support  is in the  best  interest  of a foster  care  child.  In instances  where  it is 
considered  appropriate,  each  case  should  be  referred  to child support  for  collection. 
Child  support  agencies  should  work  cooperatively  with foster  care  agencies  to pursue 
child support,  where  appropriate,  as a routine  part  of the  process  of building  parental 
responsibility.  To  do this, States  may choose  to better  manage  or change  their  systems 
so that  child  support  will be  pursued  on behalf  of all children  in foster  care. 
12
 RECOMMENDATIONS 
Recommendation  1:  ACF  should encourage  States to extend child support  services to 
all children in foster care, regardless of the funding source.  Some  options  for ACF  to 
accomplish  this are  discussed  below. 
Option  1:  Extend  written  instructions  to States  to include  all foster  care  children 
regardless  of the  funding  source.  Such instructions  should  encourage  State 
foster  care  agencies  to record  names,  dates  of birth  and  Social  Security 
numbers  for both  biological  parents  of children  in foster  care, 
foster  care  agencies  to review  each  foster  care  case  to determine  if pursuing 
child support  collections  is in the  best  interest  of a child, 
foster  care  agencies  to refer  all appropriate  biological  parents  of foster  care 
children  to IV-D  child support  enforcement  agencies  for  establishing  child 
support  orders  and  collecting  child support,  and 
foster  care  agencies  and  child support  enforcement  agencies  to develop  a 
Memorandum  of Understanding  determining  appropriate  cases  for referral,  and 
gathering  and  exchanging  data. 
Option  2:  Provide  specific  guidance  and  plans  to States  for  coordinating  foster  care

and  child  support  programs,  such as including  a data  exchange  link between  foster

care  and  child  support  enforcement  records  when  developing  or modifying  automated

systems,  and  providing  child support  enforcement  agencies  with  a model  system  for

classifying and  processing  child  support  cases.

Option  3:  Seek  legislation  requiring  the  pursuit  of child support  on behalf  of

non-IV-E  foster  care  children,  where  appropriate,  The  legislative  requirement

should  conform  to that  presently  in place  for the  children  in IV-E  foster  care.

Recommendation  2:  Organizations  interested in foster care and child support  should

encourage  States to seek child support  for non-IV-E  foster  care children whenever

appropriate.  Such  organizations  include,  but  are  not  limited  to, the  National

Governors  Association,  the  National  Association  of State  Budget  Officers,  the  National

Conference  of State  Legislatures  and  the  National  Council  of State  Human  Services

Administrators  of the  American  Public  Welfare  Association.

13
 AGENCY  COMMENTS 
The  Administration  for Children  and  Families  (ACF)  generally  agreed  with  the  focus

of our  recommendations.  ACF  noted  however,  that  our  recommendation  on child

support  services  should  be  qualified  to recognize  that  in some  instances  it would  not

be  good  practice  to collect  child support  from  parents  of children  in foster  care.  The

ACF  welcomes  assistance  and  participation  from  national  organizations  interested  in

encouraging  States  to seek  child support  on behalf  of foster  care  children  whenever

appropriate.

The  Assistant  Secretary  for Planning  and  Evaluation  (ASPE)  agreed  with  our

recommendations.  The  ASPE  noted  that  child support  collections  should  only be

initiated  when  it would  support  a foster  care  agencys case  plan  for a foster  care  child.

We  highlighted  this objective  in our  report.  Whether  to pursue  child support

collections  or not  should  be  determined  on a case-by-case  basis  by a foster  care

agency.  The  foster  care  agency  should  then  contact  the  child support  agency  to

pursue  collections.

The  Child  Welfare  League  of America,  Inc. (CWLA)  noted  that  our  report  makes  a

case  for stronger  collaboration  between  foster  care  agencies  and  child  support

enforcement  agencies.  Further,  such collaboration  will enhance  the  financial  base  for

providing  services  to children  in foster  care  and  promote  greater  parental

responsibility.  The  CWLA  agreed  with  our  recommendations  and  are  willing to work

with the  National  Governors  Association  and  the  American  Public  Welfare  Association

in encouraging  States  to seek  child support  for non  IV-E  eligible  children  in foster

care.

The  American  Public  Welfare  Association  (APWA)  received  comments  on  our  report

from  the  (1) State  of Washington  agency  that  administers  the  child support  program,

and  (2) State  of New York  agency  that  administers  both  the  foster  care  and  child

support  program.  The  State  of Washington  is identified  in our  report  as one  that  has

had  success  in collecting  child support  on behalf  of foster  care  children.  They

commented  that  foster  care  agencies  need  to work  cooperatively  with  child  support

agencies  as a routine  part  of the  process  of building  parental  responsibility.  They

concurred  with  our  point  that  improvements  in data  gathering  will ameliorate  many  of

the  information  gaps  that  presently  inhibit  effective  case  management.  The  State  of

New York  also supports  our  recommendations.  They  believe  our  recommendations

are  consistent  with  current  Federal  and  State  government  efforts  to implement  welfare

reform  and  its emphasis  on parental  responsibility.  New York  noted  its experience

that  child  support  collections  on behalf  of State  foster  care  children  provide  significant

reimbursement  to the  State  for expenses  it incurs  in providing  child welfare  services.

