Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

JANET REHNQUIST 

Inspector General 

FEBRUARY 2002 

OEI-05-99-00392 

Child Support for 

Children on TANF 
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 noncustodial 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. 

Child Support for Children on TANF i 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 noncustodial 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 Parent’s 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 parent’s 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 parent’s 

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 parent’s 

earnings. The support order can be raised gradually as a non-custodial parent’s 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 nonChild Support for Children on TANF ii OEI-05-99-00392 
custodial parent’s 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 lowincome 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 noncustodial parents. We recognize that some of the experiments with policies dealing with lowincome 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. 

Child Support for Children on TANF iii OEI-05-99-00392 
TABLE OF CONTENTS 

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

Child Support for Children on TANF iv OEI-05-99-00392 
INTRODUCTION 

PURPOSE 

To describe the alignment of the child support order with the earnings of low-income noncustodial 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 FederalState 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 parent’s 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 court’s 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. 

Child Support for Children on TANF 1 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 noncustodial parents are known in the child support community as “dead broke” rather than “deadbeat.” 

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 noncustodial 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 

Child Support for Children on TANF 2 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 nonsupport. 

METHODOLOGY 

We selected a random sample of cases (and the 10 States associated with them) using a twostage, 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 lowincome 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. 

Child Support for Children on TANF 3 OEI-05-99-00392 
Table 1 

Stratum Description of how State 

policy treats low-income 

non-custodial parents 

Clusters Population Sample 

1 Awards in court’s discretion 893 Clusters in 16 

States 

3 Clusters in MS, 

OK and PA 

2 Presumptive awards (e.g. 

minimum wage) 

614 Clusters in 18 

States 

3 Clusters in TX, 

VA and WA 

3 Mandatory minimum awards 652 Clusters in 14 

States plus District 

of Columbia 

4 Clusters in CO, 

MA, MD and NY 

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 State’s 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 noncustodial parent had open for other children. This resulted in an initial sample of 281 noncustodial 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, 

Child Support for Children on TANF 4 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 parent’s 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 President’s Council on Integrity and Efficiency. 

Child Support for Children on TANF 5 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 noncustodial 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> 

Child Support for Children on TANF 6 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 lowincome 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 noncustodial 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 parent’s 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 

Child Support for Children on TANF 7 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 

1995 

Monthly Child Support 

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 State’s 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 parent’s 

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. 

Child Support for Children on TANF 8 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, noncustodial 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 parent’s 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> 

Child Support for Children on TANF 9 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 parent’s income in the year before the support order was 

established as it relates to the poverty line for 1995. We grouped the low-income noncustodial 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 noncustodial 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 

parent’s 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 nt’s 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 

Parent's Earnings 

Increases In 

Income 

Front-end fees Percent of 

Support Order to 

Income 

Predicted 

Compliance 

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. 

Child Support for Children on TANF 10 OEI-05-99-00392 
Table 4 presents predicted compliance rates for a few typical cases to show how changes in a 

non-custodial parent’s situation effect compliance. As demonstrated in Row A, when a noncustodial 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. 

Child Support for Children on TANF 11 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 parent’s 

earnings. The support order can be raised gradually as a non-custodial parent’s 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 parent’s 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 lowincome 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 noncustodial parents. We recognize that some of the experiments with policies dealing with lowincome 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. 

Child Support for Children on TANF 12 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. 

Child Support for Children on TANF 13 OEI-05-99-00392 
APPENDIX A 

Confidence Intervals

Percent of NonCustodial Parents Standard 

Error 

90 % Confidence 

Upper Limit Lower Limit 

Mean Standard 

Error 

90 % Confidence 

Upper Limit Lower Limit 

1995 - Earnings below 

$7,470 

55% 3.73 61% 49% 

1995 - Earnings between 

$7,471 and $14,940 

23% 1.83 26% 20% 

1995 - Earnings greater 

than $14,940 

21% 3.84 28% 15% 

1995 - No reported 

earnings 

20% 3.37 25% 14% 

No earnings over 4 year 

period of time 

8% 0.92 10% 7% 

1998 - Earnings below 

$8,050 

50% 6.3 60% 40% 

Increase in earnings in 

each year over the 4 year 

period 

17% 2.76 22% 13% 

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 

ordered for non-custodial 

parents below the poverty 

line 

$1,249 142 $1,482 $1,015 

Child Support for Children on TANF 14 OEI-05-99-00392 
Mean Standard 

Error 

90 % Confidence 

Upper Limit Lower Limit 

Median Standard 

Error 

90 % Confidence 

Upper Limit Lower Limit 

1996 Total support 

ordered for all noncustodial parents 

$1,552 175 $1,841 $1,264 

1996 Report earnings for 

non-custodial parents 

below poverty line 

$1,974 360 $2,566 $1,381 

1995 - Earnings below 

$7,470 

$141 9.58 $157 $125 

1995 - Earnings between 

$7,471 and $14,940 

$195 18.31 $225 $165 

1995 - Earnings greater 

than $14,940 

$282 50.81 $366 $199 

Monthly order for all noncustodial parents $184 14.15 $207 $161 

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 

Child Support for Children on TANF 15 OEI-05-99-00392 
Total Support as 

a Percent of 

Income 

Standard 

Error 

90 % Confidence 

Upper Limit Lower Limit 

1996 - Earnings below 

$7,740 

69% 0.04 76% 62% 

1996 - Earnings between 

$7,741 and $15,480 

14% 0.04 17% 11% 

1996 - Earnings greater 

than $15,480 

9% 0.02 13% 5% 

All non-custodial parents 40% 0.04 47% 34% 

Child Support for Children on TANF 16 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 Parent’s 

Income Below $7,470 -.1682* .0719 -2.34 .0519 

C. Non-Custodial Parent’s 

Income $7,471 - $14,940 (Omitted 

category) 

D. Non-Custodial Parent’s 

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 

Child Support for Children on TANF 17 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. 

Child Support for Children on TANF 18 OEI-05-99-00392 
APPENDIX C 

Agency Comments

Child Support for Children on TANF 19 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, noncustodial 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 lowincome status of many of these children�s non-custodial parents, they would be able to 

meet. The OIG encourages states to experiment with policies dealing with lowincome, 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, noncustodial 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 Labor�s 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 obligor�s 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 lowChild Support for Children on TANF 20 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. 

Child Support for Children on TANF 21 OEI-05-99-00392