Department  of Health  and Human  Services 
OFFICE  OF 
INSPECTOR  GENERAL 
Implementation  of  State  Child  Support 
Certified  Data  Systems 
JUNE  GIBBS  BROWN 
Inspector  General 
APRIL4 1997 
OEI-O4-%OOOlO  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 Evaluationa nd 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. 
OEIs  Atlanta  Regional  Office  prepared  this  report  under  the  direction  of Jesse  J. 
Flowers,  Regional  Inspector  General,  and  Christopher  Koehler,  Deputy  Regional 
Inspector  General.  Principal  OEI  staff  included: 
REGION  HEADQUARTERS 
Peggy Daniel,  Project Leader  Alan Levine, Program Specialist 
Ron  Kalil,  Team  Leader  Wm. Mark Krushat, Sc.D. 
Jackie Watkins, Program Analyst  Ann OConnor, Program Specialist 
Tammy Hipple, Program Analyst 
To obtain a copy of this report, call the Atlanta  Regional Office at 404-331-5748.  Department  of Health  and Human  Services 
OFFICE  OF 
INSPECTOR  GENERAL 
Implementation  of  State  Child  Support 
Certified  Data  Systems 
JUNE GIBBS BROWN 
Inspector  General 
APRIL  1997 
OEI-04-96-00010  EXECUTIVE  SUMMARY 
PURPOSE 
To  describe  State  IV-D  Child  Support  Enforcement  Agencies  experiences  in 
implementing  certified  automated  data  systems. 
BACKGROUND 
The  Child  Support  Enforcement  program  was established  in  1975 as Title  IV-D  of the 
Social  Security  Act.  Its purpose  is to locate  noncustodial  parents,  establish  paternity, 
establish  and  enforce  child  support,  and  collect  child  support  payments.  State  Title 
IV-D  Child  Support  Agencies  manage  and  operate  child  support  programs. 
Because  of escalating  non-support  for  children  by noncustodial  parents,  and  a public 
need  for  responsive  child  support  enforcement  programs,  the  Administration  and  the 
Congress  have  long  been  interested  in improving  data  systems  for  child  support.  As a 
result  of this  interest,  the  1988 Family  Support  Act  required  each  State  to  develop  a 
Statewide  automated  data  system  that  had  the  capability  to control,  account  for,  and 
monitor  all processes  for  determining  paternity  and  collecting  child  support. 
The  1988 Act  also  set  October  1, 1995 as the  deadline  for  States  to implement  the 
required  certified  automated  child  support  data  system.  However,  only  one  State  met 
the  October  1, 1995 deadline  for  implementing  a certified  automated  data  system  for 
child  support  enforcement.  As a result,  on  October  11, 1995, Congress  passed 
legislation  to  authorize  a 2-year  extension  of the  deadline  -- until  October  1, 1997. 
Federal  and  State  expenditures  for  developing  automated  child  support  systems 
totalled  about  $2 billion. 
FINDINGS 
Mmt  States and territories are well positioned  to have cert$ed  automated  child supprt 
data systkms by the rev&d  October 1,1997  &adlim 
Only  one  State  met  the  original  October  1, 1995 deadline  for  having  a certified  data 
system.  However,  at the  time  of our  review  five more  States  had  been  certified. 
Forty-two  States  said  they  expect  to have  certified  automated  data  systems  by the 
revised  October  1, 1997 deadline.  Five  States  did not  know  whether  or not  they  would 
be  certified,  and  one  State  said it does  not  expect  to  develop  a certified  data  system  by 
the  revised  deadline.  Of those  anticipating  to be  certified  by the  revised  deadline, 
thirty-two  were  in the  implementation  and  operational  phases.  States, ACF,  and conaactors general& attributed implementation  delays huge& to three 
pqgmm  ekkments: technology b-arqfer, short timefmmes; and Stai2/contractor 
iz?htionsw 
States,  ACF,  and  contractors  shared  responsibility  for  the  delays.  Neither  was solely 
responsible.  States  identified  three  program  elements  that  contributed  most  to  delays 
in developing  and  implementing  certified  automated  data  systems.  The  program 
elements  were  (1) a requirement  to share  technology,  (2) short  timeframe  for 
developing  and  implementing  the  systems,  and  (3) ineffective  State  and  contractor 
working  relationships.  ACF  and  contractors  generally  agreed  with  States  that  these 
program  elements  were  the  major  causes  of delays. 
Most States cosider the qualityo f Federal technical assistance and guidance  to be good 
to excelknt 
About  70 percent  of the  States  said the  quality  of ACFs  technical  assistance  and 
guidance  was good  or excellent.  ACF  provided  various  types  of technical  assistance 
and  guidance  to States  at different  stages  during  planning  and  development  of certified 
data  systems.  States  said  on-site  reviews,  certification  guide  and  questionnaire, 
interpretation  of the  certification  guide,  and  user  group  meetings  were  most  helpful. 
