Department of Health and Human Services 
OFFICE OF 
INSPECTOR GENERAL 
Child Support Enforcement 
State Disbursement Units 
State Implementation Progress 
JUNE GIBBS BROWN 
Inspector General 
AUGUST 2000 
OEI 06-00-00040  OFFICE OF INSPECTOR GENERAL 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-
452, is to protect the integrity of the Department of Health and Human Services 
programs as well as the health and welfare of beneficiaries served by them.  This 
statutory mission is carried out through a nationwide program of audits, investigations, 
inspections, sanctions, and fraud alerts.  The Inspector General informs the Secretary 
of program and management problems and recommends legislative, regulatory, and 
operational approaches to correct them. 
Office of Evaluation and Inspections 
The Office of Evaluation and Inspections (OEI) is one of several components of the 
Office of Inspector General.  It conducts short-term management and program 
evaluations (called inspections) that focus on issues of concern to the Department, the 
Congress, and the public.  The inspection reports provide findings and 
recommendations on the efficiency, vulnerability, and effectiveness of departmental 
programs. 
OEI's Region VI prepared this report under the direction of Chester B. Slaughter, 
Regional Inspector General and Judith V. Tyler, Deputy Regional Inspector General. 
Principal OEI staff included: 
DALLAS  HEADQUARTERS

Blaine Collins
 Joan Richardson, Program Specialist

Ruth Ann Dorrill

Clark Thomas, Ph.D. 

Scott Whitaker

Jnette Oshitoye

Nancy Watts

Lisa White

Jennifer Kahende

Patricia Martin

To obtain copies of this report, please call the Dallas Regional Office at 214-767-3310. 
Reports are also available on the World Wide Web at our home page address: 
http://www.dhhs.gov/progorg/oei  E X E C U T I V E  S U M M A R Y  
PURPOSE 
To describe States progress in implementing State Disbursement Units (SDUs), and 
share their experiences and perceptions as an informed basis for learning from one 
another and identifying opportunities for improvements. 
BACKGROUND 
Requirements for Centralized State Disbursement Units:  Congress requires States 
to process child support payments through centralized State Disbursement Units 
(SDUs). The primary objectives of centralization are to provide employers with a single 
location in each State to send income withholding payments, and to make payment 
processing more efficient and economical. Federal requirements specify deadlines for 
SDU implementation and standards for operations, and outline areas of State 
discretion, such as the option to have private contractors operate SDUs. To meet these 
requirements, several States had to make relatively minor changes to their previous 
centralized systems. In other States which had traditionally processed payments 
through local child support offices or clerks of court, centralization of payment 
processing was a major endeavor. 
Concerns About Implementation:  In December 1999, the Office of Inspector General 
(OIG) received a letter from Congressman Bob Clement of Tennessee expressing 
concern about the effectiveness of his States new system for collecting and disbursing 
child support payments. In response, the OIG initiated a study of the Tennessee SDU, 
reviewing 16 cases that experienced delayed payments under the new system. 
Additionally, we surveyed all States and undertook an in-depth review of SDU 
implementation in six States. 
Methodology:  Information in this report comes primarily from survey responses of 
SDU program managers from all States. These respondents provided details about the 
current status of SDU implementation, problems they encountered in developing and 
operating SDUs, strategies they employed to ensure quality SDU performance, and 
their assessment of current operations.  We did not verify the accuracy of their 
responses.  Rather, our goal was to present the self-reported experiences and 
perspectives of key players who are implementing and operating the centralized unit in 
order to facilitate their learning from one another. 
FINDINGS 
Thirty-eight States Report They Have Fully Implemented the Federal Law to 
Centralize Payment Processing of Most Child Support Payments 
Thirty-eight States and territories report fully implementing their SDU by April, 2000. 
Three States have Federal waivers to link their local disbursements units. All but one of 
the 12 remaining States report plans to complete their SDU implementation by 2001. 
i 
SDUs: State Implementation Progress  OEI 06-00-00040  OCSE granted two of these States extensions to their SDU implementation deadline 
and gave the remaining 10 States an opportunity to request an alternative penalty by 
submitting a corrective compliance plan and demonstrating a good faith effort to 
implement their SDU. 
Twenty-five States implemented, or plan to implement, their SDU incrementally, a 
strategy that allows program managers to resolve startup problems and make technical 
changes without affecting a large number of cases. While almost half of State child 
support agencies directly operate their SDUs, many contract with private companies 
and clerks of court to perform some or all SDU functions. While the Federal law 
requires only that SDUs process payments for public assistance cases and cases with 
income withholding ordered on or after January 1, 1994, 32 States will process 
payments from all types of child support cases through their SDU. In order to monitor 
the effectiveness of their SDU, most States track the timeliness of disbursements and 
the extent of undistributed payments. 
States Experienced a Number of Problems in Implementation, But Managers Report The 
Severity of Most Problems Has Diminished Over Time 
Most SDUs encountered problems when they first centralized payment processing. 
While some problems remain as continuing operational concerns, the severity of many 
of these problems have diminished subsequent to startup periods. SDU managers 
report they initially had problems getting payments mailed to the SDU and that many 
payers either continued to send payments to local sites instead of new SDU post office 
boxes, or failed to include information necessary for identifying the cases to which 
payments should be applied. In some States, when payments contained insufficient 
information or were mailed to the wrong location, disbursements were significantly 
delayed. 
Managers also report problems negotiating with contractors, and coordinating with local 
child support staff and clerks of court who had previously processed payments locally. 
For example, many SDUs had to convert local case information to central databases 
prior to SDU implementation, requiring a good deal of collaboration with local staff and 
clerks of court. Managers in some Sta9tes report these efforts were often problematic, 
resulting in payments being received by the SDU for which it had no associated case 
information. Managers also indicate difficulty in staffing their SDUs due to variable 
workloads. 
A Majority of Managers Believe Their State Disbursement Units Have Improved Payment 
Processing, Particularly After an Initial Startup Period 
Based on monitoring and experience, a majority of SDU managers believe their SDU 
achieves better results than previous local processes. Managers cite general 
improvements in payment processing speed, service to custodial and noncustodial 
parents, and in easing the burden on employers. However, several States report 
improvements were not realized until after an initial startup period. Despite the positive 
perceptions of the majority of managers, others report their SDU has made little 
difference or even had negative effects on some program functions. 
ii 
SDUs: State Implementation Progress  OEI 06-00-00040  AGENCY COMMENTS 
The Administration for Children and Families (ACF) agreed with the findings and 
conclusions presented in these two reports. ACF concurred with each of the 
recommendations directed to OCSE and recounted its efforts to assist States with SDU 
implementation. ACF also expressed a desire to collaborate with the OIG in quickly 
disseminating to States the information provided in these reports. ACF comments are 
provided in their entirety in Appendix A. 
iii 
SDUs: State Implementation Progress  OEI 06-00-00040  T A B L E   O F   C O N T E N T S  
PAGE

