Department of Health and Human Services 
OFFICE OF 
INSPECTOR GENERAL 
Child Support for 
Children on TANF 
JANET REHNQUIST 
Inspector General 
FEBRUARY 2002 
OEI-05-99-00392  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 Chicago Regional Office prepared this report under the direction of William C. Moran, Regional 
Inspector General and Natalie Coen, Deputy Regional Inspector General. Principal OEI staff included: 
REGION  HEADQUARTERS 
Tom Komaniecki, Project Leader  Linda Hall, Program Specialist 
To obtain copies of this report, please call the Chicago Regional Office at (312) 353-4124. 
Reports are also available on the World Wide Web at our home page address: 
http://oig.hhs.gov/  EXECUTIVE SUMMARY 
PURPOSE 
To describe the alignment of the child support order with the earnings of non-custodial parents 
who have children on Temporary Assistance for Needy Families (TANF) and to describe the 
relationship of this alignment with their compliance with the support order. 
BACKGROUND 
An Office of Inspector General report entitled, The Establishment of Child Support Orders 
for Low-Income Non-custodial Parents (OEI-05-99-00390), examined the policies and 
practices used to determine the amount of child support paid by low-income non-custodial 
parents. The report found that methods used to determine support orders for low-income non-
custodial parents often yield poor compliance with the support order.  We followed up on a 
sample of 270 non-custodial parents used in our previous study and examined 4 years of 
earnings data and their compliance with their support orders. 
FINDINGS 
Over Half of Our Non-custodial Parents with Children on TANF Had Reported 
Earnings Below the Poverty Line 
In 1995, 55 percent of our non-custodial parents had earnings that were below the poverty line 
of $7,470 for one person.  Twenty percent had no reported earnings in 1995.  The overall 
average reported earnings for our low-income non-custodial parents was $8,460. The average 
reported personal income for males in 1995, according to Census data, was $31,454. 
From 1995 to 1998, the average reported earnings for non-custodial parents increased by 28 
percent with the largest increases occurring in those low-income non-custodial parents who had 
reported earnings that were below the poverty line in 1995. However, despite the overall 
increase in reported earnings, about 50 percent of our non-custodial parents still had reported 
earnings below the poverty line for 1998. 
i 
Child Support for Children on TANF  OEI-05-99-00392  Total Support Orders for Non-custodial Parents Below the Poverty Line Represent 
69 Percent of Their Reported Earnings 
The overall average of total support orders to reported earnings was 40 percent.  However, 
for non-custodial parents with reported earnings below poverty, total child support orders were 
69 percent of reported earnings for 1996. 
This ratio of 69 percent of child support ordered to reported earnings appears to exceed 
Federal law that prohibits States from garnishing more than 50 to 65 percent of income 
depending on whether the non-custodial parent was in arrears or supporting another family. 
The ratio also appears to exceed the limitations on maximum award levels in many States even 
for families with multiple children.  For example, Wisconsin limits the percent of income a non-
custodial parent has to pay as support to 34 percent when there are five or more children. 
Minnesota will set a support order as a percent of income as high as 50 percent when there are 
seven or more children and the non-custodial parent has a net monthly income of $1,001 or 
greater.  In our sample, the average number of children per non-custodial parent where support 
orders were in place was 1.4. 
Two Factors, Earnings and Retroactive Support, Have a Plausible Association 
with a Non-custodial Parents Compliance with a Child Support Order 
According to the Census Bureau, approximately 59 percent of all child support owed was paid 
in 1997.  This represents child support owed to families whether or not they are on TANF.  By 
way of comparison, our analysis revealed that over a 32 month period of time our non-custodial 
parents paid only 39 percent of the support owed to families on TANF.  A further examination 
of support order compliance reveal differences based on a  non-custodial parents earnings and 
the percent a support order represents of their earnings. 
In addition, the combination of factors, earnings and retroactive support, have a plausible 
association with a non-custodial parent's support order compliance. Previous work examining 
State policies indicated that the number of months of retroactive support affected the parents 
compliance with their support order.  Our analysis indicated that earnings before order 
establishment, increases in reported earnings and the number of months of retroactive support 
impact compliance.  Low reported earnings before order establishment and the number of 
months of retroactive support tended to have negative impact on compliance. Increases in 
earnings and a lower proportion of award to earnings tend to have a positive effect on 
compliance. 