14
 APPENDIX  A

METHODO~GY 
Sample Selection 
Since  no accurate  count  of children  in foster  care  exists, we used  a listing  of Title  IV-B 
appropriations  to establish  our  universe.  We  selected  10 States  with probability 
proportional  to the  appropriation  amounts  for Title  IV-B  as our  national  sample.  One 
State,  Massachusetts,  chose  not  to participate.  This  reduced  our  sample  to the 
following  nine  States:  California,  Ohio,  Florida,  South  Carolina,  Illinois,  Washington, 
North  Carolina,  Nevada,  and  Texas. 
We  asked  foster  care  officials  in each  sampled  State  to select  a random  sample  of 70 
cases  from  a universe  of children  who had  been  in foster  care  for at least  6 months  as 
of December  31, 1991.  States  were  instructed  to use  the  same  sampling  procedures 
used  to sample  for reviews  conducted  by ACF.  We  requested  States  not  to include 
foster  care  children  funded  under  Title  IV-E  in the  sample.  We verified  the 
randomization  method  used  by the  States  prior  to actual  sample  selection.  We 
conducted  our  review  between  March  and  November  1992. 
Information  Collection 
Using  standardized  forms,  we requested  names,  Social  Security  numbers  and  dates  of 
birth  for both  the  foster  care  children  appearing  in our  sample,  and  their  biological 
parents.  We  received  information  on 630 children;  however,  we excluded  37 from  our 
sample  because  they  had  been  classified  as eligible  for Title  IV-E  financial  support. 
State  foster  care  officials  provided  us with the  names,  addresses,  Social  Security 
numbers,  and  birth  dates  for each  of the  remaining  593 sampled  children  and  their 
biological  parents. 
We  contacted  State  child support  enforcement  agencies  in each  of the  9 States  to 
determine  which  parents  of the  593 foster  care  children  had  been  referred  to a IV-D 
child support  enforcement  agency.  We  asked  child support  enforcement  agencies  for 
detailed  information  on any established  cases.  Using  standardized  forms  we asked 
whether  a case was currently  open,  how it was classified,  what  services  had  been 
performed  in the  cases, whether  a child  support  order  was established,  and  whether 
collections  were  being  made.  If collections  were  made,  we requested  information  on 
how the  money  was distributed. 
Using  the  Social  Security  Administrations  (SSA)  Earning  Reference  Files  (ERF),  to 
determine  earned  income,  we calculated  potential  child support  that  could  be  paid  by 
biological  parents  of sampled  children.  We  used  a child support  formula  of 17 percent 
of earnings  to  estimate  potential  funds  available  for child  support. 
A-1
 APPENDIX  B

THE  FOSTER  CARE  PROCESS 
After  a child is removed  from  a home  - occasionally  by the  police  or linked  child 
protection  authorities  - the  child is placed  in some  type  of emergency  care.  A removal 
order  is signed by a court  official  and  a more  permanent  place  for the  child  is found. 
Some  States  and  localities  also  allow parents  to voluntarily place  their  children  in 
foster  care. 
The  preferred  placement  is usually  in the  least  restrictive  and  most  homelike  setting 
where  a child will be  cared  for by foster  parents.  Usually  foster  parents  are  certified 
volunteers  who  take  children  into  their  homes.  Maintenance  payments  are  for 
expenses  directly  related  to care  and  lodging  for  eligible  children.  An  eligibility 
determination  is made  to determine  which  funding  sources  will cover  the  cost  of foster 
care. 
Local  foster  care  agencies  work with the  former  custodial parent(s)  - usually the 
biological  parent(s)  who last had legal custody of a child - to develop  a permanency 
plan.  The  permanency  plan is a step-by-step  action plan to determine  what will 
happen  with a child.  In accordance  with the Adoption  Assistance  and Child Welfare 
Act  of 1980, the majority of permanency  plans are designed  to return a child to the 
former  custodial parent(s)  as soon  as possible. 
Occasionally,  a foster  care  worker  (or  a parent)  will determine  that  a child can  never

return  home.  This  determination  is usually  reached  because  problems  causing  removal

are  extreme  and  insurmountable.  For  many  such cases  the  permanency  plan  will be

adoption.  For  adoption  to take  place,  proper  legal  proceedings  must  terminate

parental  rights  of both  parents.  This  termination  can be voluntary  or involuntary.  If a

parent  is absent  and  his or her  whereabouts  are  unknown,  a diligent  search  must  be

made  to satisfy legal  requirements  before  a child can be  eligible  for adoption.

A childs case  must  be  reviewed  every  six months  and  the  permanency  plan  updated.

The  familys progress  towards  improving  the  home  situation  is tracked  by an  assigned

foster  care  case worker.  In cases  of voluntary  placements,  a child must  be  returned  to

the  parent(s)  upon  his/her  request,  or the  agency  must  seek  court-ordered  custody.

Coordination  between  foster  care  and  child support  programs  begins  with  a referral

from  a foster  care  agency.  The  child  support  enforcement  agency  attempts  to locate

an  absent  parent(s).  An  absent  parent  is a biological  parent  not  residing  in the

home  the  child  is in.  Paternity  will be  established  if necessary.  The  child  support

enforcement  agency  will go through  the  court  proceedings  to establish  a support  order.

A support  order  is an  order  issued  by a court  requiring  an absent  parent(s)  to provide

child  support.  The  agency will then  collect  monies  from  the  absent  parent(s)  and

distniute  them  in accordance  with  the  courts  ruling  and  Federal  regulations.