EXECUTIVE SUMMARY  i

INTRODUCTION  1

FINDINGS 
SDU Operations 
Current Implementation Status  3

Use of Incremental Implementation  4

Entities Operating SDUs  4

SDU Caseloads  5

Parental Access to Payment Information  6

Monitoring SDUs  6

Challenges to Effective SDU Operations 
Coordinating with Employers and Parents  7

Coordinating with Other Entities  8

Poorly Labeled Payments  9

Lack of Automated Case Information  9

Payments Mailed to the Wrong Location  9

Customer Service Demands  10

Staffing Issues  11

State Assessment of SDUs 
Overall Assessment  11

Payment Processing Speed  11

Service to Parents  12

Burden on Employers  13

Undistributed Payments  13

SUMMARY  13

AGENCY COMMENTS  14

ENDNOTES  15

APPENDICES 
A: Coordination and Operational Problems 
 A-1 
B: ACF Comments
 B-1  I N T R O D U C T I O N  
PURPOSE 
To describe States progress in implementing State Disbursement Units (SDUs), and 
share their experiences and perceptions as an informed basis for learning from one 
another and identifying opportunities for improvement. 
BACKGROUND 
In the 1996 Personal Responsibility and Work Opportunity Reconciliation Act 
(PRWORA), Congress required States to centralize collection and disbursement of 
child support payments into State Disbursement Units (SDUs).1 The primary objectives 
of centralization are to provide employers with a single location in each State to send 
income withholding payments, and to make payment processing more efficient and 
economical. Federal law requires that States: 
!	 Implement the SDU by a Deadline of October 1, 1998 or 
(October 1, 1999 for States with Previous Clerks of Court Involvement) 
!  Provide Employers with a Single Location to Send Payments 
!  Disburse Payments Within Two (2) Business Days 
!  Process All Payments for a Specified Caseload2 
(With Discretion to Include All Cases) 
!  Provide Payment Information to Parents 
!  Operate the SDU Through a State Agency or Contractors 
!  Staff SDUs Sufficiently to Perform Required Functions 
!  Automate Procedures as Much as Feasible, Efficient, and Economical 
!  Integrate the SDU with the States Automated Child Support System 
!  Monitor SDU Performance 
Several States already had centralized procedures and had to make relatively minor 
changes to meet Federal requirements. In other States, however, local child support 
staff or clerks of court traditionally processed many payments, making centralization 
more challenging. Congress anticipated that some States with reliable local systems 
might be reluctant to centralize. Therefore, PRWORA allowed States to be granted a 
waiver to operate their SDU by linking local disbursement units through an automated 
information network, if the Secretary of DHHS agreed that the linked system would not 
cost more nor take more time to establish or operate than a centralized system. 
However, even when a linked system is used, Congress specified that employers must 
still be given only one location for sending payments within each State. States that 
failed to implement an SDU by their deadline, unless granted a waiver, potentially faced 
stiff penalties, though these have subsequently been reduced.3 
Federal Financial Participation (FFP) is available for administrative expenses of the 
SDU at a rate of 66 percent.4 However, States which choose to process all child 
1 
SDUs: State Implementation Progress  OEI 06-00-00040  support payments through their SDU do not receive Federal funds for processing any 
cases not mandated by Federal law. For processing non-public assistance cases, 
SDUs are allowed, but not required, to charge parents processing fees. 
In December 1999, the Office of Inspector General (OIG) received a letter from 
Congressman Bob Clement of Tennessee expressing concern about the effectiveness 
of his States new system for collecting and disbursing child support payments. In 
response, the OIG initiated a study of the Tennessee SDU, reviewing 16 cases that 
experienced delayed payments under the new system. Additionally, we surveyed all 
States and undertook an in-depth review of SDU implementation in six States. 
METHODOLOGY 
Information in this report comes primarily from survey responses of SDU program 
managers from all States, as well as the District of Columbia, Puerto Rico and the 
Virgin Islands.5 Additionally, we use information from interviews of key participants 
involved in SDU operations in six focus States. The six focus States we visited for on-
site interviews were Arizona, Florida, Iowa, Minnesota, Pennsylvania, and Tennessee. 
These States were chosen to provide variety regarding when centralization occurred, 
and whether the State uses contractors or other partners in payment processing. In 
each focus State, analysts interviewed SDU program managers, SDU information 
system managers, contractor managers, and managers of staff that process payments. 
We also toured the primary SDU payment processing facility. Where appropriate, we 
also interviewed at least one representative of local entities that were responsible for 
payment processing prior to centralization.6 All data collection occurred in February, 
March, and April 2000. 
Limitations. In conducting this inspection, we did not attempt nor intend to evaluate 
SDU operations. For example, we did not try to measure the relative costs or 
efficiencies of various operational arrangements. We also did not verify the accuracy of 
State responses. Rather, this report examines the self-reported experiences and 
perceptions of key personnel who are implementing and operating SDUs. 
This study was conducted in accordance with the Quality Standards for Inspections 
issued by the Presidents Council on Integrity and Efficiency. 
2 
SDUs: State Implementation Progress  OEI 06-00-00040  F I N D I N G S  
OPERATIONS OF STATE DISBURSEMENT UNITS 
To meet Federal requirements, States had to develop and implement SDUs for 
processing child support payments, as well as mechanisms to provide information to 
parents and methods for monitoring SDU activities. 
Thirty-eight States Report They Have Fully Implemented the Centralized Processing of 
Child Support Payments as Required by Federal Law 
As of April 2000, thirty-eight States and territories have SDUs that process payments 
for the Federally-required caseload. Eighteen of these States were already processing 
payments centrally prior to 1998, the first year in which SDU implementation was 
Federally-required (Figure 1). Another 20 States began centralized payment processing 
since 1998. Three additional States were granted a waiver which releases them from 
the Federal SDU requirements by linking local disbursements units.7 Four States have 
partially implemented their SDUs, already processing a substantial portion of the 
required payments, and the remaining eight States have not yet begun centralization. 
Most States without fully implemented SDUs, except those with waivers, expect to 
complete their SDU implementation by 2001, but one State estimates it will not 
complete implementation until 2006. OCSE granted two of these States extensions to 
their SDU implementation deadline and gave the remaining 10 States an opportunity to 
request an alternative penalty by submitting a corrective compliance plan and 
demonstrating a good faith effort to implement their SDU.8 
Figure 1: State Disbursement Unit Implementation Dates 
(as Reported by States) 
20 
11 
9  9 
3 
1 
Before 1990  1990-97  1998 - April 2000 May 2000 - 2001  2006  Waiver 
Based on Responses from 50 States, the District of Columbia, Puerto Rico, and the Virgin Islands 
3 
SDUs: State Implementation Progress  OEI 06-00-00040  Half of Managers Report Current or Planned Use of Incremental Implementation 
Methods, Initially Processing Payments for Only a Segment of Their Caseload 
To ease startup difficulties, 25 States implemented, or plan to implement, their SDUs 
incrementally. These States have developed unique strategies, including phase-ins 
based on county, payer type, or case type. Managers report that incremental 
implementation allows SDUs to recognize and solve problems early, while affecting 
only a portion of their caseload. Incremental implementation may also help managers 
gauge payment volume for staffing purposes, and provides early performance 
information. It also allows technical staff to make modifications in State databases, 
computer software, and processing equipment as technical glitches or needed 
structural changes are identified. SDU phase-in periods have ranged from a single 
disbursement cycle (one month) to many months. Some States also operated pilot 
projects prior to beginning more widespread implementation. Pilot projects often 
involved only one large county or a handful of smaller counties, allowing managers to 
test procedures with a closely controlled set of payments prior to finalizing plans for full 
implementation. 
Other States considered and then discarded the idea of incremental implementation for 
various reasons. After securing the necessary legislative authority for their SDU and 
beginning development, managers in some States did not perceive they had enough 
time for an incremental implementation prior to their Federal deadline. Others report 
they preferred to initially implement statewide, hoping to deal with startup problems 
over a shorter, though more intense, period. Some managers also note that payers not 
included in initial phases of incremental implementation may hear of the SDU and begin 
sending payments to the centralized unit too early. 
State Disbursement Units are Operated by Child Support Agencies or By Private 