CONCLUSION 
The most effective way to achieve both immediate and long-term child support payments for 
children on TANF is to set realistic support orders when compared to a non-custodial parents 
earnings. The support order can be raised gradually as a non-custodial parents earnings 
increase. This action would likely result in increasing child support payments rather than starting 
with a support order that is unrealistic when compared to a non-
ii 
Child Support for Children on TANF  OEI-05-99-00392  custodial parents earnings.  Meanwhile, as a non-custodial parent is increasing their earnings 
and support payments, a custodial parent can rely on TANF to support the family.  Starting a 
support order too high is more likely to have the opposite effect on payment compliance with 
little improvement over time. 
This is consistent with the conclusions made in our earlier work examining State policies used in 
the establishment of child support orders for low-income non-custodial parents. At that time, 
we believed that States should experiment with State policies that determine the amount low-
income non-custodial parents must pay in child support. 
As a response to our earlier work, the Administration for Children and Families, (ACF) Office 
of Child Support Enforcement issued a Policy Interpretation on September 14, 2000 to all 
State IV-D Directors regarding program flexibility with respect to low-income non-custodial 
parents. In that letter, the Office of Child Support Enforcement informed States that they 
currently have the flexibility to substantially address all the issues raised in our earlier work. 
We continue to encourage States to experiment with policies dealing with low-income non-
custodial parents.  We recognize that some of the experiments with policies dealing with low-
income non-custodial parents may require additional resources. We also continue to advocate 
that the Office of Child Support Enforcement encourage, facilitate and evaluate State 
experiments that address concerns raised in our earlier work. 
AGENCY COMMENTS 
We received comments from the Administration for Children and Families. They agree with 
our conclusion and described a number of specific actions which they have taken to address 
findings in this and related prior reports.  In addition, ACF is providing waivers and 
demonstration projects to address the complex issues which impede low income non-custodial 
parents from supporting their families.  Finally, ACF is preparing a detailed action plan on 
improving the collection and distribution of child support nationwide. The action plan will 
include programmatic innovations to address the needs of low-income, non-custodial parents as 
they move towards full responsibility for supporting their children. A complete text of their 
comments can be found in Appendix C. 
iii 
Child Support for Children on TANF  OEI-05-99-00392  T A B L E   O F   C O N T E N T S  
EXECUTIVE SUMMARY

INTRODUCTION ............................................................. 1

FINDINGS  .................................................................. 6

Reported earnings below poverty line ..........................................6

Percent of support orders to earnings  ..........................................7

Compliance associated with earnings and retroactive support  ........................9

CONCLUSION  ............................................................. 12

AGENCY COMMENTS  ...................................................... 13

APPENDIX A: Confidence Intervals  ..............................................14

APPENDIX B: Regression Model................................................ 17

APPENDIX C: Agency Comments  ...............................................19

iv 
Child Support for Children on TANF  OEI-05-99-00392  INTRODUCTION 
PURPOSE 
To describe the alignment of the child support order with the earnings of low-income non-
custodial parents with children on Temporary Assistance to Needy Families and to describe the 
relationship of this alignment with their compliance with the support order. 
BACKGROUND 
Child Support Enforcement 
The Child Support Enforcement (CSE) program was created in 1975 with the addition of Part 
D to Title IV of the Social Security Act.  The CSE program was initiated as a joint Federal-
State effort to contend with growing public expenditures on welfare and the lack of paternity 
establishment for children born outside of marriage.  The States were assigned the responsibility 
for administering the program through IV-D agencies (referring to the related title of the Social 
Security Act). These agencies are charged with locating absent parents, establishing paternity 
and collecting child support with technical and operational assistance from the Federal Office of 
Child Support Enforcement (OCSE). 
The establishment of orders for child support enforcement cases occurs through either judicial 
or administrative processes. Federal law requires States to establish child support orders in 
accordance with State guidelines, outlining specific descriptive and numeric criteria.  Any 
deviation from the presumptive guideline amount must be justified in writing. 
States generally use one of three types of guidelines in establishing child support orders.  Most 
States (31) use the Income Shares approach which uses the combined income of both 
parents to determine the child support order. This method tries to guarantee that the child 
receives the same proportion of income that they would have received had the parents stayed 
together. Fifteen States use a percentage of income approach. This method uses the number 
of eligible children to determine the percentage of the non-custodial parents income.  A few 
States use the Melson-Delaware approach which provides for a minimum self-support 
reserve before prorating the cost of raising the child between the parents. 
States also have some procedures to establish an order for a non-custodial low-income parent. 
States are almost evenly split in the how they approach determining an award for a low-income 
parent. Some States leave the decision to the courts discretion while other States make a 
presumptive award unless there is evidence that supports a lower award. The remaining States 
set mandatory minimums that cannot be adjusted downwards. 
