Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

JUNE GIBBS BROWN 

Inspector General 

MARCH 2000 

OEI-06-98-00043 

CLIENT COOPERATION WITH 

CHILD SUPPORT ENFORCEMENT 

Use of Good Cause Exceptions 
OFFICE OF INSPECTOR GENERAL 

The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, is to 

protect the integrity of the Department of Health and Human Services programs as well as the 

health and welfare of beneficiaries served by them. This statutory mission is carried out through a 

nationwide program of audits, investigations, inspections, sanctions, and fraud alerts. The 

Inspector General informs the Secretary of program and management problems and recommends 

legislative, regulatory, and operational approaches to correct them. 

Office of Evaluation and Inspections 

The Office of Evaluation and Inspections (OEI) is one of several components of the Office of 

Inspector General. It conducts short-term management and program evaluations (called 

inspections) that focus on issues of concern to the Department, the Congress, and the public. The 

inspection reports provide findings and recommendations on the efficiency, vulnerability, and 

effectiveness of departmental programs. 

OEI's Region VI prepared this report under the direction of Chester B. Slaughter, Regional 

Inspector General and Judith V. Tyler, Deputy Regional Inspector General. 

Principal OEI staff included: 

DALLAS 

Blaine Collins

Ruth Ann Dorrill

Marnette Robertson

Clark Thomas, Ph.D.

Nancy Watts

Lisa White

FIELD OFFICES 

Lucille Cop 

Vincent Greiber 

Ianna Kachoris 

Thomas Purvis 

Graham Rawsthorn 

HEADQUARTERS 

Alan Levine, Program Specialist 

Joan Richardson, Program Specialist 

Linda Hall 

To obtain copies of this report, please call the Dallas Regional Office at 214-767-3310. 

Reports are also available on the World Wide Web at our home page address: 

http://www.dhhs.gov/progorg/oei 
EXECUTIVE SUMMARY 

PURPOSE 

To describe State use of good cause exceptions which exempt Temporary Assistance to 

Needy Families (TANF) clients from requirements to cooperate with child support 

enforcement. 

BACKGROUND 

Federal law requires TANF clients to cooperate with State child support enforcement 

agencies in establishing paternity, and in creating and enforcing child support and medical 

support orders. States are allowed to exempt TANF clients from cooperating with child 

support through good cause exceptions, typically when the pursuit of support is expected 

to result in physical or emotional harm to the child or client, when the child is born as a 

result of forcible rape or incest, or when adoption proceedings are pending. This report 

describes use of good cause exceptions in six focus States which we chose in order to 

examine a variety of implementation strategies and experiences regarding TANF client 

cooperation. We gathered survey responses and reviewed documents from 99 local child 

support and 103 local public assistance offices, and interviewed 180 managers and 

caseworkers. 

FINDINGS 

Public Assistance and Child Support Staff Report Few Requests for Good Cause 

Exceptions and Virtually No Fraudulent Claims 

Consistent with prior research about the use of good cause exceptions, respondents in our 

focus States report receiving few requests for exceptions from TANF clients. Staff 

believe that most, if not all, requests for good cause exceptions are legitimate. While staff 

recognize the potential for clients to fraudulently claim a good cause exception simply to 

avoid cooperating with child support enforcement, no caseworker or manager we 

interviewed was aware of a case with such fraud. Rather, staff indicate that the 

administrative process for requesting an exception deters fraud. 

A Variety of Reasons and Disincentives Help Explain the Low Number of TANF 

Client Requests for Good Cause Exceptions 

Most State child support agencies do not pursue child support enforcement when a good 

cause exception is granted, yet staff report that many TANF clients potentially eligible for 

an exception want child support collected. Some clients find it easier to claim they have 

no information about an absent parent than to corroborate a good cause exception. While 

i 
public assistance staff provide at least minimal notification of good cause exceptions, few 

attempt to assess whether client circumstances support an exception. 

Most Local Offices Make Some Efforts to Preserve Client Safety, But These 

Efforts Are Often Modest and Not Fully Implemented 

Many public assistance and some child support staff refer TANF clients who report 

domestic violence concerns to shelters and other community resources and may also keep 

client addresses confidential to help preserve safety. Most local offices also routinely 

record potential domestic violence problems by labeling paper and electronic case files 

which have good cause exceptions. 