Contractors Who Perform Some Part of Payment Processing 
SDUs perform two primary functions: receipting, which includes receiving, posting, and 
depositing child support payments; and disbursement, which includes printing and 
mailing payments. Managers in 22 States report the child support agency performs, or 
will perform, the receipting function, and will perform the disbursement function in 35 
States (Table 1). A few of these States report having cooperative agreements with 
other State agencies, such as the State Treasury, to print and mail checks, typically 
because the other State agency already has check printing equipment and expertise. 
Table 1: CURRENT OR PLANNED ENTITIES PERFORMING MAJOR SDU FUNCTIONS 
Function  Child Support Agency  Private Companies  Clerks of Court 
Receipting  22 (42%)  27 (52%)  3 (6%) 
Disbursing  35 (67%)  14 (27%)  3 (6%) 
Percentages based on the 52 respondents answering this question. 
Most of the remaining managers report their SDUs currently contract, or plan to 
contract, with private companies to perform receipting (27 States) and disbursing (14 
States). Three private companies contract with more than one State: Lockheed Martin 
IMS (13 States); Tier Technologies (7); and System & Methods, Inc. (2). These 
4 
SDUs: State Implementation Progress  OEI 06-00-00040  companies may be awarded additional contracts by States still preparing for 
implementation. Private contractors in some States use sub-contractors to perform 
various functions, such as check printing. In three States, local clerks of court who 
performed receipting and disbursing functions prior to SDU implementation were 
awarded contracts to continue performing these functions centrally. 
Thirty-two States Report Their Disbursement Units Will Process All Types of Child 
Support Cases, Rather Than Only Those Required by Federal Law 
SDUs are Federally-required to process payments for a specified caseload, but have 
discretion over whether to centralize processing of payments for all child support cases. 
Thirty-two States currently process, or plan to process, payments for all case types 
through their SDU. Additionally, a few States report they process payments through 
their SDU for more cases than just those which are required, but still process some 
cases locally. For example, States may centrally process any case with an income 
withholding order, even though the SDU is only required to process cases with income 
withholding ordered after January 1, 1994. Cases that are not processed through the 
SDU are typically handled locally, as they were before SDU implementation. Federal 
funding is not available for processing cases not mandated to be handled by the SDU. 
Some States recoup at least a portion of their costs by charging fees to custodial 
parents in non-public assistance cases, regardless of whether the cases are processed 
centrally or locally. 
Managers in States processing all child support cases through their SDUs report a 
number of advantages, such as the ability to provide employers with a single address to 
send all child support payments. They also report that processing all cases through the 
SDU avoids any need to switch cases between central and local processing, thereby 
avoiding confusion for parents and employers. Managers also maintain that centralizing 
all cases may be a more efficient use of State resources. When some cases continue 
to be processed locally, these local processors must devote resources to payment 
processing, including post office boxes, bank accounts, databases, processing 
equipment, and staff time, even though they may be handling only a fraction of the 
volume they were before SDU implementation. Some managers argue that since 
continued local processing limits the number of payments processed centrally, it fails to 
take full advantage of efficiencies and cost savings achievable through highly-
automated SDUs. 
Some States Do Not Plan to Centralize All Cases, Primarily Because They Lack Funding 
for the Conversion or Are Satisfied With Their Local Systems 
While Federal Financial Participation (FFP) is available to reimburse States for SDU 
expenses incurred through processing the Federally-required cases, States which 
process additional cases through their SDU must bear the expense of conversion and 
processing. Although some States have discovered greater efficiencies in processing 
all payments through SDUs, others incur only minimal expense when payments are 
processed through local entities such as clerks of court. Advocates for continued local 
processing of some cases also report being reluctant to change a method that is 
already successful, considering their local jurisdictions to be more responsive to clients 
and fearing a heavy reliance on automated systems. Finally, managers point out that 
SDUs may never truly process payments for all child support cases in their State 
5 
SDUs: State Implementation Progress  OEI 06-00-00040  because many noncustodial parents are court-ordered to pay the custodial parent 
directly, with no government processing or tracking of payments. 
States Use a Number of Methods to Provide Parents With Access to Payment 
Information, Primarily Relying on Telephone Contact 
In attempting to promote service to parents under a centralized system, States offer a 
number of options for accessing payment information. Almost all States (49) provide, or 
plan to provide, parents with telephone access to customer service staff (Table 2). This 
staff is often housed in a centralized customer service call center, staffed either by the 
State or a contractor. Call center staff typically answer payment questions from 
employers and local child support offices, as well as from parents. Call center staff in 
some States have access only to case payment information, but not other case 
information such as paternity or enforcement matters, and may be instructed to only 
respond to payment-related inquiries. In other States, call center staff have full access 
to caseload databases and are trained to answer multiple questions regarding case 
management, enforcement, and State policy, in addition to payment inquiries. 
Table 2: SDU SERVICES FOR RESPONDING TO PARENTAL INQUIRIES 
Current and  Response 
Service to Parents  Planned Services  Time Frame 
Speak by Telephone With Customer Service Staff  49 (92%)  Immediate 
Query Automated Telephone Response System  49 (92%)  Immediate 
Speak by Telephone with Local Caseworker  47 (87%)  1 to 2 Days 
Make Appointment with Local Caseworker  41 (77%)  1 to 2 Days 
Leave Internet Electronic Mail Message  24 (45%)  1 to 2 Days 
Query Through Database Internet Website  13 (25%)  Immediate 
Response Time Frame based on the most common responses of States. 
Most States also report current or planned use of some form of automated telephone 
response system, often linked to the States customer service call center. Through 
these automated systems, parents may first access information stored in SDU 
databases, such as the last date a payment was received on a case, and are able to 
transfer to a customer service representative to inquire about more detailed matters. In 
many States, local caseworkers are also available to answer payment inquiries by 
phone (47) and in person (41). However, managers report that this type of local service 
will not be as immediate as call center service. Several States also report current or 
planned use of the Internet to enhance customer service and parental access to 
payment information. 
Managers Report Use of Performance Indicators to Monitor State Disbursement Units, 
Primarily Focusing on the Timeliness of Processing 
Forty-seven States report current or planned use of performance indicators to help 
monitor and evaluate SDU payment processing. These performance indicators mostly 
provide information about the timeliness of child support disbursements, and the ability 
6 
SDUs: State Implementation Progress  OEI 06-00-00040  of the SDU to limit undistributed payments. For example, 39 States report current, or 
planned, tracking of the elapsed time between receipt of each payment and 
disbursement to custodial parents, and 35 of these will further compute and track the 
percentage of payments processed within two business days (Table 3). These 
measures may be used to gauge the overall effectiveness of their SDU, as well as to 
help detect procedural weaknesses and forecast staffing needs. 
Thirty-five States track how long it takes to research previously unidentified payments. 
When SDU automated systems are unable to initially match a payment to a case, staff 
must research any information provided with the payment, such as a return address on 
an envelope. Staff typically search a number of available databases, and may call 
employers to obtain additional identifying information. Many research items are 
matched during the same processing cycle, allowing payments to be identified and 
disbursed within two business days. Many States also track the amount (34) and 
number (32) of their SDUs undistributed payments. The number of undistributed 
payments on a given day may assist supervisors in adjusting the workload of research 
staff, while the dollar amount of undistributed payments may serve as a better indicator 
of the overall impact on families. 
Table 3: USE OF SDU PERFORMANCE INDICATORS 
Performance Indicator  States 
Elapsed Time to Disbursements  39 (83%) 
Percent of Payments Disbursed Within 2 Business Days  35 (75%) 
Elapsed Time for Payment Research  35 (75%) 
Dollar Amount of Undistributed Funds  34 (72%) 
Number of Undistributed Payments  32 (68%) 
Percentages based on the 47 respondents answering this question. 