B-1  APPENDIX  C

ESTIMATION  OF POTENTIAL  CHILD  SUPPORT  COLJ..JXXIONS 
Recompleted  anearnings  search  on317parents,  or26.7percent  of the  1186  possible 
parents  of children  in our  sample.  The  reason  for  alowpercentageof  parents  with 
reported  earnings  is that  foster  care  records  lack  the  basic  information  on  parents, 
such  as  names  and  Social  Security  numbers  (SSNS).  For  example,  foster  care  agencies 
were  able  to  provide  us with  836  names  of parents  and  570  SSNS  for  1186  parents  in 
our  sample.  Further,  some  of the  information  we  did  receive  was  invalid,  e.g.  the  SSN 
did not  match  the  name. 
Data  obtained  from  the  Social  Security  Administration  showed  the  317 parents  earned

$~372,800  during  1991.  Because  of State  variations  in formulas  used  for  calculating

child  support,  we could  not  find a formula  that  was applicable  to all States.

Therefore,  we based  our  estimate  on  17 percent  of income  -- a formula  used  by

Wisconsin.  This  calculation  showed  that,  theoretically,  $403,376  could  have  been

collected  by child  support  enforcement  agencies  from  317 biological  parents  of

sampled  children  in foster  care  during  1991.

We  chose  the  17 percent  for several  reasons.  First,  we could  not  obtain  consensus 
among  ACF  officials  on what  percentage  to use.  Several  ACF  officials  referred  us to 
Wisconsin  which  uses  17 percent  of income  for child support.  Second,  regardless  of 
what  percent  we used,  potential  collections  would  not  be  precise  for  each  State. 
Actual  collections  vary by State  depending  on their  individual  child  support  formulas. 
Third,  collections  vary depending  on numerous  factors  unique  to each  individual  case. 
Therefore,  we could  not  account  for all the  possible  factors  affecting  collections. 
National  projection  of possible  child support  collections 
To  estimate  how much  could  be  collected  nationally,  if child support  were  pursued  on 
behalf  of children  in non-IV-E  foster  care,  we made  several  assumptions. 
First,  we do not  have  an exact  number  of children  in non-IV-E  foster  care.  Several 
estimates  place  the  total  number  of children  in non-IV-E  foster  care  in 1991 nationally 
to be  over  260,000.  Assuming  this number,  each  child has  2 parents  for  a total  of 
520,000 parents  who  could  possibly  support  their  child. 
We  assumed  all biological  parents  of foster  care  children  have  earned  incomes  similar 
to  the  317  parents  of children  in  our  random  sample.  Further,  we  assumed  a child 
support  formula  used  would  approximate  17 percent  of earned  income. 
We  know,  however,  that  both  parents  of every  child in non-IV-E  foster  care  will not 
be  identified  and  located.  Further,  some  parents  that  are  located  will be  unable  to 
pay child  support  because  of inadequate  income.  Finally,  in some  situations  it is not 
c-1  in the  best  interests  of a child to pursue  child support  collections.  In the  Title  IV-E 
foster  care  program,  for  example,  parents  are  referred  to  child support  enforcement 
agencies  for possible  collections  where  appropriate.  We believe  a similar  standard 
should  be  applied  for  children  in non-IV-E  foster  care.  In situations  where  a childs 
safety  or w~l~-being would  be jeopardized,  child support  should  not  be  pursued.  In 
foster  care  cases  where  parental  rights  are  to be  quickly terminated,  pursuing  child 
support  collections  could  also be  inappropriate. 
The  table  below  shows possible  child support  collections  which  could  have  been 
collected  in  1991 if child support  were  pursued  from  specific  percentages  of the 
520,000 parents  of non-IV-E  foster  care  children. 
Estimate  of Potential  Child  Support  Collections 
For  Non-IV-E  Foster  Care  Children  in  1991 
Percent  of Children 
On Whose  Behalf  50%  4070  30%  20%  15%  10% 
Child  Support  Is 
Collected 
Possible  Collections 
(in millions)  $193.8  $154.4  $115.8  $77.2  $57.9  $38.6 
The  dollar  figures  shown  above  are  based  only on biological  parents  earned  income. 
Other  income  sources,  such  as disability  payments,  dividends  or investment  income  can 
also be  used  to pay child support.  In our  sample  over  half  (55 percent)  of the  child 
support  actually  paid  in 1991 came  from  parents  who had  no reported  earned  income. 
Additionally,  biological  parents  may be  able  to provide  medical  insurance  which  covers 
a childs medical  expenses. 
c-2  APPENDIX  D

AGENCY  COMMENTS 
ADMINISTRATION  FOR  CHILDREN  AND  FAMILIES

ASSISTANT  SECRETARY  FOR  PLANNIN G AND  EVALUATION

CHILD  WELFARE  LEAGUE  OF AMERICA  INC.