RECOMMENDATIONS 

Successful operation of the child support enforcement program requires effective, 

cooperative action by both the Office of Child Support Enforcement and the Office of 

Family Assistance. Therefore, we recommend that the Assistant Secretary for the 

Administration for Children and Families (ACF) encourage States to complete the 

following. 

Develop Strategies That Allow TANF Clients Who May Be at Risk of Domestic 

Violence to Safely Pursue Child Support 

Enhance Local Office Training to Improve Staff Understanding of Good Cause 

Exceptions and Better Equip Workers to Assist TANF Clients At Risk 

Evaluate Their Standards and Practices for Protecting TANF Client Confidentiality 

and Assess the Need for Further Federal Guidelines 

COMPANION REPORTS 

This is one of four OIG reports on how States gain TANF client cooperation with child 

support enforcement. One companion report, Client Cooperation with Child Support 

Enforcement: Policies and Practices (OEI-06-98-00040), provides an overview of 

cooperation polices and how they are implemented. Another report, Client Cooperation 

with Child Support Enforcement: Challenges and Strategies to Improvement (OEI-06-98-

00041), examines why some clients do not cooperate and how States attempt to gain 

cooperation. The remaining report, Client Cooperation with Child Support Enforcement: 

The Role of Public Assistance Agencies (OEI-06-98-00042), discusses responsibilities of 

public assistance agencies and collaboration between agencies. 

ii 
TABLE OF CONTENTS 

PAGE

EXECUTIVE SUMMARY i

INTRODUCTION 1

FINDINGS

State Use of Good Cause Exceptions 4

Preserving Client Safety 9

Reasons For Clients Not Requesting Exceptions 12

RECOMMENDATIONS 17

ENDNOTES 18
INTRODUCTION 

PURPOSE 

To describe State use of good cause exceptions which exempt Temporary Assistance to 

Needy Families (TANF) clients from requirements to cooperate with child support 

enforcement. 

BACKGROUND 

Federal law requires public assistance clients receiving TANF benefits to cooperate with 

State child support enforcement agencies in establishing paternity and in creating and 

enforcing child support and medical support orders. Cooperation often involves providing 

information about noncustodial parents and appearing for appointments as needed. State 

child support agencies are required to determine if a TANF client is cooperating in “good 

faith” and notify the public assistance agency of each client’s cooperation status. States 

are allowed to exempt clients from child support enforcement cooperation requirements 

through good cause exceptions. 

Prior to the passage of welfare reform legislation,1 Federal law required States to grant 

clients good cause exceptions when one of the following circumstances existed: when 

pursuing paternity establishment or child support enforcement was “reasonably expected 

to result in” physical or emotional harm to the child, or physical or emotional harm to the 

client which reduced “such person’s capacity to care for the child adequately;” and when 

one of three circumstances existed (i.e., the child was born as a result of forcible rape or 

incest, adoption proceedings were pending, or a public or social agency was assisting the 

client to determine whether to release the child for adoption) and because of this 

circumstance, enforcement “would be detrimental to the child.”2 

These pre-reform regulations required States to provide clients with written notification of 

“the right to claim good cause as an exception to the cooperation requirement” prior to 

requiring cooperation and clients to acknowledge such notification “by signing and dating 

a copy of the notice.”3 States were also required, upon request, to “provide reasonable 

assistance in obtaining corroborative evidence” to substantiate a good cause exception 

claim. Clients who claimed good cause under the pre-reform regulations were required to 

“provide corroborative evidence of a good cause circumstance ... [and], when requested, 

furnish sufficient information to permit the State and local agency to investigate the 

circumstances.”4 Once an exception was granted, Federal regulations required State 

public assistance agencies to determine whether child support enforcement could proceed 

without risk of harm to the child or caretaker and notify the client of its determination. 