CHALLENGES TO EFFECTIVE OPERATION 
Many people familiar with child support enforcement expected that as SDUs were 
developed and implemented, States would encounter problems coordinating with 
payers (employers and noncustodial parents) and other entities involved in payment 
processing. Stakeholders also anticipated problems in transferring a large number of 
cases from local payment processing to a centralized, automated system. SDU 
program managers report that their SDUs have encountered a variety of problems, 
especially during the early phases of implementation. Managers indicate difficulties 
continue to exist in some areas, but the severity of most problems has diminished over 
time. 
Coordinating with Employers and Parents 
Many SDU managers report experiencing problems in communicating with and 
receiving responses from noncustodial parents and employers during their initial startup 
phase (Table 4).9 For example, many payers reportedly did not redirect their payments 
to the newly centralized system upon initial notification, causing disbursement delays. 
7 
SDUs: State Implementation Progress  OEI 06-00-00040  States which had this problem at startup continue to struggle with payer coordination, 
but the severity of the problem is perceived to have decreased after startup. SDUs 
must continue to collaborate with payers, especially regarding changes in employment 
and income withholding orders. 
Table 4: SDU PROBLEMS IN COORDINATING WITH KEY PLAYERS 
States with  States with 
Startup  Continuing  Severity of 
Problems with Payers  Problems  Problems  Problem* 
Getting checks mailed to SDU by parents  24 (67%)  21 (60%)  Decreased 34% 
Coordinating with employers  22 (61%)  20 (57%)  Decreased 26% 
Notifying employers and parents of changes  20 (56%)  17 (49%)  Decreased 38% 
Problems with Other Entities 
Securing necessary funding  17 (49%)  19 (54%)  Increased 35% 
Coordinating with clerks of court  14 (39%)  12 (34%)  Decreased 23% 
Gaining necessary state legislative authority  14 (40%)  6 (17%)  Decreased 50% 
Negotiating terms with contractors  13 (37%)  12 (34%)  Decreased 10% 
Coordinating with local child support offices  13 (37%)  7 (20%)  Decreased 63% 
Percentages based on the number of respondents to each question. 
* Using State responses regarding the severity of each problem. Percentages reflect a weighted scale based upon State 
description of problems as major, moderate, or minor, during and after startup. See Appendix A. 
Coordinating With Other Entities 
SDU implementation required State child support agencies to collaborate with their 
State legislatures in gaining necessary funding and authority for SDU operations. 
Implementation often also brought new participants, such as contractors, into child 
support payment processing, and substantially changed the responsibilities of others. 
Some SDU managers report experiencing problems in coordinating with these entities. 
Coordination problems are generally reported to have decreased after initial 
implementation, although negotiations with contractors and collaboration with clerks of 
court continue to cause concerns for several States. Interestingly, securing adequate 
funding is the only problem that managers report has increased in severity after startup. 
Managers suggest that initial SDU funding requests may have underestimated SDU 
staffing and funding needs, with managers only realizing all associated costs after 
operating their SDU for a period of time. Some managers report involving all key 
players in the initial planning stages for an SDU, and many formed work groups made 
up of representatives from local child support offices, clerks of court, and employers. 
These work groups discussed potential problems, and were often given the opportunity 
to influence the design of SDU operations based on their needs and concerns. 
8 
SDUs: State Implementation Progress  OEI 06-00-00040  Poorly Labeled Payments 
Thirty States report continuing problems with identifying payments that are poorly or 
incorrectly labeled by payers (Table 5). To allow automated procedures to match a 
payment to a case, payments processed through SDUs must include identifying 
information about the case, such as a case number, so the payment can be correctly 
applied. Managers report that when centralized processing first started, many payments 
omitted needed information or contained inaccurate information, possibly because 
payers had not previously been required to submit this information with each payment. 
When previously processed through local offices, staff often could correct payer errors 
or omissions. However, automated SDU systems are not designed for such 
individualized processing. To reduce the number of payments with incomplete or 
inaccurate case information, some States provide employers and noncustodial parents 
with remittance notices or billing statements that may be returned with each payment, 
similar to those used by credit card companies to ensure payments are posted to the 
proper account. However, because child support is sometimes paid weekly or by pay 
period, instead of once a month, the use of remittance notices is more complicated. 
Many States also make additional efforts to educate payers about what information 
must be included with each payment to ensure proper posting. While managers report 
some improvements in payment labeling, the severity of this problem appears not to 
have declined substantially after startup. 
Lack of Automated Case Information 
A related problem involves receiving payments for which no case information exists in 
the SDUs database. At startup, managers in some States report this occurred because 
the database used by SDUs was not yet fully populated with information from local 
clerks of court or child support offices. States report making significant conversion 
efforts to get all local information into the SDU database prior to centralization. Most 
States that converted or transferred case information from local entities to the SDU 
either set up an automated data merge, or created manual procedures in which staff 
worked at local offices to record case information, and entered that data into the SDU 
database. Managers report that both methods had inherent problems that allowed 
some cases to be missed or improperly converted. Conversion was reportedly more 
difficult in some States that maintain separate processing systems for non-public 
assistance cases, because staff had to make decisions about which cases should be 
converted and which should remain for local processing. Beyond conversion, case 
information may be absent from SDU databases because of delays in entering new 
case information. Many SDUs rely on local staff and clerks of court to add new cases to 
the system, yet managers report payments are sometimes received before data entry 
occurs. Disbursement of these payments may be delayed until case information is 
added to the database. A number of States report that getting new case information 
into the SDU database continues to be a challenge. 
Payments Mailed to the Wrong Location 
At startup, States used a variety of methods to notify payers where and when to begin 
sending payments to the SDU rather than to a local jurisdiction. However, managers 
report that many payers initially failed to make this change, and States had not 
prepared sufficiently to handle misdirected payments. Some States implemented 
9 
SDUs: State Implementation Progress  OEI 06-00-00040  procedures to continue to process misdirected payments locally, while others forwarded 
them to the SDU. However, each of these methods had the potential to delay 
disbursements to families. Managers also report that instead of processing misdirected 
payments or forwarding them to the SDU, a few local entities returned payments to 
payers, causing more extensive delays in disbursement. While managers from 21 
States report that processing payments mailed to the wrong location continues to pose 
problems for their SDU, the severity of this problem appears to decline considerably 
after startup. 
Table 5: SDU OPERATIONAL PROBLEMS 
States with  States with 
Problem  Startup  Continuing  Severity of 
Problems  Problems  Problem* 
Identifying poorly labeled payments  28 (78%)  30 (86%)  Decreased 9% 
Identifying payments with no case in system  27 (75%)  30 (86%)  Decreased 20% 
Re-directing payments mailed to wrong place  26 (72%)  21 (60%)  Decreased 34% 
Meeting customer service demands  26 (72%)  25 (71%)  Decreased 21% 
Securing, training and retaining staff  22 (61%)  21 (60%)  Decreased 30% 
Disbursing support within 2 business days  19 (53%)  11 (31%)  Decreased 64% 
Predicting volume for staffing purposes  18 (50%)  14 (40%)  Decreased 37% 
Monitoring SDU performance  14 (39%)  11 (34%)  Decreased 33% 
Percentages based on the number of respondents to each question. 
* Using State responses regarding the severity of each problem. Percentages reflect a weighted scale based upon State 
description of problems as major, moderate, or minor, during and after startup. See Appendix A. 
Customer Service Demands 
Managers primarily identify responding to inquiries and complaints as a startup 
problem, but customer service demands continue to challenge many States. 
Implementation of SDUs often changed the method through which States respond to 
inquiries and complaints regarding payments. These questions and complaints primarily 
come from parents, but may also be raised by other entities, such as local child support 
offices or employers. States appear to have experienced a high demand for customer 