1 
Child Support for Children on TANF  OEI-05-99-00392  States can also hold a non-custodial parent responsible for retroactive support.  The child 
support enforcement community sees retroactive support as a disincentive to non-custodial 
parents to delay the establishment of the support order. Retroactive support is also seen as 
holding the non-custodial parents accountable for supporting their children and recouping 
expenses incurred by the State or the custodial parent. 
Increasing Attention to the Treatment of Low-income Non-custodial Parents 
Earnings of non-custodial parents can be divided into three income tiers: high, middle and low. 
The percentage of non-custodial parents who do not pay their child support is greatest in the 
low-income tier. 
While some low-income non-custodial parents are delinquent because they are unwilling to pay 
support, an estimated 60 percent have a limited ability to pay child support based on their 
income levels, employment history, education levels and rates of institutionalization. These non-
custodial parents are known in the child support community as dead broke rather than dead-
beat. 
The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 presented a 
package of temporary aid and opportunities for welfare mothers to become self-sufficient. 
Child support payments are seen as a vital ingredient to this self-sufficiency.  To increase child 
support payments to former welfare families, the limited earnings of non-custodial parent need 
to be addressed. 
In the wake of welfare reform, more attention is being devoted to how to improve the family 
maintenance contributions of low-income fathers to parallel the welfare-to-work initiatives for 
low-income mothers. Three developments demonstrate this trend. 
C	 A portion of welfare-to-work funds in the Balanced Budget Act of 1997 was 
designated to help low-income fathers secure employment, pay child support and 
increase their involvement with their children.  In March 2000, the Department 
announced $15 million in combined Federal and private funding for demonstration 
projects serving non-custodial parents who do not have a child support order in place 
and may face obstacles to employment. 
C	 Amendments to the welfare-to-work law in the November 1999 Consolidated 
Appropriations Act broadened the eligibility requirements for non-custodial parents to 
participate in the services available through welfare-to-work programs. 
C	 Publication of A Guide to Funding Services for Children and Families Through the 
Temporary Assistance for Needy Families (TANF) Program by the Administration 
for Children and Families (ACF) which provides examples of ways States can use their 
TANF funds to support responsible fatherhood efforts and employment of non-
custodial parents. About half of the States have allocated some TANF funds to 
support responsible fatherhood programs. 
To increase the payment of child support by low-income non-custodial parents, representatives 
of the child support community have begun to explore other avenues 
2 
Child Support for Children on TANF  OEI-05-99-00392  beyond punitive enforcement. We examined the relationship between earnings and support 
order establishment and how this impacts overall compliance with the support orders. 
Previous Office of Inspector General Work 
In July 2000, the Office of Inspector General (OIG) released two reports entitled The 
Establishment of Child Support Orders for Low-Income Non-Custodial Parents, OEI-05-
99-00390 and State Policies Used to Establish Child Support Orders for Low-income 
Non-custodial Parents, OEI-05-99-00391. These reports examined the policies and 
practices, such as minimum support orders and retroactive support, used by States to 
determine the amount of child support paid by low-income non-custodial parents. The report 
found that methods used to determine support orders for low-income non-custodial parents 
often yield poor compliance with the support order. 
The OIG and OCSE have a joint enforcement effort targeted at higher income obligors with the 
most egregious arrears. The focus of this successful initiative is the criminal pursuit of non-
support. 
METHODOLOGY 
We selected a random sample of cases (and the 10 States associated with them) using a two-
stage, stratified cluster sample.  We stratified the United States (excluding Alaska and Hawaii) 
into three strata based on State policy regarding establishment of minimum awards for low-
income obligors. We then divided each State into a number of case clusters based on the 
estimated number of child support cases per State.  From each stratum, we randomly selected 
three or four clusters. The States containing the randomly selected clusters became our sample 
States, shown below in Table 1. 
3 
Child Support for Children on TANF  OEI-05-99-00392  Table 1 
Stratum  Description of how State  Clusters Population  Sample 
policy treats low-income 
non-custodial parents 
1  Awards in courts discretion  893 Clusters in 16  3 Clusters in MS, 
States  OK and PA 
2  Presumptive awards  (e.g.  614 Clusters in 18  3 Clusters in TX, 
minimum wage)  States  VA and WA 
3  Mandatory minimum awards  652 Clusters in 14  4 Clusters in CO, 
States plus District  MA, MD and NY 
of Columbia 
For stratum three, we randomly selected two replacement clusters because our first selections, 
Michigan and Indiana, declined to participate in the study.  Because of this replacement, we 
projected our statistics to a population that excludes the clusters for Michigan (153 clusters) 
and Indiana (35 clusters). 