1
Welfare reform legislation changed many Federal provisions regarding good cause 

exceptions. These changes were made in an attempt to improve client cooperation with 

child support enforcement.5 Current policy allows, but does not require, States to keep 

the prior Federal standards for granting good cause exceptions. States now have 

discretion to expand or constrict the circumstances they accept as qualifying for good 

cause exceptions, as long as they are “taking into account the best interests of the child.”6 

States determine what standards of proof are required to demonstrate the circumstances 

warranting exceptions and which agency - child support, public assistance or Medicaid - is 

responsible for evaluating, and approving or denying, requests for good cause exceptions.7 

States may also decide whether to provide clients any assistance in demonstrating good 

cause circumstances.8 

Researchers, advocates, and policy-makers voice two concerns about States’ use of good 

cause exceptions. The first concern involves the potential for clients to fraudulently claim 

exceptions when they do not have a legitimate fear of domestic violence or other 

qualifying circumstance simply to avoid cooperating with child support enforcement. 

This concern has been minor in the past because States report receiving very few requests 

for exceptions and granting even fewer.9 However, some fear that stricter enforcement of 

penalties for noncooperation may encourage some clients to seek an exception even in the 

absence of qualifying circumstances. Second, because States grant few exceptions, yet 

domestic violence among the TANF population is reportedly widespread,10 there is 

concern that some clients may not request an exception even when they do have 

circumstances that meet a State’s definition of good cause. Some fear that TANF clients 

may not be adequately informed of their right to request an exception or may have other 

reasons or disincentives for not requesting an exception. 

This report describes the use of good cause exceptions in six focus States. We describe 

State policies and processes regarding good cause exceptions to child support cooperation 

requirements. We review State efforts to preserve the safety of clients who are granted an 

exception. We also explore reasons and disincentives that may lead clients not to request 

good cause exceptions. Disincentives are of particular interest because of the apparent 

disparity between the high incidence of domestic violence within the TANF population 

and the relatively small number of requests for good cause exceptions. 

SCOPE AND METHODOLOGY 

To examine State use of good cause exceptions to child support enforcement cooperation 

requirements, we began by gathering information from local child support and public 

assistance offices. Administrators from 99 local child support offices and 103 public 

assistance offices in six States - California, Georgia, Illinois, New Jersey, Texas and 

Virginia - returned mail surveys regarding good cause exception policies and practices. 

We also gathered and reviewed agency documents including client cooperation policy 

statements, standardized claim forms, examples of correspondence with clients, and other 

related documents. Additionally, we made site visits to a subset of local offices, visiting 

2
 offices in one or two cities and their surrounding areas in each of the six focus States. 

During these visits, we conducted interviews with approximately 180 local public 

assistance and child support managers and caseworkers. At almost all offices, we 

interviewed one or more managers, then separately interviewed two or more caseworkers. 

These respondents provided detailed information about how good cause exception policies 

are implemented, as well as the effect of good cause exceptions on office operations, staff, 

and clients. Resource constraints prevented us from directly interviewing clients. Finally, 

we conducted telephone interviews of administrators from each State’s child support 

enforcement and public assistance agency to confirm information regarding State policies. 

We purposively selected the six focus States to include a variety of implementation 

strategies and experiences regarding client cooperation and good cause exceptions. To 

achieve this variety, we considered many criteria including type of penalties for 

noncooperation, number of good cause requests, number of good cause exceptions 

granted, Family Violence Option (FVO) status, outstanding program characteristics 

(innovations, privatization, etc.), and geographic region. We also purposively selected 

local child support and public assistance offices within these States to provide a mix of 

urban, suburban, mid-size, and rural locations. For on-site interviews, we visited offices in 

one or two cities and their surrounding areas in each focus State. The selection of focus 

States does not purport to be representative of the nation, nor do local offices represent all 

offices within individual focus States. The selections do, however, allow for examination 

of good cause exceptions to TANF client cooperation processes under conditions found 

throughout the country. 

This report relies on the experiences and perceptions of local office survey respondents 

and interviewees. We did not attempt to independently verify the information provided. 

However, the information included in the report does relate the experience of front line 

staff who deliver services to clients on a daily basis, and who demonstrate considerable 

concern for the effectiveness of their programs. This study was conducted in accordance 

with the Quality Standards for Inspections issued by the President’s Council on Integrity 

and Efficiency. 