service response at startup, due to confusion and delays caused by changes in 
payment procedures. Managers in 26 States report that meeting customer service 
demands was a problem at startup. For most of these States, meeting customer service 
demands continues to be a concern even after fully implementing their SDU, although 
the severity of the problem has diminished somewhat. States that experienced initial 
difficulty in meeting customer service needs report increasing staff and streamlining 
methods for responding to calls. They also focused on timely payment processing, 
reasoning that a more successful system would reduce the likelihood of inquiries and 
complaints. Many States also appear to use performance indicators to evaluate the 
customer service process, such as tracking the average time customers wait on hold 
during a call to the centralized customer service center. Others have conducted surveys 
10 
SDUs: State Implementation Progress  OEI 06-00-00040  of parents and employers to help anticipate ongoing needs and continue to conduct 
outreach to ensure that customers are informed about service options and points of 
contact. 
Staffing Issues 
About half of States with operating SDUs report problems with securing, training and 
retaining staff, and with accurately predicting payment volume in order to project 
staffing needs. Ensuring adequate staffing of SDUs is sometimes problematic because 
the jobs are typically not high paying, the duties are somewhat monotonous, and the 
work hours can be unusual. For instance, some SDUs have shifts beginning at 3 AM, 
while others operate on both Saturday and Sunday. Because training new staff is 
reportedly costly and time-consuming, and experienced workers make fewer errors in 
processing payments, managers report a variety of efforts to keep their employees 
motivated, such as providing performance incentives. Predicting payment volume can 
be difficult because of day-to-day variation in the number of payments received. Some 
days, such as most Mondays and days just after the first of the month, have typically 
high volume because of the timing of employer pay periods, but even volume on these 
days may vary. 
STATE ASSESSMENTS OF DISBURSEMENT UNITS 
Overall Assessment 
Based on monitoring and experience, program managers in a majority of the 38 States 
which report they have fully implemented SDUs perceive that centralized processing 
has resulted in improvements on each of seven performance indicators (Figure 2). 
While some managers report that centralization immediately resulted in improvements, 
others feel that their State realized improvements only after startup problems were 
resolved. Managers in over 60 percent of States with operating SDUs cite 
improvements in payment processing speed, service to both custodial and noncustodial 
parents, and in minimizing the burden on employers. 
Payment Processing Speed 
Most managers believe their fully-implemented SDUs have improved payment 
processing speed, and nearly all report disbursing payments within two business days. 
The highest number of managers (27) report SDU implementation has resulted in 
improvements in payment processing speed, but a third of these (9) report they did not 
realize improvements in timeliness until after their initial startup period. In fact, 34 
managers report their SDU currently meets or exceeds the requirement to disburse 
child support payments within two business days, and 15 States report that, on 
average, payments are disbursed within only one business day of receipt. Some States 
achieve this performance by including tougher processing and disbursement time 
standards upon contractors. 
11 
SDUs: State Implementation Progress  OEI 06-00-00040  Figure 2: PERCEIVED IMPROVEMENT RESULTING FROM 
SDU IMPLEMENTATION 
PAYMENT PROCESSING SPEED  18  9  7  1 
SERVICE TO CUSTODIAL PARENTS  18  5  4  5 
SERVICE TO NONCUSTODIAL PARENTS  16  5  6  5 
BURDEN ON EMPLOYERS  14  6  10  1 
UNDISTRIBUTED PAYMENTS  14  4  7  6 
OVERALL COST OF OPERATIONS  11  5  9  4 
TRACKING CASE ACTIVITY  12  3  11  2 
0%  10%  20%  30%  40%  50%  60%  70%  80%  90%  100% 
Better  Better, Following Startup  Little Difference  Worse 
Responses of 38 States reporting fully-implemented SDUs. 
Percentages based on the number of responses to each question. 
Service to Parents 
About two-thirds of managers believe their fully-implemented SDUs have improved 
service to parents. A concern of many familiar with child support enforcement is that 
customer service to parents might suffer due to centralized payment processing, but 
Staff who process payments in local child support and clerks of court offices often know 
many parents, have direct access to payment information and, reportedly, often provide 
highly personalized service. Managers report that some local staff use this case 
knowledge to identify poorly-labeled payments and to assist parents in dealing with 
situations of payment delays, job changes, and needs for new income withholding 
documents. Some are concerned that customer service might suffer because 
automated systems are not designed for such individualized case management. 
However, survey responses indicate that most State managers who compared 
customer service before and after SDU implementation believe their fully-implemented 
SDUs have improved service to parents. Among States reporting improvements, at 
least a quarter note that improvement was realized only after the startup period, 
possibly because parents needed to become accustomed to new systems and points of 
contact. 
12 
SDUs: State Implementation Progress  OEI 06-00-00040  Burden on Employers 
About two-thirds of managers believe fully-implemented SDUs ease the burden on 
employers, yet some perceive their SDU has made little difference to employers. One 
of the primary objectives of centralization is to ease the burden on employers in 
complying with income withholding orders by providing them with a single place to send 
payments in each State. While SDU managers in 20 States with operating SDUs 
believe centralization has eased the burden on employers, managers from 10 States 
perceive their SDU implementation had little effect on employers. In States only 
processing the Federally-specified caseload through their SDU, managers explain that 
employer burden may not decrease since only a portion of their employees cases are 
centralized. These systems require employers to send payments to one more place, 
instead of only one place as one manager said. Other managers express a belief that 
sending payments to a number of addresses was not particularly burdensome on 
employers, and thus, centralization may have had little effect. 
Undistributed Payments 
While more than half of managers believe undistributed payments have decreased 
since their SDU was fully-implemented, some report increases in undistributed 
payments. Managers in 18 States believe their SDU has helped minimize undistributed 
payments relative to previous local processing. However, six managers perceive their 
SDUs have contributed to increases in undistributed payments. Based on tracking, 
managers report that because of the large number of unidentifiable payments when 
States first centralize processing, undistributed payments tend to increase at startup, 
then decline as payments are identified through research. In some States, SDU 
managers indicate they could not divert sufficient staff from payment processing to 
researching unidentified payments, especially during the early weeks of centralized 
processing. 
SUMMARY 
A majority of States are currently processing payments centrally and all but one of the 
remaining States plan to implement their SDU by 2001. SDUs appear to have helped 
States improve program operations by taking advantage of the efficiencies of 
automated processing of a large number of payments on a daily basis. Most States 
report they are meeting the Federal requirements by disbursing the vast majority of 
payments within two business days, providing employers with a single location to mail 
income withholding payments, and providing parents with ready access to payment 
information. However, almost all States report experiencing significant difficulties during 
the early stages of their SDU implementation, and many States have yet to realize all 
the program improvements potentially attainable through centralized payment 
processing. 
In conducting this study, our objective was to systematically gather information about 
the perceptions and experiences of SDU program managers so it could be shared 
among all States as they cope with the new centralization requirements. We hope this 
report will be useful to policy makers and State administrators as they implement and 
refine their SDUs. 
13 
SDUs: State Implementation Progress  OEI 06-00-00040  We offer further analysis and recommendations about SDUs, their implementation, 
problems encountered, potential solutions, and keys to successful operations, in our 
companion report, States Disbursement Units: Sharing the Implementation Experiences 
of Six States, OEI 06-00-00041. 
AGENCY COMMENTS 
The Administration for Children and Families (ACF) agreed with the findings and 
conclusions presented in these two reports. ACF concurred with each of the 
recommendations directed to OCSE and recounted its efforts to assist States with SDU 
implementation. ACF also expressed a desire to collaborate with the OIG in quickly 
disseminating to States the information provided in these reports. ACF comments are 
provided in their entirety in Appendix B. 
14 
SDUs: State Implementation Progress  OEI 06-00-00040  ENDNOTES