We conducted case record reviews in each of the 10 States. From these States, we obtained 
data on all child support cases in which (1) the child support order was established during 
1996, (2) the custodial parent was on Aid to Families with Dependent Children (AFDC) or 
Temporary Assistance to Needy Families (TANF) at the time the order was established and 
(3) the case was still open. 
We randomly assigned the non-custodial parents for these cases to each States clusters. We 
then randomly selected one cluster per State for our sample. From these clusters, we randomly 
selected a sample (usually 35 per cluster) of non-custodial parents.  We reviewed all child 
support cases for each non-custodial parent in our sample, including any cases the non-
custodial parent had open for other children. This resulted in an initial sample of 281 non-
custodial parents with 402 child support cases of which 298 cases had been established during 
1996 in the sampled States.  Data on the methods used to establish support orders and 
subsequent payments generated is based on the cases established during 1996 in the sampled 
States. 
We then matched this initial sample of 281 non-custodial parents with Internal Revenue Service 
(IRS) records to obtain reported earnings from 1995 to 1998. Our analysis uses earnings as 
reported to IRS. We were able to obtain reported earnings for 270 of the 281 non-custodial 
parents. This resulted in a final sample of 270 non-custodial parents with 376 child support 
cases of which 273 had been established in 1996. The reasons for no reported earnings can 
not be ascertained from the data used for this report. 
The payment period we examined on all cases is 32 months as this was the period of time for 
which all cases had the opportunity for payment. Thirty-two months is the minimum amount of 
time between the last month in which sampled orders were established, 
4 
Child Support for Children on TANF  OEI-05-99-00392  December 1996, and the last month for which we had access to payment information for all 
cases, August 1999. Except where specified, the statistics in this report are weighted to reflect 
all levels of clustering and stratification.  All reported correlations are statistically significant at 
the 90 percent confidence level or greater. 
To measure a non-custodial parents relationship to poverty, we used the poverty guidelines 
issued by the Department. In all cases, the figures shown for the poverty line are for one 
person. 
Our review was conducted in accordance with the Quality Standards for Inspections issued 
by the Presidents Council on Integrity and Efficiency. 
5 
Child Support for Children on TANF  OEI-05-99-00392  FINDINGS 
Over half of our non-custodial parents with children on TANF 
had reported earnings below the poverty line 
In 1995, average reported earnings for our entire sample of non-custodial parents 
was $8,460 
In 1995, 55 percent of our low-income non-custodial parents had reported earnings that were 
below the poverty line of $7,470 for one person. Of the 55 percent, 20 percent had no 
reported earnings in 1995.  Twenty-three percent had reported earnings between one and two 
times the poverty line, while 21 percent of low-income non-custodial parents had reported 
earnings of more than $14,940. The median income for our entire sample was $5,468 in 1995. 
In comparison, the average reported personal income for males in 1995, according to the U.S. 
Census Bureau, was $31,4541 with a median income of $22,5622. 
From 1995 to 1998, the average reported earnings for non-custodial parents increased by 28 
percent. For the same time period, the overall increase in reported income according to U.S. 
Census Bureau figures, was 15 percent for males.  The change in the consumer price index was 
about 7 percent over the same period of time.  Despite the overall increase in reported 
earnings, about 50 percent of our low-income non-custodial parents still had reported earnings 
below the poverty line of $8,050 in 1998.  In 1998, the average reported earnings for our non-
custodial parents were $10,796 with a median income of $7,884 (See Table 2). 
Table 2 
Reported Earnings  Mean  Median 
1995  $8,460  $5,468 
1996  $9,639  $7,565 
1997  $10,081  $7,998 
1998  $10,796  $7,884 
Source: OIG Analysis 
1	
U.S. Census Bureau; "Historical Income Tables - People, (Table) P-3. Race and Hispanic Origin of 
People by Mean Income and Sex: 1947-1999;" created February 7, 2001 ; 
<http://www.census.gov/hhes/income/histinc/p03.html> 
2	
U.S. Census Bureau; "Historical Income Tables - People, (Table) P-2. Race and Hispanic Origin of 
People by Median Income and Sex: 1947-1999;" created February 7, 2001 ; 
<http://www.census.gov/hhes/income/histinc/p02.html> 
6 
Child Support for Children on TANF  OEI-05-99-00392  The largest increase in reported earnings was among those low-income non-custodial parents 
who had reported earnings that were below the poverty line in 1995. This group of low-
income non-custodial parents saw increases in reported earnings of nearly 200 percent although 
this represented an increase of $3,732 to an average reported earnings of $5,631 in 1998. 
Those low-income non-custodial parents who had reported earnings in excess of $14,940 saw 
a decrease of 5 percent in reported earnings from 1995 to 1998. 