RECOMMENDATIONS 
Despite  the  favorable  outlook,  the  Administration  for  Children  and  Families  (ACF) 
should  take  steps  to ensure  that  all States  develop  a certified  automated  child  support 
data  system  by the  revised  October  1, 1997 deadline.  We  recommend  that  ACF: 
Secure  a detailed  action  plan  from  each  State  identifying  specific  steps  they  are 
b 
undertaking  to meet  the  revised  deadline. 
w  Establish  an intensive  system  to continuously  monitor  the  status  of each  States 
progress  towards  becoming  certified  by October  1, 1997. 
b  Provide  more  indepth  technical  assistance  and  guidance  to States  having 
difficulty  meeting  the  revised  deadline.  Such  assistance  could  include  (1) 
working  with  States  to determine  specific  causes  of problems,  and  (2) assisting 
States  in designing  and  implementing  corrective  action  measures. 
The  Personal  Responsibility  and  Work  Opportunity  Reconciliation  Act  of  1996 
requires  States  to  develop  several  additional  child  support  data  systems  by October  1, 
2OMI.  Some  lessons  learned  from  the  systems  development  effort  analyzed  in this 
report  may be  applicable  to these  new systems.  We  suggest  that  ACF: 
k  Allow  States  flexibility  in determining  whether  or not  transferring  proven  child 
support  data  systems  from  one  political  jurisdiction  to  another  would  shorten 
implementation  time,  reduce  systems  cost, and  achieve  standardized  systems. 
ii  b  Develop  strategies  to identify  areas  where  States  can  provide  technical 
assistance  to  others.  ACF  should  also  coordinate  this  effort  both  regionally  and 
nationally. 
Towards  this  effort,  we will issue  a report  in the  near  future  that  identifies  lessons 
learned  by States  in their  efforts  to develop  and  implement  certified  automated  data 
systems. 
AGENCY  COMMENTS 
The  Principal  Deputy  Assistant  Secretary  for  Children  and  Families  commented  on 
our  draft  report.  She  expressed  general  agreement  with  our  recommendations.  To 
help  assure  that  States  implement  certified  automated  data  systems  by the  revised 
October  1, 1997 deadline,  ACF  is re-emphasizing  the  importance  of Advance  Planning 
Document  Updates  by States.  The  ACF  will also provide  more  in-depth  technical 
assistance  to  States,  including  more  frequent  on-site  visits by regional  and  central 
office  staffs.  ACF  intends  to  obtain  Quarterly  Status  Reports  from  States  experiencing 
difficulties  in developing  certified  data  systems. 
Further,  ACF  modified  original  instructions  requiring  States  to  transfer  another  States 
child  support  data  system.  The  revised  instructions  give States  an  option  on whether 
or not  to  transfer  another  States  data  system.  The  ACF  is also  seeking  opportunities 
to build  supportive  relationships  between  States  to enhance  development  of the  data 
systems. 
The  Acting  Assistant  Secretary  for  Planning  and  Evaluation  also  concurred  with  our 
recommendations. 
Appendix  A shows the  full text  of ACF  comments. 
. . . 
111  TABLE  OF  CONTENTS 
PAGE 
INTRODUCI-ION  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 
FINDINGS  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 
State  Readiness  ............................................  5 
Causes  of Implementation  Delays  ..................  r ............  6 
Technology  Transfer  Policy  ...............................  8 
Short  Timeframes  ......................................  9 
State  and  Contractor  Working  Relationships  .................  10 
.  Quality  of Federal  Technical  Assistance  .........................  11 
RECOMMENDATIONS  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 
AGENCYCOMMENTS  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 
APPENDIX A:  ACF COMMENTS..  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-l  INTRODUCTION 
PURPOSE 
To  describe  State  IV-D  Child  Support  Enforcement  Agencies  experiences  in 
implementing  certified  automated  data  systems. 
BACKGROUND 
ChiiiiS  upportE  nforcement 
The  Child  Support  Enforcement  program  was established  in  1975 as Title  IV-D  of the 
Social  Security  Act.  Its purpose  is to locate  noncustodial  parents,  establish  paternity, 
establish  and  enforce  child  support,  and  collect  child  support  payments.  State  Title 
IV-D  Child  Support  Agencies  manage  and  operate  child  support  programs. 
Within  the  Department  of Health  and  Human  Services  (HHS),  the  Office  of Child 
Support  Enforcement  (OCSE),  Administration  for  Children  and  Families  (ACF),  has 
Federal  oversight  responsibility  for  State  Title  IV-D  Child  Support  programs. 
Automating Child SupportD  ata Systems 
Because  of escalating  non-support  for  children  by noncustodial  parents,  and  a public 
need  for  responsive  child  support  enforcement  programs,  the  Administration  and  the 
Congress  have  long  been  interested  in improving  data  systems  for  child  support. 
In  1984, Congress  amended  Title  IV-D  of the  Social  Security  Act  to fund  90 percent 
of State  costs  for  computer  hardware  and  software  to operate  automated  child  support 
data  systems. 
The  1988 Family  Support  Act  extended  90 percent  funding  for  development  of 
automated  child  support  enforcement  data  systems.  The  Act  required  each  State  to 
develop  a Statewide  automated  data  system  that  had  the  capability  to  control,  account 
for,  and  monitor  all processes  for  determining  paternity  and  collecting  child  support. 
Additionally,  the  system  was required  to electronically  interface  with  systems  of other 
agencies  at the  Federal,  State,  and  local  level.  Such  interface  was deemed  essential  to 
assure  collection  of child  support,  where  appropriate,  and  proper  distribution  of child 
support  payments. 
The  1988 Act  also  required  ACF  to  certify  each  State  system  to  assure  that  State 
automated  systems  for  child  support  meet  Federal  requirements. 