AMERICAN  PUBLIC  WELFARE  ASSOCIATION

D-1
 . 
*$--, 
*4 #  4.%   
*4   DEPARTMENTOFHEALTH&HUMANSERVICES

5: 
s

%
  
*+.
ADMINISTRATION  FOR CHILDREN  AND FAMILIES 
Office of the Assistant  Secreta~,  Suite 600 
370 LEnfant Promenade, S.W. 
March  29,  1994  Washington,  11.C. 20447 
15 
d 
me 
To:	 June  Gibbs  Brown  PDIG 
Inspector  General 
%?  5 
mG4X
From:  Mary  Jo  Bane 
Ax_J  = 
~%~ 
Assistant  Secretary  for 
\ 
Children  and  Families 
DATE  SENT  ~ 
Sub]  ect:	 Comments  on  Office  of  Inspector  General  Draft  Report: 
Child  Support  for  Children  in  State  Foster  Care, 
OEI-04-91-00980 
Thank  you  for  the  opportunity  to  submit  comments  on  your  draft 
report  of  a  study  conducted  on  the  potential  for  collecting  child 
support  payments  from  biological  parents  of  children  in  State 
foster  care  programs. 
General  Comments 
There  are  several  areas  in  the  report  regarding  the  use  of  title 
IV-B  child  welfare  funds,  and  title  IV-E  eligibility  requirements 
which  should  be  clarified. 
Title  IV-B  funds  should  be  expended  by  the  States  on  child 
welfare  senices,  not  foster  care  maintenance  as  could  be  assumed 
from  information  in  the  report. 
States  m~  expend  a  limited  amount  of  title  IV-B  funds  for  foster 
care  maintenance,  however,  according  to  section  423(c)  (1)  of  the 
Social  Security  Act,  there  are  restrictions  which  apply  when  Such 
funds  are  used-for  maintenance.  The  overall  goal  of  the  title 
IV-B  child  welfare  program  is  to  keep  families  together  through 
the  provision  of  social  services  so  that,  if  possible,  children 
will  not  have  to  be  removed  from  their  homes. 
Regarding  title  IV-E  foster  care  eligibility,  the  draft  report 
indicates  that  title  IV-E  foster  care  eligibility  is  based  solely 
upon  a  childs  removal  from  the  home  of  afi  Aid  t~  Families  with 
Dependent  Children  (AFDC)  family.  The  AFDC linkage  is  only  one 
of  several  title  IV-E  eligibility  criteria. 
OIG  I?ecoxrunendation  1: 
ACF  should  encourage  States  to  extend  child  support  services  tO 
all  children  in  foster  care,  regardless  of  the  funding  source. 
Some  options  for  ACF  to  accomplish  this  are  discussed  below. 
Option  1:  Extend  written  instructions  to  Stateg.to  include  all 
foster care children regardless of:-th~@;@
 .&,is6urce.  Such

instructions should encourage State-
  Page 2 - June  Gibbs  Brown 
foster care agencies to record names, dates of birth, and

Social Security numbers for both biological parents of

children in foster care,

foster care agencies to refer all appropriate biological

parents of foster care children to IV-D child support

enforcement agencies for establishing child support orders

and collecting child support, and

foster care agencies and child support enforcement agencies

to develop a Memorandum of Understanding determining

appropriate cases for referral, and gathering and exchanging

data.

Option  2:  Provide  specific  guidance  and  plans  to  States  for 
coordinating  foster  care  and  child  support  progr-,  such..-~s
including a data exchange link between foster care and child 
support enforcement records when developing or modifying

automated systems, and providing child support enforcement

child

agencies  with a model system for classifying and processing
support cases.

Option  3:  Seek legislation requiring the pursuit of child 
support on behalf of non-IV-E foster care children, where 
appropriate.  The legislative requirement should conform to that 
presently in place for the children in IV-E foster care.

ACF Comments 
The ACF does not disagree with the direction of this

recommendation.  However, recommendations concerning child

support for children in foster care should be qualified to 
recognize that in  some instances it would not be good practice to 
seek (or to seek immediately) to collect support from parent(s)

of children in care.  The major goal of the title IV-E foster

care program is the reunification of children with their

families.  Premature or ill-timed efforts to collect child

support payments from a parent could jeopardize and complicate

reunification.  The pursuit of child support from the ex

custodial biological parent may be inappropriate if the

conditions are temporary, such as hospitalization or

incarceration of the parent.  In too many of these cases, the

absence of child support payments from the non-custodial

biological parent, for any number of reasons, also contributed to

the poor financial conditions of the family.
 ,, 
.1 
Page3 - June Gibbs Brown

State  foster  care  agencies  are  now,  and  have  been  since  the 
inception  of  the  child  support  program  in  1975,  able  to  apply  for 
and  receive  Ehe  full  range  of  non-ZWDC  child  support  senices 
from  the  State  w-l)  agency.  currently,  the  foster  care  a9e~Cy 
makes  a  referral  and  pays  a  very  nominal  application  fe@  (In  -Y 
States  $1)  for  IV-D  services.  This  fee  need  be  paid  only  one 
time  by  the  131-13 agency,  and  the  application  may  be  for  one  child 
or  several  children. 
The ACFS Automated Svst  ems for Child Support Enforcement: A 
Guide for States, revised June 1993, addresses the requirements 
for certification of State child support automated syst-: 
flThe  ~ysf-~  must  automatically  accept  and  process 
automated referrals from the IV-E agency if the State

IV-E system is automated.

Alternative: If the Title IV-E agency is not

automated, procedures must be established to ensure

timely transmittal  of information from the IV-E

agency.

The system must record the date the referral is received and must

be able to link two non-custodial parents to a child(ren) in the

custody of the IV-E agency.  The system must also accept and

process a number of data elements, such as the IV-E case

identification number, the IV-E case status, the IV-E approval

date, the IV-E payment amount, and many others.