Overall, 8 percent of our low-income non-custodial parents had no reported earnings from 
1995 through 1998. In comparison, 1 in 6 non-custodial parents in our sample had increases in 
reported earnings in each year between 1995 and 1998. 
Total support orders for low-income non-custodial parents 
below the poverty line represents 69 percent of their earnings 
The average amount of total support ordered for 1996 for low-income non-custodial parents 
below the poverty line in 1996 was $1,249 representing 69 percent of earnings. This amount 
includes all child support for which the non-custodial parent is responsible for paying. 
In 1996, the overall average of total child support orders in our sample was $1,552 which 
represented 40 percent of reported earnings. For non-custodial parents with reported earnings 
in excess of two times the poverty, total support orders were 9 percent of reported earnings. 
This ratio of 69 percent of child support ordered to reported earnings appears to exceed 
Federal law that prohibits States from garnishing more than 50 to 65 percent of income 
depending on whether the non-custodial parent was in arrears or supporting another family. 
The ratio also appears to exceed the limitations on maximum award levels in many States even 
for families with multiple children.. For example, Wisconsin limits the percent of income a non-
custodial parent has to pay as support to 34 percent when there are five or more children. 
Minnesota will set a support order as a percent of income as high as 50 percent when there are 
seven or more children and the non-custodial parent has a net monthly income of $1,001 or 
greater.  In our sample, the average number of children per non-custodial parent where support 
orders were in place was 1.4. 
Monthly child support obligations increase as earnings increase 
In our sample, we found that, on average, as a non-custodial parents income increased the 
amount of the support order established increased. For example, in 1996 the average child 
support order was $141 for non-custodial parents reporting earnings below the poverty line in 
1995. The average monthly child support order for non-custodial parents who had reported 
earnings of twice the poverty line in 1995 was $282. The overall 
7 
Child Support for Children on TANF  OEI-05-99-00392  average amount of monthly child support obligations established in 1996 was $184 (See Table 
3). 
Table 3 
Relationship to Poverty line for  Monthly Child Support 
1995  Order 
Poverty line or below  $141 
1 to 2 times poverty  $195 
More than 2 times poverty  $282 
Source: OIG Analysis 
Federal law requires that States use an established set of guidelines upon which to base child 
support orders. However, most States have a process that allows exceptions which can be 
used when establishing support orders for low-income non-custodial parents.  These processes 
range from allowing the order to deviate from the guidelines because of low-income to 
establishing minimum support orders. However, in cases where a minimum support order is 
part of the States guidelines, the State must allow some mechanism that can be used to show 
that the minimum order would be inappropriate. Our previous work found that 36 percent of 
cases established with a minimum order cases made no payments toward their support 
obligation compared to 20 percent of cases established with a non-minimum order.3 
Two factors, earnings and retroactive support, have a 
plausible association with a non-custodial parents 
compliance with a child support order 
Over a 32-month period, non-custodial parents of TANF children paid on average 
only 39 percent of child support owed 
3	
U.S. Department of Health and Human Services, Office of Inspector General, The Establishment of 
Child Support Orders for Low-income Non-custodial Parents, OEI-05-00390, July 2000, pg. 18. 
8 
Child Support for Children on TANF  OEI-05-99-00392  According to the U.S. Census Bureau, in 1997 non-custodial parents complied with 59 percent 
of the support owed4  This represents child support owed to families receiving TANF and 
those not receiving TANF.  By way of comparison, our analysis revealed that over a 32 month 
period of time our non-custodial parents paid only 39 percent of the support owed to families 
receiving TANF.  Our examination of compliance does not account for any informal or in-kind 
support provided by a non-custodial parent. 
According to our sample, those non-custodial parents who had no reported income in 1995, 
the year prior to the establishment of their support orders, complied with 17 percent of the child 
support due over a 32-month period of time.  Over the same 32-month period of time,  non-
custodial parents who had reported earnings in excess of two times the poverty line in 1995 
complied with 62 percent of the child support due (See Chart 1). 
For all non-custodial parents in our sample, those non-custodial parents whose support orders 
in 1996 were 15 percent or less of their income complied with 61 percent of their support 
order. Non-custodial parents who had support orders that were more than 20 percent of 
income in 1996 complied with 20 percent of their support order. 
The combination of factors, earnings and retroactive support, have a plausible 
association with a non-custodial parents support order compliance 
Chart 1 
4 
U.S. Census Bureau; "Table 1. Child Support Payments Due and Actually Received, by Gender 
1997 (People 15 years and older with own children under 21 years of age present from an absent 
parent as of spring 1998)" Revised October 13, 2000; 
<http://www.census.gov/hhes/www/childsupport/97tables/tabl.html> 
9 
Child Support for Children on TANF  OEI-05-99-00392  We examined how the various factors discussed in previous sections interact with each other in 
being able to predict a non-custodial parents compliance with their support order. We found 
that the earnings of non-custodial parents with children on TANF and a State policy of 
charging retroactive support have a plausible association with their compliance with the support 
order. 