Finally,  the  1988 Act  set  October  1, 1995 as the  deadline  for  States  to  implement  the 
required  certified  automated  child  support  data  system.  At  that  time,  funding  was to 
be  discontinued. 
1  However,  only  one  State  met  the  October  1, 1995 deadline  for  implementing  a 
certified  automated  data  system  for  child  support  enforcement.  As a result,  on 
October  11, 1995, Congress  passed  legislation  to  authorize  a 2-year  extension  of the 
deadline  -- until  October  1, 1997. 
Fe&ml and State Expedhrm 
While  only  one  State  system  had  been  certified  as of the  October  1, 1995 deadline, 
Federal  and  State  expenditures  for  developing  State  systems  totalled  almost  $2 billion. 
Figure  1 shows that  Federal  and  State  funding  for  developing  automated  child  support 
systems  steadily  increased  from  1988 through  1995. 
FIGURE  1 
CHILD  SUPPORT  SYSTEMS  EXPENDITURES 
FY  19884995 
TOTAL:  FEDERAL/STATE  SHARE  ($  millions) 
700  - 
590.1 
600  - 
500  - 
400  - 
1988  1989  1990  1991  1992  1993  1994  1996 
FISCAL  YEAR 
m  Federal  EZi  State 
2  tincem  about State lbgrm  in DevelopingA utmnati  Child SupportD  ata Systems 
Congress  and  the  Administration  for  Children  and  Families,  Department  of Health 
and  Human  SeMces expressed  interest  in learning  about  the  status  of implementation 
of automated  child  support  data  systems,  delays  in implementation,  problems, 
successes,  and  lessons  learned.  Such information  should  be  helpful  to  OCSE,  the 
Department,  and  the  Congress  in continuing  to  develop  an  automated  data  system  for 
child  support,  and  in designing  and  implementing  such  systems  in the  future. 
Previously,  the  U.S. General  Accounting  Office  (GAO)  had  issued  two reports  on 
Federal  and  State  efforts  to  automate  data  systems.  In  1989, the  GAO  reported  on 
the  automation  status  of State  Child  Support  Enforcement  programs.  That  report 
showed  that  between  September  1985 and  May  1988, States  had  made  some  progress 
toward  developing  automated  child  support  systems.  Thirty-nine  States  had 
progressed  through  at least  one  development  stage,  13 States  had  remained  in the 
same  phase,  and  2 States  had  regressed  to  a preplanning  phase. 
In  1992, the  GAO  reported  on  OCSEs  oversight  of States  in developing  the  required 
automated  child  support  systems. 2  GAO  reported  that  OCSE  did not  require  States 
to  correct  known  problems.  The  GAO  noted  that  OCSEs  approach  resulted  in a risk 
that  serious  problems  would  have  to be  corrected  later  when  it is much  more  costly 
and  time-consuming  to  do so. 
PkimnedA dditionalC  hild Supper Enfon;ementD  ata Systems 
The  Personal  Responsibility  and  Work  Opportunity  Reconciliation  Act  of  1996 
required  States  to develop  several  additional  child  support  data  systems.  For  example, 
(1) State  directory  of new  hires,  (2) State  case  registry,  (3) collection  and  use  of Social 
Security  numbers  in child  support  enforcement,  and  (4) centralized  collection  and 
disbursement  of support  payments.  The  deadline  set for  implementation  of the  new 
systems  is October  1, 2000.  However,  the  deadline  shall  be  extended  by one  day for 
each  day  (if any)  that  the  Secretary  fails to meet  the  set deadline  for  prescribing  final 
regulations.  In developing  the  additional  new systems,  States  are  expected  to face 
similar  challenges  as they  faced  in developing  the  certified  data  systems. 
We believe  this  report  on implementation  of State  child  support  certified  data  systems 
will provide  important  information  for  planning  and  implementing  the  additional  child 
support  data  systems.  Additionally,  we will issue  a follow-up  report  on  this  subject  of 
lessons  learned  by States  in implementing  the  certified  data  systems. 
Child Support:  State Progress in Developing Automated  Enforcement  Systems 
(GAO/HRD-89-lOI%, February 10, 1989). 
2Child Support Enforcement:  Timelv Action Needed to Correct System Development 
Problems (GAO/IMTEC-92-46, August 13, 1992). 
3  METHODOLOGY 
We  used  a standardized  questionnaire  to survey  all 50 States,  the  District  of Columbia, 
Puerto  Rico,  Guam,  and  the  Virgin  Islands.  Additionally,  we conducted  telephone 
interviews  with  staff  at ACF  headquarters  and  10 regional  offices.  Finally,  we 
conducted  telephone  interviews  with  eight judgmentally  selected  State  contractors  who 
were  responsible  for  developing  the  required  automated  data  systems. 
We  used  the  following  criteria  in selecting  the  eight  contractors.  First,  we stratified 
the  States  into  the  following  two groups.  States  that  were  (1) certified,  including  those 
States  that  had  obtained  a Level  2 certification  review  by ACF,  and  (2) not  certified. 
We  selected  four  contractors  from  each  of the  two groups. 