OIG  Recommendatf.on  2: 
Organizations interested in foster care and child support should

encourage States to seek child support for non-IV-E foster care

children whenever appropriate.

ACF  Comment 
The ACF would welcome the assistance and participation of other

organizations, such as those named in Recommendation No. 2, in

this work.

Technical  Comment8 
Appendix C of the report notes that the formulas used for

computing child support obligations vary from State to State.

For a simple way of estimating child support collections

nationwide the report used 17 percent of income--a formula used

by Wisconsin for one child.  This presumes the cases involve only

one child.  We recommend that the OIG consider how many children

a typical foster care case involves in making their

computations of a theoretical amount of child support available.
 -.
.
.. 
.=+...::$--    -- ~  ,  .._  _  ... 
& 
-- DMARTMENT oF i-iEALTH& HUMAN  SERVICES  Office  of the Secretary 
:. 
;
%-
Washington,  D.C.  20201 
FEB  i ~ 
TO:	 JuneGibbs Brown 
Inspector  General 
FROM:	 Assistant  Secretary  for 
Planning  and Evaluation 
SUBJECT:	 Draft  OIG Report:  Child Support for Children in State Foster  Care,  OEI-
04-91 -00980--COND~ONti  CONCURRENCE 
I appreciaytoeu rofficeinsq uiriyn ttoh issu bjeacntd Ifoundthidsr afrte poratn,dtheone

whichaccompanieidt, IncorrDeicstt ributoifoCnh ilSdu pporCto llectoendB ehaloff
 Non-
IV-EFosteCrh ildrenh,el pfian.dd i
nformative.  Both have the potential  to make important
contributitootnhse chilwde lfaraen dchilsdu pporfti eldsI .am
  in general  agreement with 
the recommendations of the draft report which is the subject of this memorandum and I 
concur with it provided  the following points are developed more fully. 
First,  I believe  it is critical  for the draft report  to highlight that collection  of child support 
from parents  with children  in foster care should only be pursued  in instances  in which this 
action would  support the child welfare agencys case plan for the child.  tie  *odd  be 
taken to make clear that this determination  should be made on a case-by-case  basis.  It is 
clearly  not appropriate  for all foster care cases. 
Secondt,h edrafrte porsth ouledm phasizteh aitn instancwehse nthihs 
 considered

appropnate,cth.ihlewde lfaraeg encyr,a thetrh anthechilsdu pporatg encys,h oulmda
 ket.his

determinatainodnt henincorporcaotmep lianacsep arto fthechildcass
 eplan.Thechild

welfaraeg encys houltdh encontactth ec hilsdu pporatg encyt opursuceo
 llection.

I understatnhda otu rstafhfa vetalkeidn formalalnyd Yourofficke c omfortablmea kintgh
ese 
modificatitoontsh efinarle
 port.
David T. Ellwood  Cwu
Child  Welfare  League  of  America,  Inc, 
440 First Street  NW Suite 310 Washington,  DC  20001-2085   202/638-2952.  FAX 202/6384004 
m 
PRESIDENT 
John F Merchant  SAm 
VICE PREsIDENTS  Z&s
 *

Anne Ouncan 
Judl!h Sherman
 February  3,  1994  *  -- . .

Rulhann  S  Yamanaka  ~  G.,   -n
.-=  n 
SECRETARY  NGMP  ,-
;?  -JJ 
Mar@7  Cox  --1 
,,T 
.- ~  l-n 
ASSISTANT SECRETARY  .4  ,:;  ~.i ~ 
Norman  W  Powell.  Jr  June Gibbs Brown  mm- z    1  :.=-l-m
+  .;~:  
TREASURER  Inspector General  -::7)< 
Rochard H  Flemmg  -:m 
Department of Health and Human Services  . 
:> G 
ARSaySmISoTnAdN T PT RCEaArSpeUmReErR   330 Independence Avenue, SW  F... >  A
Washington,  DC  20201  n  -m 
BOARD  OF DIRECTORS  k.. . 
Carol Armstrong 
Charles  L. Baker 
Dear Ms. Brown, 
JudOh S. BIOCK 
Sheryl Br,ssett.Chapman 
Saran  Bryanl 
Nan Da!e  Thank you for forwarding to us the draft inspection report,  Child Suppontfor C%ildrenin State Foster 
Charles  A  DeGrandOre  Cizre. We appreciate your efforts to analyze child support payment activities on behalf of non-IV-E 
Jeanette  Ounckel 
Charles  A  Haas  eligible  children  in foster  care.  Your  findings  clearly  make the  case for  stronger  collaboration 
Ken! !- Henderson

between foster care agencies and child support agencies to enhance the tlnancial base for providing

George  T Hubbard 
Mao Efell Hurley
 semices to children in foster care and to promote greater parental responsibility. 
Ann O Jordan 
James  M  Karet 
Glynn O. Key

With regard to our specific comments,  we would like to share the following:

Karl G. Kmg 
Suzanne  S  Megathhn 
Elba Montalvo 
Rob Mosbacher.  Jr  +  Page 2:  While Tkle  IV-B may serve as a source of federal finding  for foster care

Timotny  F Moelker
 maintenance,  the requirements  in P.L.  96-272  limit the use of Title IV-B funds for

M!chael  R Oslrowskl 
Jane K. Patne  child day care,  foster care maintenance payments  and adoption assistance payments

R)chara  G  Plufka

to the 1979 Title IV-B appropriation of $56.6 million.  Because of this limitation and

Slepname  G. Robinson 
Maolyn  R  Seymann
 states needs to finance child welfare services with Th.ie IV-B funds, Th.le IV-B has

P Stanley  Shavers 
S Norman  Sherry  not been a viable source of funding for foster care maintenance payments.  Stateand

Farth Sm#th
 10CS.fIu
 nds are the primary funding mechanisms for foster care for non-IV-E eiigible
Pamela  K. Steele 
Manna  Stenms
 children,  a fact that you may wish to emphasize in the description.