1.Social Security Act, Title IV-D, SEC. 454B [42 U.S.C. 654b]. 
2.The required caseload includes all public assistance cases, plus non-public assistance cases 
requesting services and those cases with income withholding ordered on or after January 1, 
1994. 
3.OCSE Action Transmittal 00-03, January 19, 2000. 
4.States can receive enhanced FFP at 80 percent for some of their PRWORA-related 
expenses. If a State has not already used all of their enhanced funds, SDU development costs 
could be matched at the higher rate, but operational costs are limited to 66 percent. 
5.Hereafter, this report groups the District of Columbia, Puerto Rico, and the Virgin Islands with 
the 50 States. 
6.We interviewed local Clerks of Court in Arizona, Florida, Iowa, Pennsylvania, and 
Tennessee. In Minnesota, we interviewed local child support office staff. 
7.Indiana, South Carolina, and Wyoming received Federal waivers to link local disbursement 
units. 
8.Arkansas, Georgia, Kentucky, and Oklahoma report their SDUs are centrally processing 
payments of many cases, but have yet to include a significant portion of the Federally-required 
caseload. Michigan and Nevada were granted extensions to implement their SDU by October 
1, 2000 and October 1, 2001, respectively. Alabama, California, Kansas, Nebraska, Ohio, and 
Texas report they have not yet begun centralized payment processing. 
9.We did not specify a time frame for startup in our survey. We estimate State respondents 
may have considered startup to last between three and twelve months, depending upon 
whether they implemented their SDU all at once or incrementally. 
15 
SDUs: State Implementation Progress  OEI 06-00-00040  APPENDIX A  A - 1 
Table A-1: PROBLEMS COORDINATING  Startup Problems  Continuing Problems 
WITH PAYERS AND OTHER ENTITIES  Severity 
Total  Major  Moderate  Minor  Total  Major  Moderate  Minor  Of Problem
Getting checks mailed to SDU by parents  24  5  10  9  21  0  8  13  Decreased 34% 
Coordinating with employers  22  9  6  7  20  3  8  9  Decreased 26% 
Notifying employers and parents of changes  20  7  8  5  17  2  5  10  Decreased 38% 
Securing necessary funding  17  2  10  5  19  6  11  2  Increased 35% 
Coordinating with clerks of court  14  6  4  4  12  4  3  5  Decreased 23% 
Gaining necessary State legislative authority  14  3  6  5  6  2  3  1  Decreased 50% 
Negotiating acceptable terms with  12  1  7  4  12  0  7  5  Decreased 10% 
contractors 
Coordinating with local child support offices  13  1  4  8  7  0  0  7  Decreased 63% 
Tables A-1 and A-2 present SDU program manager responses about problems encountered during startup stages of SDU implementation, as well as 
continuing problems. Respondents ranked problems as major, moderate or minor. To allow comparison between these time periods, we gave a 
numerical value to each degree of problem. As shown in the example below, we gave the response major problem a value of 3, moderate 
problem a value of 2, and minor problem a value of 1. We then summed the values for each time period, subtracted the value of the continuing 
period from value for the startup period, and calculated a percentage decrease (or increase) in perceived severity of each problem. 
EXAMPLE: Getting Checks Mailed to SDU by Parents 
Startup Problem  Continuing Problem 
Major Problem:  5 States x 3 = 15  Major Problem:  0 x 3 =  0 
Moderate Problem:  10 States x 2 = 20  Moderate Problem:  8 x 2 = 16 
Minor Problem:  9 States x 1 =  9  Minor Problem:  13 x 1 = 13 
Total Value:  44  29 
Percent Change:  44 - 29 = 15  15/44 = 34% Decrease  APPENDIX A  A - 2