From  each  organization  included  in our  survey, we obtained  information  on 
experiences  and  lessons  learned  in developing  automated  data  systems  for  child 
support  enforcement.  Further,  we obtained  views of staffs  on  reasons  for  delays  in 
developing  certified  automated  data  systems.  Additionally,  from  ACF  staffs, we 
obtained  information  on  the  status  of development  of certified  data  systems.  We  did 
not  determine  the  extent  that  funding  affected  State  delays  in developing  and 
implementing  certified  data  systems.  The  U.S. General  Accounting  Office  has  a 
review  underway  which  we understand  will examine  the  effect  of funding  on  system 
implementation. 
As of August  30, 1996, 54 States3 had  completed  and  returned  our  questionnaire  -- a 
response  rate  of  100 percent. 
We  conducted  our  inspection  between  April  1996 and  August  1996. 
This  inspection  was conducted  in accordance  with  Quality  Stundardr  for  Inspections 
issued  by the  Presidents  Council  on  Integrity  and  Efficiency. 
3For convenience  in summarizing survey results, we considered the District of 
Columbia, Puerto  Rico, Guam, and the Virgin Islands as States.  FINDINGS 
MOST STATES ANTICIPATE HAVING A CERTIFIED AUTOMATED  CHILD 
SUPPORT DATA SYSTEM BY THE REVISED OCTOBER 1,1997D  EADLINE 
srirstateshadcertjciedDatasysterns 
As of October  1, 1995, only  one  State  had  a certified  automated  child  support  system 
as required  by the  1988 Family  Support  Act.  However,  at the  time  of our  review,  five 
more  States  had  developed  certified  automated  data  systems  for  child  support  -- for  a 
total  of six States. 
Forty-twoo f the Remaining4 8 StatesB  pect  to Meet the Rev&d Deadline of October 1, 
1497 
The  majority  of the  remaining  48 States  (88 percent),  said they  expect  to  have 
certified  data  systems  by the  revised  deadline.  Table  1 shows the  status  of all States  in 
developing  and  implementing  certified  automated  child  support  data  systems  at the 
time  of our  review.  The  table  also  shows that  two-thirds  of the  remaining  48 States 
(32 of 48) are  in the  implementation  and  operational  phases. 
TABLE 1 
STATE PROGRESS  IN DEVELOPING  AUTOMATED  DATA SYSTEMS 
CURREWTPHASE  NUMBER OF STATES IN PHASE 
Design  2 
Programming  3 
Testing  9 
Conversion  2 
Implementation  9 
Pilot  in several  counties,  but enhancing  1 
Operational  Statewide,  but  enhancing  12 
Operational  Statewide,  but  transferring  new  1 
system 
Level  1 Certification  Review  2 
Level  2 Certification  Review  7 
Certified  6 
TOTAL  STATES  54 
I 
.Tlx.4. 8 .States, that.d id.a ct have certified .data systemsa t, tire.t ime.o f.o ur revieww  ere ,in one ,or more 
phases of development  or implementation:  For the States that selected more than one phase, we 
chose the last phase checked to be the States cnrrent phase. 
5  Five of theR emaining4 8 StatesD  id Not K&w  whether or Not lhcy Would Meet the 
RevivedD  eadline of October I, 1997 
Officials  from  the  five  States  gave  several  reasons  for  uncertainty  about  meeting  the 
revised  October  1, 1997 deadline.  Some  of the  more  prevalent  reasons  were  (1) the 
system  has  to be  implemented  in a number  of counties,  (2) ACFs  certification  guide 
was published  too  late,  (3) contractors  plan  was flawed,  and,  based  on  past 
performance,  the  State  has  no  confidence  in the  contractors  projections,  and  (4) State 
management  is insisting  that  appropriate  time  be  taken  to develop  a quality  system. 
We  observed  that  the  six States  who  already  have  certified  systems  and  the  42 who 
expect  to  have  such  systems  by October  1, 1997 faced  similar  challenges. 
One StateD  oa  Not Expect to Meet the RevivedD  ead&e of October I, 1997 
This  one  State  does  not  expect  to develop  a certified  automated  data  system  by the 
revised  deadline  because  of procurement  and  contractor  problems.  That  State  said 
they  may  have  a certified  system  by October  1998.  Again,  6 States  have  successfully 
overcome  such barriers  and  42 others  expect  to do so. 
STATES,  ACF,  AND  cXXUTRACl-ORS  GE NERALLYAITRIBUTED 
IMPLEMENTATION  DELAYS  LARGELY  TO  THREE  PROGRAM  ELEMENTS 
Our  survey  results  show that  neither  the  States,  ACF,  nor  contractors  were  solely 
responsible  for  implementation  delays,  but  each  organization  shared  in the  delays. 
States,  ACF  and  contractors  identified  various  program  elements  that  contributed  to 
the  delays.  Table  2 shows factors  States  said caused  delays  in developing  and 
implementing  certified  data  systems. 
However,  States  identified  three  program  elements  that  contributed  most  to delays  in 
developing  and  implementing  certified  automated  data  systems  for  child  support.  The 
program  elements  were  (1) ACFs  transfer  policy,  (2) short  timeframe  for  developing 
and  implementing  the  systems,  and  (3) ineffective  State  and  contractor  working 
relationships.  These  are  the  top  five factors  identified  in Table  2. 