We examined the non-custodial parents income in the year before the support order was 
established as it relates to the poverty line for 1995. We grouped the low-income non-
custodial parents income into three categories: below the poverty line, one to two times the 
poverty line, and more than two times the poverty line.  In addition, we looked at whether the 
low-income non-custodial parent had an increase in reported earnings from 1995 to 1998. 
We also reviewed whether the State charged the non-custodial parent with any front end fees 
including retroactive support. Our previous work found that the longer the time for which non-
custodial parents are charged retroactive support, the less likely they are to make any payments 
on their child support order once established.5 
Finally, we calculated the percent of the total support order to the low-income non-custodial 
parents income.  We categorized the percent of support order to income into three categories. 
We defined a support order as low if the order was less than 15 percent,  as medium if the 
order was 15 to 20 percent, and as a high if the order was 20 percent or more of income. 
Our analysis indicates that non-custodial parents, with income below the poverty line the year 
before the establishment of the support order, comply with less of their support. In addition, 
when front-end fees such as retroactive support are added to the non-custodial nts support 
order it decreases compliance with the support order. However, when a non-custodial parent 
experiences increases in reported earnings over the time period examined, compliance 
increases  (See Appendix B for the results of our analysis). 
Table 4 
Non-Custodial  Increases In  Front-end fees  Percent of  Predicted 
Parent's Earnings  Income  Support Order to  Compliance 
Income 
A.  < $7,470  No  Yes Low (<15%)  19% 
B.  < $7,470  Yes  No Low (<15%)  54% 
C.  < $7,470  Yes  Yes Low (<15%)  44% 
D.  < $7,470  No  No Low (<15%)  29% 
Source: OIG Analysis 
5	
U.S. Department of Health and Human Services, Office of Inspector General, The Establishment of 
Child Support Orders for Low-income Non-custodial Parents, OEI-05-00390, July 2000, pg. 13. 
10 
Child Support for Children on TANF  OEI-05-99-00392  Table 4 presents predicted compliance rates for a few typical cases to show how changes in a 
non-custodial parents situation effect compliance. As demonstrated in Row A, when a non-
custodial parent has earnings below the poverty line, with no increases in income and front-end 
fees charged, their predicted compliance with their support order is 19 percent. However, 
when that same low-income non-custodial parent has an increase in reported earnings over the 
time period examined (Row C), their compliance with their support order is 44 percent. 
11 
Child Support for Children on TANF  OEI-05-99-00392  CONCLUSION 
The most effective way to achieve both immediate and long-term child support payments for 
children on TANF is to set realistic support orders when compared to a non-custodial parents 
earnings. The support order can be raised gradually as a non-custodial parents earnings 
increase. This action would likely result in increasing child support payments rather than starting 
with a support order that is unrealistic when compared to a non-custodial parents earnings. 
Meanwhile, as a non-custodial parent is increasing their earnings and support payments, a 
custodial parent can rely on TANF to support the family.  Starting a support order too high is 
more likely to have the opposite effect on payment compliance with little improvement over 
time. 
This is consistent with the conclusions made in our earlier work examining State policies used in 
the establishment of child support orders for low-income non-custodial parents. At that time, 
we believed that States should experiment with State policies that determine the amount low-
income non-custodial parents must pay in child support. 
As a response to our earlier work, the Administration for Children and Families, Office of Child 
Support Enforcement issued a Policy Interpretation on September 14, 2000 to all State IV-D 
Directors regarding program flexibility with respect to low-income non-custodial parents. In 
that letter, OCSE informed States that they currently have the flexibility to substantially address 
all the issues raised in our earlier work. 
We continue to encourage States to experiment with policies dealing with low-income non-
custodial parents.  We recognize that some of the experiments with policies dealing with low-
income non-custodial parents may require additional resources. We also continue to advocate 
that OCSE encourage, facilitate and evaluate State experiments that address concerns raised in 
our earlier work. 
12 
Child Support for Children on TANF  OEI-05-99-00392  AGENCY COMMENTS 
We received comments from the Administration for Children and Families. They agree with 
our conclusion and described a number of specific actions which they have taken to address 
findings in this and related prior reports.  In addition, ACF is providing waivers and 
demonstration projects to address the complex issues which impede low income non-custodial 
parents from supporting their families.  Finally, ACF is preparing a detailed action plan on 
improving the collection and distribution of child support nationwide. The action plan will 
include programmatic innovations to address the needs of low-income, non-custodial parents as 
they move towards full responsibility for supporting their children. A complete text of their 
comments can be found in Appendix C. 