Susan S. Step(eton 
George  W  Swan  III 
JOhn G  Theban  +  Pages 2  and 5:  The list of Foster Care Services includes refer parent(s) and child 
Mary Y  Tull 
Cheryle  Wdls-Malthewa  for child  support  services  as a foster  care fimction  and lists this function before 
HONORARY  MEMBER  planning for the childs long term welfare.  Likewise, the discussion of State Foster 
Mm  Ben W  +fememan 
Care Agency Records Are Inadequate for Pursuing Child Support appears to suggest 
EXECUTIVE DIRECTOR  that routine and systematic collection of information  for pursuing  child support is a 
Oawd S  L$ederman 
primary responsibility  of foster care agencies.  It should be recognizedthat foster care 
DEPuTY DIRECTOR 
Sh#rley E  Marcus  agenciesare legally charged with protecting children and ensuring safe and nurturing 
care for  children outside of their  parents homes when necessary.  collecting 
WESTERN OFFICE 
762 W  Cypress  Avenue  information to pursue child support is, at besb a secondary function.  By contrast, 
San D!mas.  CA  91773 
909/599-4565  child support enforcementstaff ~  primarily charged with collecting informationon 
FAX 909/599.  7281  parents and establishing a child support case.  As a consequence, it  is hardly 
Jean McIntosh 
OirectOr  surprising-and,  in fact, wouldbe expected-that  child supportagencieshavemore 
CWLAICANAQA  complete information on this issue than foster care agencies.
180 Argyle Avenue 
SUlfe3 ~z

Ottawa.  ON  K2P  f B 7

6 13/235-4412

FAX 6 13/788-5075

Sandra  G. Scarth

O,recror
 Cwiiiiiiii

Guarding Childrens Rights  Serving Childrens Needs 
 
February 3, 1994 
Page 2. 
+	 Pages 9-12: We certainly agree that States Can Increase Child Support Collections 
through Better Management of the Process but we urge you to recommend that child 
support agencies become actively involved in the process.  Placing yet another non-
protection fiuxxion on foster care agencies to collect infonsation  and refer parents is 
unrealistic  without  an active collaboration  with the  child  support  agencyS.imply