6  TABLE  2 
FAcXXlS  CAUSING DELAYS  IN DEVELOPING  AND IMP-G 
STATE CHILD SUPPORT CERTIFIED  DATA SYSTEMS 
[r 
1 
FACIXNIS CAUSING DELAYS  PERCENT 
II 
1.  ACFs prior  mandate  that  States  transfer  a CSE  70%  (38 of 54) 
system  I 
I 
2.  Not  enough  time  allowed  by the  October  1, 1995 
deadline  for developing  and implementing  your  States 
certified  data  system 
3.  Contractor  meeting  deliverables  schedule  stipulated  in  *55%  (27 of 49) 
contract 
------A 
4.  Qualitv  of contractors  work  *49%  (24 of 49) 
I 
5.  Problems  with  State  contractor  *43% (21 of 49) 
I 
6.  State  administrative  problems 
7.  Resources  assigned  to other  competing  child support 
priorities 
5.  State  staff technical  expertise  to develop  and implement 
data  system 
9.  Guidance  provided  bv ACF  to State 
10. Guidance/direction  provided  by State  to contractor 
11. Technical  assistance  provided  by ACF  to State 
12. State  monitoring  of contractors  progress  *17%  (8 of 49) 
I 
13. State  leadership  and commitment 
14. State  planning  process 
15. State-established  contract  requirements  *13%  (6 of 49) 
I 
16. State  legislation  12% (6 of 54) 
I 
17. Organizational  location  of child support  data  system  in  8%  (4 of 54) 
relation  to State  IV-D  program  office 
18. Monitoring  by ACF 
y 5 of.54 States did ntit use contractors, thereby reducing the 
to 49. 
7  Attempts to lhzn.$wAutomated Data Systemsf rom One State to Another Did Not Wok 
In  1986, OCSE  established  a transfer  policy  generally  requiring  States  seeking 
enhanced  funding  to use existing  automated  data  systems  of other  States  as models 
rather  than  develop  new systems.  The  OCSE  expected  such  transfers  to  (1) save 
system  development  time  and  costs,  and  (2) increase  the  likelihood  of success, 
especially  in States  lacking  technical  staff. 
However,  about  71 percent  of the  States  said  the  attempt  to transfer  an  automated 
data  system  delayed,  rather  than  enhanced,  development  and  implementation  of 
automated  systems.  For  example,  several  State  officials  said  attempts  to use  a transfer 
system  delayed  implementation  by several  years. 
According  to the  States,  the  transfer  requirement  delayed  development  and 
implementation  of certified  data  systems  for  two major  reasons. 
b  No Complete  Systems to Transfer:  When  States  began  developing  data 
systems,  there  were  no  certified  systems  to transfer  as models.  None  of the 
States  had  complete,  mature  automated  IV-D  child  support  systems  that  could 
be  certified  according  to the  requirements  of the  1988 Family  Support  Act. 
b  Transfer  Systems Not Unique  To  State  Needs:  The  systems  States  finally  chose 
as a transfer  model  had  to be  redesigned,  rewritten,  modified  and  enhanced  to 
meet  individual  State  needs.  One  State  official  said  the  transfer  concept  was 
fundamentally  flawed.  It called  for  the  transfer  of poorly  designed  systems  and 
old  technology  that  had  to be  significantly  enhanced  to function  for  individual 
States.  State  officials  said  that  redesigning,  rewriting,  and  enhancing  the  flawed 
transfer  systems  resulted  in much  lost  time. 
According  to many  States,  the  existing  State  systems  they  tried  to  transfer  did 
not  meet  the  diverse  needs  of individual  States  and  counties.  The  States  said 
the  transfer  concept  seemed  to be based  on  a premise  that  one  child  support 
program  is like  another.  They  said, however,  that  in reality  each  child  support 
program  is unique,  and  trying  to adopt  another  system  wasted  time  and 
resources.  For  example,  officials  in one  State  said they  wasted  about  a year 
trying  to adopt  a transfer  system.  The  final  result  was a documentation  of 
deficiencies  in the  transfer  system  that  were  eventually  used  to justify  not  using 
the  system. 
A few States  said  the  transfer  systems  did not  permit  the  degree  of 
customization  desired  by individual  States.  For  example,  officials  in one  State 
noted  that  the  transfer  system  could  not  satisfy  over  182 elected  officials 
involved  in child  support  at the  State  and  county  level.  The  requirements  of 
county-administered  child  support  systems  create  additional  difficulties  for  some 
States.  Some  States  said  the  transfer  system  requirement  forced  them  to 
choose  a system  they  otherwise  would  not  have  chosen. 
8  ACF  and  contractor  staffs  generally  corroborated  State  opinions  that  the  transfer 
policy  was a major  contributor  of the  delays.  Both  ACF  and  contractor  staffs  said  the 
transferred  system  needed  significant  modifications. 