COMPANION REPORTS 

This is one of four OIG reports on how States gain TANF client cooperation with child 

support enforcement. One companion report, Client Cooperation with Child Support 

Enforcement: Policies and Practices (OEI-06-98-00040), provides an overview of 

cooperation polices and how they are implemented. Another report, Client Cooperation 

with Child Support Enforcement: Challenges and Strategies to Improvement (OEI-06-98-

00041), examines why some clients do not cooperate and how States attempt to gain 

cooperation. The remaining report, Client Cooperation with Child Support Enforcement: 

The Role of Public Assistance Agencies (OEI-06-98-00042), discusses responsibilities of 

public assistance agencies and collaboration between agencies. 

3
FINDINGS 

STATE USE OF GOOD CAUSE EXCEPTIONS 

All six focus States have adopted the prior Federal definition of good cause by which 

TANF clients may be exempted from child support cooperation requirements in cases of 

domestic violence, when conception was the result of forcible rape or incest, when 

adoption is pending, or when the client is consulting with a social service agency regarding 

the possibility of adoption. Some focus States have added circumstances that warrant an 

exception, including mental incapacity of the client, cases with non-parent caretakers, 

cases in which conception occurred from artificial insemination, cases in which clients lack 

knowledge about absent parents, and cases in which domestic violence is anticipated. Five 

focus States make their public assistance agency responsible for evaluating requests for 

good cause exceptions. In the sixth State, child support workers evaluate requests for 

good cause exceptions, but are employees of the public assistance agency and work in the 

same offices as public assistance workers throughout the State. 

Staff in Local Public Assistance and Child Support Offices Report Few Requests 

for Good Cause Exceptions and Virtually No Fraudulent Claims 

While our study makes no attempt to quantify the number of good cause exception 

requests processed by local offices, we did ask local office staff their perception of the 

frequency of requests. Consistent with prior research about the use of good cause 

exceptions, respondents in our focus States report receiving few requests for exceptions. 

In many offices, even experienced caseworkers have never had a client request a good 

cause exception, or have only received one or two requests in several years. Typical 

caseworker and manager responses to questions about the frequency of requests for 

exceptions were, “I’ve had one in six years,” and “Very, very few. There is a form in 

there that the worker is supposed to fill out and turn in each month on each [client] that 

claims good cause. I can’t remember the last time I had to fill one out.” One local 

public assistance office administrator reported participating in a Statewide review of good 

cause claims and related her experiences. “I had to review 17 of them. We don't get a lot 

of them. They are primarily domestic violence (proven) or threat of domestic violence. 

Normally they can prove their claim.” 

Staff believe that most, if not all, requests for good cause exceptions are legitimate. One 

worker expressed what we heard from most staff, “The few cases I have had have been 

outright, fully validated cases, such as incest or sexual abuse. The clients could validate 

this, and were not just making up a story.” While staff did recognize the potential for 

clients to fraudulently claim a good cause exception simply to avoid cooperating with child 

support enforcement, no caseworker or manager we interviewed was aware of any such 

attempted fraud. Rather, staff indicate that the administrative process for requesting 

4
an exception deters fraud. Most offices require corroboration, and a client may have to 

relay their story to more than one staff member in one or both agencies. Additionally, 

staff experience in confronting other types of welfare fraud likely helps them in judging the 

authenticity of client good cause exception requests. 

Public Assistance Staff Provide at Least Minimal Notification to TANF Clients of 

Their Right to Request a Good Cause Exception, Yet Few Individually Assess 

Clients for the Circumstances that Might Warrant an Exception 

Ninety-three percent of public assistance staff responding report their offices provide new 

applicants and clients seeking re-determination of benefits written materials explaining 

their right to request a good cause exception. These materials are often included with 

application forms and documents that explain requirements to cooperate with child 

support enforcement. The written explanations of good cause exceptions often include a 

list of the circumstances that may warrant an exception and the standards of proof needed 

to corroborate the circumstances. Additionally, public assistance staff often provide a 

second notice of the opportunity to request a good cause exception to TANF clients who 

have already been deemed noncooperative by the child support agency. 