statiansygo
udo on page11 that the administrative cost of collecting the information 
wouid be minimal because foster care caseworkers  generally  obtain information on 
biological parents., but  do not enter this information.. . fails to acknowledge (1) tie 
role of foster care and (2) the nature of the relationship  between foster care workers 
and the parents with whom they are working.  Child support  agencies need to give 
priority  to developing  collaborative  relationships  and  interagency  procedures  with 
foster care agencies.  This emphasis should be included in the last paragraph on page 
U. 
Your recommendations  are excellent,  particularly  Recommendation  1, Option  1 as it recognizx  the 
collaboration  required  between foster  care and child  support  agencies.  We also strongly  support 
Recommendation  2 and would be happy to work with organizations  such as the NGA and APWA in 
encouraging  states to seek child support for non-IV-E eligible children  in foster care. 
Thank you for your excellent work.  Please let us know if we can be of any assistance. 
Sincerely, 
TM8L.L-. 
David S. Liederman 
Executive Director  3F  B+:APIVA  : 2-28-94  ; 2:14PM  ;  2022898555+  4750487:P  2/  5 
sIATEC)FWU-llNCiTON 
DEPARTMENT  OF SOCIAL  AND  HEALTH  SERVICES 
.-,  =. 
K) 80%9162   ~~  WA 98507-9162  ,,  Q=  -nn  
February  11, 1994  -.  T7X)
->  :;>7 m
IG  -2  ~-,c+~ 
SAIG  I  -n -.  m 
.2 -b.  
PDIG 
Cathleen  Tuoker  DIGAS  /----- .. V-: )<m 
American Public Welfare Association  DIG-EI  +    .n.u 
810 First Street, NE  DIG-CM 
Suite 500 
Washington, DC  20002-4267  S:S= 
DATE  SENT 
I 
Re:  Draft Inspector General Report on Child Support for Children  in State Foster Care 
&/-~$Lpf-- @&l@ 
Dear Ms. Tucker: 
Thank-you for the opportunityto review and amment  upon the draft report of the ltispector 
General  on child support for children in state fostercare.  As our state was one of the nine Sbtes 
sampled  for  information  collection, we were  particularly interested in both the findings  and 
recommendations  set out  in the  report.  We  agree  that  foster  care  agencies  need  to work 
cooperativelywithchildsupportagenciestopursuechildsupportaSa routinepartofthe process 
of building  parental  responsibility. 
The specific recommendation tnat tho Administration for Chiidren and Families encourage  states 
to extend  chiid support services to ali children  in foster care, regardless  of funding  sou~,  is a 
concept  already  endorsed by Washington.  We concur that improvements  in data gathering and 
referral systems wili ameliorate many of the information gaps that presently inhibiteffective case 
management-
Based on an internal review oonducted last year, our own oonciusion was that an increase in the 
communicationand coordination of  responsibilities between  foster care  and child support 
enforcement  agencies wouid prMt  all sewice  recipients and stakeholdere.  The major benefits 
anticipated  to flow from implementation of these recommendations  would be an increase in chiid 
support ooilections,  increased paternity establishment  and location of absent parents. 
To these ends, the foliowing recommendations  were made: 
1,	 Development of anautomated coileotion distribution program to complywith federal 
distribu~on regulations. 
2.	 Proposed  development  of  an  electronic  foster  care case referral  process  with 
enhanced data provisions. 
3.	 Proposed development  of an electronic data exchange  system between the chiid 
support agency (IV-D) and the foster care agency  (IV-E and State Oniy).  ;  2-28-94  :  2:14P!U;  202289653s+  47s04i37; #  3[  3 
4.  Proposed on4ine  accew  to the foster care oaee management  data base. 
5.	 Development  of coordinated training tracks for child suppoti  and kwter oam staff 
which  provide  an  OWWOWof each  agencys  reciprocal  intmeta  and Spf3Cific 
program requirements. 
6,	 Ongoing issuance of appropriatepolioydar&stions  and direodves that afticutate 
program  requirements  and best pracdces. 
7.	 Development of a joint work group,  staffed  by both  child support  and foster care 
employees, to develop  strategies  and solutions  for specific issues,  to broaden 
interagency communicationon ail levels and to  form the nudeue of a Mwok fOr 
mntinuing communication. 
Comments  on the  Dmft Report 
The stated purpose of the d@  report is to determine potential for collecting  child support from 
biologicalparents of children in State foster care programs.  In examining the question, the repofl  . 
began  to set out the  impediments  to effective  referral of state  funded  foster care  cases and 
posited  a methodology for estimating potential collections.  This was a good beginning.  Bluntly, 
our concern is that the analysis  in the report did not go far enough in identifying  impediments to 
refenal, suppottorderestablishmentandcollectionand thatthe estimate ofcollectionpotential 
did not reflect a more realistic assessment  of the demographics  of the responsible  parants. 
Impediments  to  Effective  Case  Referral  and  Child  Support  Order  Estebllahment  ati 
Collection 
AS Appendix E in the draft report describes, children entering the foster care environment  are not 
always  voluntarily  placed.  Children  are  sometimes  removed  from  the  household  under 
circumstances  that oan best be described as requiring emergmt intervention. Parents of thw 
children are generally not cooperative, in the sense of voluntarilyprovidinginformationthatwill 
lead to filling in all the blanks on a child support referral. This, in turn, means that referrals tend 
to be incomplete withcmt fault to the foster care agenoy. 
The lack of cooperativenessfurtherextends to the arena of paternityestablishment. For example, 
in an AFDC case, an uncooperative  mother may be sanotfoned for not partidpating  in the p~e$$ 
of establishingpaternity, No similar remedy exists for an uncooperative  mother in the We  Only 
foster care case.  Adding requirements to Individual Servioe Plans and plaoement orderswhich 
requireparentstoparticipatein paternityestablishmenteffortsis onlymarginallyeffeotive,in that 
it presumes the parties are truly interestedin family reconciliation. 
Our study also noted a lingering  perception among foster care professionals  that referral to the 
child supportagency was detrimentaltofamily reconciliationefforts. The additionalfinancialstrain 
imposed by a child support  obligation  on a family  already  in crisis  is the food  point for that 
perception.  Overcomingthisimpressionisa matterofeducationand trainingand of identifying 
solutions  which take into consideration  the financiai issues reieed.  ;2-28-94:2:1- ;  2fJ2289835S- 47s0487;%  41  5 
Factors  Limiting the Coll@ion  Potential From Parentaof  Children  lnStat.  Only  FoSter 
Care 
The draft report estimates a population of 520,000 parentsfromwhichsuppotlWOUlCble oollected. 
In arriving at this estimate, the number of children (260,000 nationwide)  was rnu}tiplied by two. 
Income  data, obtained from  the Social  Security Administration,  was then used to oalcuJatea 
potential  earnings  base,  Finally, a child support formula of 17 percent  of earned  inoome was   
used to net out a potential collection figure. 
{t must first be noted that Washington agrees that there remains an untapped collection potential 
from parents in State Only foster care.  However, each of the applications  in the draft report make  . 
significant  assumptions  or ignore  significant  faotors which tend  to  reduce  cxdlection potential. 
Neither  postulating  or creating  an account  receivable  is equivalent  to  aotually  collecting  the 
amounts  due.  Efforts to accurately measure collection potential must both evaluate  the amount 
of the receivable and the likelihood of successfully collecting the soheduled  obl~gation. A review 
of the magnitude  of existing receivables and the rats of cdeotion  on IV-E Foster Care, AFDC, 
and Non-Assistan~  oases could provide instructive data. 
Additional  factors to consider are: 
1.	 Not every child has two parents from whom supporl maybe  collected.  Aside from 
issues such as abandonment  and the death of a parent, which may lead to foster 
care placement,  a childs parent may simply not be able to be Iooatad. 
2.	 Many placements  involve siblings.  Either siblings  remain in the household  from 
which  the child  in care  was  removed or the  siblings  are all removsd  from the 
household.  Our review of Washington data indioates that this often oocurs.  Where 
other  siblings  are  involved,  a  clifferent  (lower)  per  child  support  formtila  is 
appropriate which consider%the multiple child ecenario,  Where other siblings are 
involved, and remain in the household, one or both parents earning ability maybe 
dramatically affected. 
3.	 Many placements  involve family reconciliation efforts,  Counseling,  treatment and 
other expenses @ trying to bring the family unit back together  are often reasons 
for dramatic  reductions  in child support awards,  h  Washington,  for example, a 
deviationfrom the scheduledchild support obligation  is available for reconciliation 
costs. 
4.	 State  law  may  limit  collections  of  child  support in  some  circumstances.  For 
example, child support collections may be limited to the amount of the expenditures 
actually incurred by the state. 
5.	 State  law  may  provide  other  deviations  from  scheduled  support  obligations 
particularly petiinent  to children in foster care.  These  maybe  extensive  mediod 
bills, specialized care and edudon,  or simply the continuing  cost of maintaining 
a hou=hold  for the child to return to after placement.  Parents  may also face 
unique transportation  costs for children in foster oare. 
These factors  should be addressed  by the report and the collection  potential  revised in light of 
the limitations identified.  Just as the draft report alludes to dividends  and investment income, and  h:
SENT APIVA  ;  2-28-94  ;  2:15PM  :  2022896553+  47S0487:G  s{  5
,1 
thuswealthier parents,the reportshouldalso take noteof parenta withdevelopmentalorother 
disabilitieswhich may have promptedthe need for state Intervention. 
All childrendeserve thesupportoftheirparents. Thissupportcan betional,  financial,orby 
in-kindcontribution. Fostercare agenciesand childsupportagenctesmustworkcooperatively 
to ensurethatthesupportdesewed forchildreninfostercare ismadeavailableIna fashionthat 
best meets the intere$tsof each child. 
Extendingthe benefitsof paternityestablishment,childsupportestablishmentand child support 
mllectbn  to the population  of non-lV-E  foster oars chiidmn is a sound concept.  Improvingthe 
communicationand coordinationbetween foster oare agencies and childsupportagenaesis a 
sound recommendation, However, our feeling is that this is only the beginning. 
A unifiedapproachmustbedevelopedthatteamstheeffo~  ofbothfostercareandchildsupport 
staff,  Simply increasingthe amount of data collected will no doubt lead to higher child support 
collections,but it will do little to support broader program goals suoh as preservation of the family 
unit and familyselfsufficiency. We recommendthat the scopeofthisreportbe broadenedorthat 
an  additional study be commissioned  to more fully address the issues we have raised in our 
response. 
Thank-you  again for the oppommity  to review and comment  upon the draft report. 
cc:  Jerry Friedman  2Q2289653~-
:  3-14-94 : 9:46.Ml; 
., 
NEW YORK STATE 
DEPARTMINI  OF  SOCIALSERVICES  E~(JE~D 
40NORTHPEARLSTREET,ALBANY,NEWYORK122434)001 
MAR ? ~  SIJSAN V. D!!MERS 
MICHAEL J. 00tVUNG 
LkPWY c~   one 
cbmlnsmlw  ad  Gcneai CQWA 
Mmch  2,  1994 
  Cathleen  Tucker,  ESq. 
Project Manager