October I, I995 Deadkhe did not Allow Adequate lhe  for Developinga nd 
ImplementingS tateC  ertifiedD ata *stems 
Seventy  percent  of the  States  said  the  October  1, 1995 deadline,  set by the  Congress, 
was unrealistic  for  developing  and  implementing  certified  data  systems.  According  to 
State  officials,  the  time  was unrealistic  because  (1) final  system  requirements  from 
ACF  were  late,  (2) political  issues  could  not  be  resolved  in time  allowed,  and  (3) 
complex  State  systems  could  not  be  developed  in time  allowed. 
b  System  Requirements  Issued Late:  State  child  support  officials  said ACF 
issued  final  certification  requirements  and  guidelines  in June  1993.  This  was 
too  late,  they  said,  to  analyze,  design,  redesign,  develop,  and  implement  systems 
to meet  the  October  1, 1995 deadline.  Several  State  officials  explained  that 
they  started  developing  systems  based  on  1992 regulations  which  detailed 
specifications  for  computer  systems.  However,  the  June  1993 regulations 
required  significant  and  extensive  changes  to the  automated  systems  that  States 
had  underway.  Other  States  said they  did not  know  what  was required  until 
they  received  the  1993 certification  requirements. 
b  Political Issues Could Not Be Resolved  In Time:  State  officials  said  the 
October  1, 1995 deadline  did not  consider  a need  for  obtaining  political 
consensus  among  all child  support  agencies  in a State.  They  explained  that 
development  of a central  child  support  system  must  consider  the  needs  and 
desires  of many  State  and  local  officials,  including  local  agencies,  county 
officials,  clerks  of courts,  and  court  administrators. 
To  illustrate,  one  State  official  said  completion  of the  implementation  phase 
was dependent  on total  county  cooperation.  That  official  said  the  road  from  a 
separate,  individual  county  system  to an integrated,  statewide  system  took  a 
long  time,  and  the  deadline  did not  allow  enough  time  for  this  task. 
b  Not Enough  Time  To  Develop  Broad  Scoped  and Complex  Systems:  Many 
States  said  the  scope  and  complexity  of the  required  certified  data  systems 
made  the  deadline  unrealistic.  To  illustrate,  one  State  official  said the  deadline 
allowed  inadequate  time  to do the  extensive  testing,  and  numerous  interfaces 
with  other  databases  that  were  required.  Another  said  the  time  was inadequate 
for  the  extensive  procurement  process.  One  official  said  the  scope  and 
complexity  of the  systems  were  underestimated  at the  Federal,  State  and  local 
levels. 
9  Several  State  officials  said only  a few private  sector  contractors  had  child 
support  and  public  welfare  expertise.  They  said the  child  support  deadline  did 
not  include  consideration  of this  limited  resource  pool.  Since  only  a few 
experienced  contractors  were  available,  States  said  the  deadline  was unrealistic. 
Again,  ACF  and  contractors  agreed  that  October  1, 1995 deadline  was a major 
contributing  factor  to  the  delays.  ACF  and  contractor  staff  said  the  deadline  was 
unrealistic  because  of the  (1) late  issuance  of Federal  regulations  and  certification 
requirements,  (2) political  issues  in States  involving  a number  of different  agencies, 
and  (3) systems  were  complex  and  expensive  to  develop. 
I.eche  Stntea nd Gmbwtor  Wohing Reibionstip 
b  Contractors  Could Not Deliver Acceptable  Products  on Time:  Officials  from 
55 percent  (27 of 49)4 of the  States  said contractors  failed  to  deliver  as 
stipulated  in their  contract.  To  illustrate  why contractors  failed  to  deliver, 
several  officials  furnished  the  following  comments. 
-- The  contractors  lacked  experienced  staff,  and  in some  instances,  the 
contractors  lost  experienced  staff  after  obtaining  a contract. 
-- The  contractors  had  insufficient  staff  to  accomplish  what  was agreed  to in the 
contract. 
-- The  contractor  changed  management  after  the  contract  was obtained. 
-- The  contractor  overpromised,  underestimated  the  scope  and  complexity  of 
work,  poorly  planned,  and  ultimately  failed  to deliver  as scheduled. 
b  Contractors  Experienced  Quality  Problems:  Officials  from  49 percent  (24 of 
49) of the  States  attributed  contractor  delays  to poor  quality  work.  To  illustrate 
contractors  poor  quality  work,  several  officials  said 
--  every  deliverable  was always late  and  subsequently  rejected  when  received. 
Ultimately,  deliverables  in one  State  were  accepted  only  conditionally, 
-- contractor  has  never  delivered  an  acceptable  product  on  schedule, 
--  many  of the  programs  they  accepted  from  the  contractors  did not  work  once 
implemented,  and 
--  contractor  programs  could  not  pass  quality  test  without  extensive 
modifications. 
45 of 54 States did not use contractors, thereby, reducing the number of States to 49. 
10  b  Contractors  Experienced  Various  Other  Petiormance  Problems:  Officials  from 
43 percent  (21 of 49) of the  States  attributed  contractor  delays  to problems 
other  than  those  mentioned  above.  For  example,  several  officials  said 
-- contractor  never  fully understood  the  business  of child  support  enforcement, 
--  contractor  failed  to undertake  needed  analysis  of State  policies,  procedures, 
and  current  systems  before  starting  the  project, 
-- contractor  was not  receptive  to input  from  the  State  on the  system  design 
(e.g., system  users),  and 
-- State  spent  many  months  deciding  what  they  wanted  from  their  system, 
but  the  contractor  pushed  his own ideas  instead  of listening  to the  State. 
Likewise,  ACF  staff  said  ineffective  State  and  contractor  working  relationships 
contributed  to delays.  To  illustrate,  ACF  said  contractors  were  not  adequately 
prepared  to  deal  with  certification  requirements  on the  level  that  States  needed.  Also, 
only  a limited  number  of contractors  had  expertise  in developjng  certified  data 
systems.  Contractor  staff  also  said there  was not  enough  available  resources  to 
develop  systems,  since  every  States  system  had  to be  developed  by the  same  deadline. 