13 
Child Support for Children on TANF  OEI-05-99-00392  APPENDIX A 
Confidence Intervals

Percent of Non- Standard  90 % Confidence 
Custodial Parents  Error 
Upper Limit  Lower Limit 
1995 - Earnings below  55%  3.73  61%  49% 
$7,470 
1995 - Earnings between  23%  1.83  26%  20% 
$7,471 and $14,940 
1995 - Earnings greater  21%  3.84  28%  15% 
than $14,940 
1995 - No reported  20%  3.37  25%  14% 
earnings 
No earnings over 4 year  8%  0.92  10%  7% 
period of time 
1998 - Earnings below  50%  6.3  60%  40% 
$8,050 
Increase in earnings in  17%  2.76  22%  13% 
each year over the 4 year 
period 
Mean  Standard  90 % Confidence 
Error 
Upper Limit  Lower Limit 
1995 Reported Earnings  $8,460  866  $9,884  $7,036 
1996 Reported Earnings  $9,639  954  $11,208  $8,069 
1997 Reported Earnings  $10,081  857  $11,490  $8,672 
1998 Reported Earnings  $10,796  975  $12,399  $9,193 
1996 Total support  $1,249  142  $1,482  $1,015 
ordered for non-custodial 
parents below the poverty 
line 
14 
Child Support for Children on TANF  OEI-05-99-00392  Mean  Standard  90 % Confidence 
Error 
Upper Limit  Lower Limit 
1996 Total support  $1,552  175  $1,841  $1,264 
ordered for all non-
custodial parents 
1996 Report earnings for  $1,974  360  $2,566  $1,381 
non-custodial parents 
below poverty line 
1995 - Earnings below  $141  9.58  $157  $125 
$7,470 
1995 - Earnings between  $195  18.31  $225  $165 
$7,471 and $14,940 
1995 - Earnings greater  $282  50.81  $366  $199 
than $14,940 
Monthly order for all non- $184  14.15  $207  $161 
custodial parents 
Median  Standard  90 % Confidence 
Error 
Upper Limit  Lower Limit 
1995 Reported Earnings  $5,468  $1,001  $7,115  $3,820 
1996 Reported Earnings  $7,565  $1,208  $9,552  $5,578 
1997 Reported Earnings  $7,998  $955  $9,569  $6,426 
1998 Reported Earnings  $7,884  $1,650  $10,599  $5,169 
15 
Child Support for Children on TANF  OEI-05-99-00392  Total Support as  Standard  90 % Confidence 
a Percent of  Error 
Upper Limit  Lower Limit 
Income 
1996 - Earnings below  69%  0.04  76%  62% 
$7,740 
1996 - Earnings between  14%  0.04  17%  11% 
$7,741 and $15,480 
1996 - Earnings greater  9%  0.02  13%  5% 
than $15,480 
All non-custodial parents  40%  0.04  47%  34% 
16 
Child Support for Children on TANF  OEI-05-99-00392  APPENDIX B 
Regression Model of Child Support Compliance 
We used SUDAAN to perform our regression analysis.  SUDAAN only uses observations where all 
the data were present. We did not have complete information for 22 low-income non-custodial 
parents. 
The following table shows the overall regression for our model.  The table includes the estimate, 
standard error, t-value and significance level (probability > |t|). The t-value for each variable tests for 
the effect of each independent variable on the dependent value. The last column gives the probability of 
the t-value. The t-values and the associated probabilities (probability > |t|) test 
Regression Model of Child Support Compliance 
Parameter  Standard Error  t-value  Probability 
> |t| 
A. Intercept  .2485  .1522  1.63  .1466 
B. Non-Custodial Parents 
Income Below $7,470  -.1682*  .0719  -2.34  .0519 
C. Non-Custodial Parents 
Income $7,471 - $14,940  (Omitted 
category) 
D. Non-Custodial Parents 
Income Above $14,941  .1014  .0551  1.84  .1084 
E. Increase In Income From 
1995-1998  .2545**  .0341  7.46  .0001 
F. Front-end Fees Charged 
(including retroactive support)  -.1050**  .0220  -4.77  .0020 
G. Low Order (<15%)  .2104  .1148  1.83  .1095 
H. Medium Order (15-20%)  Omitted 
category) 
I.  High Order (>20%)  .0213  .0996  .21  .8371 
*  Statistically Significant at .10 level 
** Statistically Significant at .05 level 
17 
Child Support for Children on TANF  OEI-05-99-00392  the hypothesis that the parameter is actually zero and answers the question: If the true slope and 
intercept were zero, what would the probability be of obtaining, by chance alone, a value as a large or 
larger than the one actually obtained. 