Table A-2: OPERATIONS PROBLEMS  Startup Problems  Continuing Problems 
Severity 
Total  Major  Moderate  Minor  Total  Major  Moderate  Minor  Of Problem
Identifying poorly labeled payments  28  10  7  11  30  7  6  17  Decreased 9% 
Identifying payments with no case in system  27  12  3  12  28  3  9  16  Decreased 20% 
Redirecting checks mailed to the wrong  26  7  10  9  21  2  8  11  Decreased 34% 
location 
Meeting customers service demands  26  13  5  8  25  6  8  11  Decreased 21% 
Securing, training and retaining staff  22  6  10  6  21  1  8  12  Decreased 30% 
Meeting the 48 hour disbursement  19  3  8  8  8  1  2  5  Decreased 64% 
requirement 
Predicting payment volume for staffing  18  4  4  10  14  0  5  9  Decreased 37% 
purposes 
Monitoring the performance of the SDU  14  3  4  7  11  2  1  8  Decreased 33%  APPENDIX B  B - 1
 APPENDIX B  B - 2 
COMMENTS OF THE ADMINISTRATION FOR CHILDREN AND FAMILIES ON THE

OFFICE OF INSPECTOR GENERAL'S DRAFT REPORTS: "CHILD SUPPORT

ENFORCEMENT STATE DISBURSEMENT UNITS, STATE IMPLEMENTATION

PROGRESS" (OEI-06-00-00040) AND "CHILD SUPPORT ENFORCEMENT STATE

DISBURSEMENT UNITS, SHARING THE IMPLEMENTATION EXPERIENCES OF SIX

STATES" (OEI-06-00-00041)

The Administration for Children and Families (ACF) does not

disagree with the findings and conclusions of these two draft

reports.  ACF welcomes the efforts of the Office of Inspector

General to examine this critical area of activity.  These reports

-- especially the one that recounts the experiences of six States

-- may be directly helpful to those States that have not yet

completed the implementation of their State Disbursement Units

(SDUs).  ACF intends to cooperate with the OIG in disseminating

these reports to the States as soon as they are available in final

form, in the expectation that the sooner States have an

opportunity to review the reports and incorporate their

experience, the greater is the likelihood that they will be able

to benefit from the reports' findings.