Contractor  staff  also  said  that  both  State  and  contractors  lost  experienced  staff which 
contributed  to  delays. 
OtherP  otentialC auseso f Delays 
To  identify  potential  causes  of delays  in implementing  certified  data  systems,  we 
considered  several  factors  in addition  to those  named  by States,  ACF,  and  contractors. 
For  example,  we considered  (1) county  vs State  administration,  (2) centralized  vs 
distributed  data  processing  systems,  and  (3) whether  or not  States  used  predominantly 
contract  staff vs predominantly  in-house  staff  to develop  certified  data  systems.  We 
found  that  these  factors  did not  appear  to  contribute  to delays  in States  meeting  the 
deadline. 
MOST  STATES  CONSIDERED  THE  QUALITY  OF  FEDERAL  TECHNICAL 
ASSISTANCE  AND  GUIDANCE  TO  BE  GOOD  TO  EXCELLENT 
While  States  expressed  concern  about  some  guidance  such  as the  transfer  policy  and 
timeliness  of final  certification  requirements,  70 percent  of the  States  said  that  overall 
the  quality  of ACFs  technical  assistance  and  guidance  was good  or excellent.  ACF 
provided  various  types  of technical  assistance  and  guidance  to  States  at  different  stages 
during  planning  and  development  of the  certified  systems.  For  example,  ACF 
furnished  various  publications  to States  for  guidance;  held  various  group  meetings, 
conferences,  and  workshops;  made  on-site  reviews,  and  provided  individual 
11  consultation.  Table  3 summarizes  the  major  types  of  technical  assistance  and  guidance 
provided  and  the  number  of  States  receiving  the  help. 
TABLE 3 
TECHNICAL ASSISTANCE AND GUIDANCE PROVIDED BY ACF Xl  STATES 
TYPESOFTIXHNICALASSISTANCEAND  NUMBER OF STATES 
GUIDANCE  ACF PROVIDED To STATES  RECEIVINGTECHNICAL 
A!!SISTANCEANDGUlDANCE 
Interpretation  of Certification  Guide  (Q&A)  49 
Certification  Guide  and  Questionnaire  47 
I 
Financial  Test  Deck  45 
I 
Visits with  Federal  Staff  43 
User  Group  Meetings  41 
CSENet  Technical  Assistance  40 
Conferences  31 
ACF  Bulletin  Board  30 
Teleconferences  with  Staff  28 
On-Site  Assistance  27 
Workshops  21 
Facilitate  Collaborative  Efforts  and  21 
Communications  between  States 
Review  of Draft  Responses  to Questionnaire  21 
NQJJZ  States  cuuld  check  more  than  one  type  of technical  assistance  or guidance. 
States  said  the  on-site  reviews,  certification  guide  and  questionnaire,  interpretation  of 
the  certification  guide,  and  user  group  meetings  were  the  most  helpful. 
12  RECOMMENDATIONS 
Despite  the  favorable  outlook,  the  Administration  for  Children  and  Families  (ACF) 
should  take  steps  to  ensure  that  all States  develop  a certified  automated  child  support 
data  system  by the  revised  October  1, 1997 deadline.  We  recommend  that  ACF: 
Secure  a detailed  action  plan  from  each  State  identifying  specific  steps  they  are 
b 
undertaking  to meet  the  revised  deadline. 
Establish  an  intensive  system  to continuously  monitor  the  status  of each  States 
b 
progress  towards  becoming  certified  by October  1, 1997. 
Provide  more  indepth  technical  assistance  and  guidance  to States  having 
b 
difficulty  to  ensure  that  appropriate  adjustments  are  made  to meet  the  revised 
deadline.  Such  assistance  could  include  (1) working  with  States  to  determine 
specific  causes  of problems,  and  (2) assisting  States  in designing  and 
implementing  corrective  action  measures. 
The  Personal  Responsibility  and  Work  Opportunity  Reconciliation  Act  of  1996 
requires  States  to develop  several  additional  child  support  data  systems  by October  1, 
2000.  Some  lessons  learned  from  the  systems  development  effort  analyzed  in this 
report  may  be  applicable  to the  new systems.  We suggest  that  ACF: 
b  Allow  States  flexibility  in determining  whether  or not  transferring  proven  child 
support  data  systems  from  one  political  jurisdiction  to  another  would  shorten 
implementation  time,  reduce  systems  cost,  and  achieve  standardized  systems. 
Develop  strategies  to identify  areas  where  States  can  provide  technical 
b 
assistance  to others.  ACF  should  also  coordinate  this  effort  both  regionally  and 
nationally. 
Towards  this  effort,  we will issue  a report  in the  near  future  that  identifies  lessons 
learned  by States  in their  efforts  to develop  and  implement  certified  automated  data 
systems. 
13  AGENCY  COMMENTS 
The  Principal  Deputy  Assistant  Secretary  for  Children  and  Families  commented  on 
our  draft  report.  She  expressed  general  agreement  with  our  recommendations.  To 
help  assure  that  States  implement  certified  automated  data  systems  by the  revised 
October  1, 1997 deadline,  ACF  is re-emphasizing  the  importance  of Advance  Planning 
Document  Updates  by States.  The  ACF  will also  provide  more  in-depth  technical 
assistance  to  States,  including  more  frequent  on-site  visits by regional  and  central 
office  staffs.  ACF  intends  to  obtain  Quarterly  Status  Reports  from  States  experiencing 
difficulties  in developing  certified  data  systems. 