National  Council  of State Human $emdces  Administrators

American Public Welfare Association 
.91o First  Street,  ~.E.,  suite  Soo 
Washington,  D.C.  20002

Child Support for Children is 
State  Foster Care  Programs
.4--  e:
/6 
45/ 64;9/  @~~~

Dear Ms. Tuc) e-r:

with the New York State

The pu~ose  of this letter is to provide you

Department  of Social  Services  comments  on  the draft report issued by Che 
Department  of Health and Human Semites  (nD_)  OffiC&o~&-Inspector 
The
~cnezal  entitled  tChild  Support  for  Children in State Foster Care. 
draft report recommends that the DHHS Administration  for Children and 
Families instruct  the  states  to  extend  the  admimisbration  of their Title IV
D Child Support  Enforcement programs to the collection  of  support for 
The Department  supports the 
childxen in state-fmded  foietex  care  progrwns. 
recomnendationa  stated in the draft repor~ ae they are consistent with the 
federal  end  state governments ourrent  efforts to implement  wclfaxe re?orm 
and its  emphasis  on  parental  responsibility. 
New York  Statels  Child Support Enforcement Program  already pursues.the 
establishment  and enforcement ef child support orders on behalf of ahildrefi

in the StaCes foster care prcqram.  As noted in  the draft report, the 
for the transfer of infmmetion 
implementation  of more  effectiveprocesses
between  a  states  foster  care  agency  and its child support   nforcement 
agency  enableei  a  state  to  benefit fxom the collection of support for those 
children.  It is this Statels  experience that such collections provide 
to tlheState for the expenses it incurs 
significant  levels of reimbursement 
in the provision of child welfare services.
 ;  3-14-94  ;  9:mwl  ; 
. 
-2-
Thank you for the opportunity to provide comments on this draft

report.  If you require any additimal  information in this regard, please

contact Assist-t  Counsel Anne Binseel of my staff at 518-473-1949.

Very  tru~y your~, 
SusC~ V. Demers

Deputy Commissioner

and General Counsel

SVD/AJB:  ab