The Office of Child Support Enforcement (OCSE) within ACF has

worked extensively with both States and employers to assist in the

implementation of SDUs.  This work has been done by Central Office

staff and, to a large extent, by Regional Office staff.  For

example, OCSE has administered several technical assistance

efforts to improve SDU operation.  Workshops -- often featuring

State representatives -- were held at conferences to discuss State

implementation issues.  A technical assistance guide, developed

with the assistance of both Federal and State staff, was

distributed to all the States.  The guide focused on critical

considerations in planning an SDU, and in preparing a Request for

Proposal for centralized processing of child support payments. 

In addition, ACF maintains a matrix of SDU program and system

contacts.  The matrix includes such data as "contact" information

as well as the status of each State SDU and whether the function

is performed by the State or contracted out.  This information is

distributed to all States and displayed on the OCSE website. 

The employer services staff within OCSE works directly with

national employer groups to assist States and to resolve SDU-

related problems, and they work directly with Federal agency

payroll officials, as described below in response to the

recommendation regarding Federal government payers.
 APPENDIX B  B - 3 
OIG Recommendations

OCSE Should Collaborate With States to Encourage Federal

Government Payers to Improve Payment Labeling and Submission

Practices.  SDU managers in focus States cite particular

difficulties processing checks issued by Federal agencies.  They

report Federal checks often contain inadequate or confusing

information, are sometimes sent to the wrong location, and may be

submitted too early to allow proper disbursement to custodial

families.  OCSE should collaborate with States in communicating

and working with Federal employers to overcome these problems.

ACF Response

ACF agrees with this recommendation.  ACF is planning a

publication that will add to its ongoing activities to improve

federal check labeling and processes to assist State SDUs.  A

number of Staff of the Office of Child Support Enforcement (OCSE)

within ACF have provided technical assistance to SDUs through the

Federal Agency Initiative.  The Federal Agency Initiative at OCSE

is an effort to respond to SDUs' requests for help.  They are

asking for help both in re-directing child support payments from

Federal agencies, and in identifying the payer or the case with

which Department of the Treasury child support payments (paper

checks) should be associated.

ACF is completing a publication entitled Working with Federal

Agencies as Employers, which will be sent to all States.  This

publication will include detailed information on sending income

withholding orders to Federal agencies, re-directing child support

payments from Federal agencies to SDUs, identification of Treasury

checks, and moving toward electronic child support payments

(EFT/EDI).

ACF's activities on behalf of States and their SDUs have included

the following specific Federal agency efforts:

Defense Finance and Accounting Service or DFAS:

OCSE negotiated with DFAS to name two points-of-contact within the

DFAS Garnishment Department for States to contact for re-direction

of all DFAS child support payments (and spousal support if

appropriate) to SDUs.  This information was sent to all States in

a Dear Colleague Letter dated April 26, 2000.

In addition, OCSE worked out a process for re-direction of DFAS

(and other Federal agency) child support payments to SDUs as

follows:
 APPENDIX B  B - 4 
DFAS sends the State a file of all child support payments

currently being sent to that State. The State reviews the file to

make certain that each payment should indeed be re-directed to the

SDU.  This also gives the State an opportunity to make changes

(e.g., to the case ID by adding a FIPS code or other county

identifier to the payment record).

The State returns the file to DFAS, and DFAS makes the necessary

changes to re-direct the child support payments to the SDU.

Social Security Administration (SSA) and Department of the

Interior

OCSE worked with the Social Security Administration (SSA) to re-

direct its employees' child support payments to SDUs.  Payroll for

SSA is handled by the Department of the Interior.  Re-direction of

child support payments (and spousal support where appropriate)

from SSA employees was completed on February 23, 2000. 

OCSE has also been working with staff at the SSA Beneficiary

Garnishments Operations, who have the responsibility for re-

direction of beneficiaries' garnishment child support payments. 

SSA designated a contact at each of the eight payment processing

centers for States to work with in re-direction of SSA beneficiary

garnishment payments to SDUs.

U.S. Postal Service (USPS): 

OCSE has worked closely with the USPS as it re-directs child

support payments to the SDUs.  As a result, the USPS has begun a

pilot project to send child support payments electronically via

electronic funds transfer/electronic data interchange (EFT/EDI) to

eight SDUs.

Department of the Treasury

OCSE worked with the Department of Treasury's Financial Management

Service (FMS) to produce a memo, issued in March 2000, reminding

Federal payroll agencies to include certain standard identifying

data elements on the child support payments they prepare.  This is

an effort to reduce the number of unidentified Treasury checks

(which sometimes become undistributed collections).

OIG Recommendation

OCSE Should Provide Additional Technical Assistance to States to

Aid in the Transmission of Payments for Interstate Cases.  SDU

managers in focus States report unique difficulties in processing

payments for interstate cases, particularly SDUs being unaware

that obligors have cases in other States and the lack of any

standard procedures for transferring money and payment information

between States.  OCSE should further assist States in developing
 APPENDIX B  B - 5 
new solutions or using available technologies to share case

information between States, and help develop and implement

uniform, automated standards for transferring money and payment

information.

ACF Response

ACF agrees that additional technical assistance is needed by

States and their SDUs, and has plans in place to provide

additional assistance.  These plans include the dissemination of

these OIG reports, especially the Six State report, and the

conduct of national technical assistance activities on this

subject, for the benefit of State staff who manage and oversee

SDUs.  OIG staff will be invited to participate in these

activities, to present on the information and conclusions of these

reports, to discuss the lessons these reports offer, and to

respond to questions from the field.  Moreover, ACF will begin

working with representatives of State SDU's to identify specific

issues requiring technical assistance.

OIG Recommendation

To Help States Meet the Congressional Goal of Providing Employers

With a Single Location in Each State to Send all Child Support

Payments, OCSE Should Consider Proposing Legislation to Provide

States with Federal Matching Funds to Centrally Process Payments

for Income Withholding Cases Created Prior to 1994.  As detailed

above, there are numerous benefits to payers and the State when

all income withholding orders are processed centrally. 

Additionally, providing employers with a single location to send

payments was a primary objective of Federal law.  Federal matching

funds are currently not available for non-public assistance income

withholding cases created prior to 1994.  In response, some States

are still processing these cases locally.  This requires employers

to continue sending payments to multiple locations, and managers

in focus States report that it also causes confusion among payers,

local offices and SDUs.

ACF Response

ACF acknowledges that providing employers with a single location

to which payments would be sent was a central objective of Federal

policy when the SDUs were first required by law.  ACF will

consider this recommendation of the OIG as it develops the next

President's Budget and the next set of legislative proposals.