Further,  ACF  modified  original  instructions  requiring  States  to transfer  another  States 
child  support  data  system.  The  revised  instructions  give States  an  option  on whether 
or not  to  transfer  another  States  data  system.  The  ACF  is also  seeking  opportunities 
to build  supportive  relationships  between  States  to enhance  development  of the  data 
systems. 
The  Acting  Assistant  Secretary  for  Planning  and  Evaluation  also  concurred  with  our 
recommendations. 
Appendix  A shows the  full text  of ACF  comments. 
14  APPENDIX  A 
A-l  DEPART-MENT OF HEALTH  & HUMAN  SERVICES 
#t 
w  41LcIc 
ADMINISTRATION  FOR CHILDREN  AND FAMILIES~ 
rf)ffice uf the Assistant  Secretary,  Suite 600 
Et!*  - 
370 LEnfant  Promenade,  S.W. 
EE  zz!z  Washington,  D.C. 20447 
March 14, 1997 
-- 
DWI-MP- 
-3 
!Ez 
Dsmsul!~ 
TO:  June Gibbs 'Brown 
Inspector General 
FROM:  Olivia A. Golden 
Principal Deputy As 
for Children and  Families 
SUBJECT:  OIG  Draft Report Wnplementation  of State Child Support 
Certified Data Systems" (OEI-04-96-00010) 
Thank you for the opportunity to respond to your draft report of 
findings concerning State Child Support Data Systems.  Our 
comments follow the order of recommendations in the report.  If 
you have questions regarding this response, please contact David 
Ross of my staff at (202) 401-9370. 
Comments: 
OIG Recommendation I:  Secure a detailed'action plan from each 
State identifying specific steijst hey are undertaking to meet the 
revised deadline. 
ACF Response:  We generally agree with the OIC's 
recommendation, and will place a renewed emphasis on the 
States' informational and submission requirements of Annual 
and As-Needed Advance Planning Document Updates. 
OIG Recommendation 2:  Establish an intensive system to 
continuously monitor the status of each  progress towards 
State's 
becoming certified by October 1, 1997. 
ACF Response:  We generally agree with the OIG's 
recommendation in this area,,a nd will be offering and 
.conducting additional technical assistance reviews to those 
States in need of these services, as well as to any State 
asking for such services.  Further, we intend to employ as 
practicable, the use of Quarterly System Status Reports by 
those States experiencing difficulties with their Child 
Support system development project.  OIG Recommendation 3:  Provide more in-depth technical  assistance 
and guidance to States having difficulty meeting the revised 
deadline.  Such assistance could include (1) working with States 
to determine specific causes of problems, and  (2) assisting 
States in designing  and implementing corrective action measures. 
ACF Response:  We generally agree with the OIG's 
recommendation in this area, and will offer and conduct 
additional technical assistance reviews to those States in 
need of these,s ervices, as well as to any State asking far 
such services.  In order to support this need for enhanced 
levels of technical assistance to States, we have offered 
States the opportunity to have more frequent visits by our 
regional and central office staff.  A primary purpose of 
these technical assistance visits will be to provide 
guidance to States project staffs in designing and 
implementing corrective action measures, should corrective 
actions ba deemed necessary. 
Here are our responses to the OIG recommendations made regarding 
States' efforts to implement systems to meet the Personal 
Responsibility and Work Opportunity Reconciliation  Act of 1996: 
GIG Recommendation 1.: Allow States flexibility in determining 
whether or not transferring proven child support data systems 
from one political jurisdiction to another would shorten 
implementation time, reduce systems Cost, and  achieve 
standardized systems, 
ACF Response:  We agree with this recommendation and have 
modified our original instructions so that States are no 
longer required to transfer systems from another 
jurisdiction.  This policy change was issued on July 22, 
1994, under Action Transmittal  in which our 
ACF-AT-94-5 
practice of mandating the transfer of systems was changed to 
require its *... consideration as an option in.the 
alternatives analysis...,*  We will:c ontinue to review our 
policy towards systems transfer, as with all policies 
regarding systems development, to ensure that we provide the 
clearest guidance and most cost-effective and efficient 
solutions to States in the area of data systems development, 
implementation and operation. 
OfG Recommendation 2:  Develop strategies to identify areas where 
States can provide technical assistance tb others.  AC!? should 
also coordinate this efforC both regionally and.nationally. 
ACF  Response:  We agree with the OIG's recommendation in 
this area, and have begun  seeking opportunities to build the 
types of supportive relationships between  States systems  Paw  3 
development and operations staffs that are envisioned by 
this recommendation.  We are seeking opportunities  through 
scme  of the  many  conferences  we  sponsor  each  year  to  allow 
for enhanced technical. assistance between States.  The ACF 
Users Group Conference, held twice a year, is another 
example of  how we are  striving to bring States' staffs 
together on issues of mutual interest.  over  the  last two 
years, we have held many regionally-based CSENet  Technical 
Aseistance  Workshops under the direct sponsorship of a 
particular State.  These workshops.,i n  many ways, directly 
address the OIG's suggestions of having States become 
valuable  resources  ta one another.  ACF will cont=inuet o 
seek more opportunities to bring the States together, 
regionally and nationally, as technical assistance resources 
and partners.