The R-square term indicates the percentage of the variation explained by the model. The R-square 
value is .31 indicating that 31 percent of the variation in the proportion of child support paid is 
explained by the model. 
18 
Child Support for Children on TANF  OEI-05-99-00392  APPENDIX C 
Agency Comments

19 
Child Support for Children on TANF  OEI-05-99-00392  APPENDIX C 
Agency Comments 
COMMENTS OF THE ADMINISTRATION FOR CHILDREN AND FAMILIES ON 
THE OFFICE OF INSPECTOR GENERAL (OIG) DRAFT REPORT:  CHILD 
SUPPORT FOR CHILDREN ON TANF(OEI-05-99-00392) 
The Department of Health and Human Services (Department) appreciates the 
opportunity to comment on this draft report, which addresses an important topic. 
General Comments 
This report was one of a series the Office of Inspector General (OIG) prepared on 
policies and practices in Child Support Enforcement that impact on low income, non-
custodial parents.  It concluded that the most effective way to achieve both immediate 
and long-term child support payments for children in the Temporary Assistance for 
Needy Families (TANF) program is to set realistic support orders that, given the low-
income status of many of these childrens non-custodial parents, they would be able to 
meet.  The OIG encourages states to experiment with policies dealing with low-
income, non-custodial parents and encourages the Office of Child Support 
Enforcement (OCSE) to facilitate and evaluate state experiments that address concerns 
raised in their work.  The report contains no specific recommendations. 
ACF Comment 
The OCSE recognizes that we have the responsibility to work with low-income, non-
custodial parents to encourage the long-term goals of a regular job, regular payment of 
child support and participation in their children s lives.  As the reports recognized, 
states are in the best position to conduct such experiments, but OCSE can encourage, 
facilitate and evaluate state experimentation. 
As OIG noted in the report, OCSE issued a Policy Interpretation Question (PIQ-00-03) 
on September 14, 2000, in response to an earlier work.  This PIQ clarifies the 
flexibility that exists under Federal Title IV-D requirements in setting support 
obligations and securing collections from low-income, non-custodial parents.  The PIQ 
addressed the recommendations of the OIG report and encouraged states to develop 
relationships with, and make referrals to, employment programs, such as the 
Department of Labors Welfare-to-Work (WTW) program.  The PIQ explained that 
states should not retroactively modify arrearages, but have the discretion to 
compromise or forgive arrears owed to the state.  It also enumerated steps states can 
take to limit the number of default cases in which the obligors income is imputed 
because he or she does not appear for trial, and instead, to set child support orders 
based upon actual income.  The OCSE also encouraged states to assist low-income, 
non-custodial parents by using case management techniques and by training staff to 
refer non-paying obligors to appropriate services. 
In addition to the PIQ, OCSE has issued guidance on the WTW program to encourage 
state Title IV-D agencies to collaborate with WTW grantees to help them serve low-
20 
Child Support for Children on TANF  OEI-05-99-00392  APPENDIX C 
Agency Comments 
parents.  The OCSE's Regional Offices convened a meeting of federal, state and local 
staff to discuss child support arrears management and develop strategies states can use to 
avoid or minimize the accrual of large amounts of arrears and how to manage arrears for 
low-income, non-custodial parents, if arrears do accumulate.  A report of the findings is 
available to all states for their reference. In addition, OCSE is providing waivers to ten 
states to run Fragile Family Demonstration projects. The projects test approaches to 
serving young never married, non-custodial parents who may have obstacles to 
employment and who do not have a child support order.  Each of the projects includes an 
independent evaluation.  The OCSE has also announced the availability of funds for state 
demonstration grants for broad collaborative efforts and outreach by child support 
agencies with a wide range of human services programs, faith-based organizations and 
community groups.  This is to promote family self-sufficiency by addressing the complex 
issues, which impede low-income, non-custodial parents from supporting their families. 
This winter, ACF will submit to the Secretary an Action Plan setting out a bold 
comprehensive agenda for improving collection and distribution of child support 
nationwide.  The Action Plan will include a section of programmatic innovations to 
address the needs of low-income, non-custodial parents as they move toward full 
responsibility for supporting their children.  We will make good use of the OIG studies in 
developing these plans, and we appreciate the usefulness of this work as guidance for our 
efforts. 
21 
Child Support for Children on TANF  OEI-05-99-00392