In addition to providing written notification, 87 percent of public assistance staff 

responding report they discuss good cause exceptions with clients during the application 

process. Staff explain that they typically use the written materials as guides for these 

discussions. However, staff also report they are unlikely to extend their discussions 

beyond the written materials. That is, staff report that during discussions about good 

cause exceptions they seldom go so far as to ask TANF clients whether any of the 

circumstances exist in their lives or to otherwise assess individual needs.11 One public 

assistance administrator summarizes, “We don’t really look for domestic violence. The 

clients have to bring it up.” Upon completion of notice, 96 percent of public assistance 

respondents report they require their clients to sign a form indicating they have received 

notification of their right to request a good cause exception. 

TANF Clients Typically Submit Requests for Good Cause Exceptions to Public 

Assistance Staff, Either Verbally or in Writing, Though Child Support Staff May 

Also Become Involved 

During application or re-determination interviews, clients may formally request a good 

cause exception directly with public assistance staff. Among local public assistance 

respondents, 40 percent report they rely simply on a verbal request, 29 percent require a 

written request, and the remaining 31 percent accept either verbal or written requests for 

exceptions. In some States, the written form for requesting an exception is printed on the 

same form that notifies clients of the State’s child support cooperation requirements. One 

State’s written form includes a check box beside the following statement, “I wish to claim 

good cause for not cooperating with child support requirements. The situations which 

5
 justify good cause have been explained to me. I agree to provide evidence to support 

this claim of good cause within 20 days.” 

Some clients do not mention circumstances that warrant a good cause exception until they 

are meeting with child support enforcement staff. This may occur because child support 

staff often ask more detailed questions and clients may only then realize the risk that the 

State may actually contact the noncustodial parent. Respondents report that when child 

support workers become aware of circumstances that may warrant a good cause 

exception, they typically refer the client back to the public assistance agency to request an 

exception. As one child support worker explains, “If the client comes in and there is 

some sort of fear for their life, their well being, or if there is any type of domestic 

violence, we can always refer [clients] to apply for good cause through the welfare 

department. We tell our clients they need to communicate this back to welfare as soon as 

possible.” Child support staff report they also notify the public assistance agency of their 

action. 

States Require TANF Clients to Corroborate Circumstances That Warrant Good 

Cause Exceptions Within a Specified Time Frame, and Most Local Offices Will 

Grant Time Extensions and Assist Clients in Gathering Information 

All focus States have policies requiring TANF clients to provide documentation of 

circumstances that warrant a good cause exception. Almost all local public assistance 

staff (93 percent) report they require proof or documentation of domestic violence, and 

most (81 percent) also require documentation that conception occurred as a result of 

forcible rape or incest, or that adoption is pending. 

As shown in Table 1, local offices accept several types of evidence to corroborate 

circumstances of domestic violence, including police reports, court orders, hospital 

records, and shelter documentation. More than half of local respondents report they also 

accept written statements of clients (59 percent), or friends of clients (62 percent), who 

attest to having knowledge of domestic violence. Some local offices accept verbal 

statements from the clients or acquaintances, without need for written verification. 

To corroborate pending adoption or conception as a result of forcible rape or incest, 

clients may present such documentation as adoption papers, court documents, birth 

certificates, police reports and hospital records. Staff note that clients may not have 

documented the nature of conception at the time of birth, and that client statements are 

often allowed as acceptable evidence of these circumstances. 

States require TANF clients to corroborate circumstances that warrant a good cause 

exception promptly upon request for an exception, though many grant time extensions. 

Ninety-one percent of public assistance staff report their offices allow recipients between 5 

and 30 days to produce good cause evidence. Only nine percent of local respondents 

report initially allowing clients more than 30 days to corroborate their claims. Regardless 

6
of time limits, 89 percent of public assistance staff say they will extend the time allowed 

for corroboration. Local public assistance staff report granting extensions often (28 

percent), sometimes (35 percent) or rarely (37 percent). 

Table 1: DOCUMENTATION ACCEPTED FOR DOMESTIC VIOLENCE CASES 

Documentation of Domestic Violence Local Focus Offices 

Police record or documentation of abuse in the home 94% (89 offices) 

Protective order already in place 89% (85) 

Hospital record or documentation of abuse 86 % (82) 

Shelter documentation or statement 79 % (75) 

Written statement by a friend of the custodial parent 62 % (59) 

Referral to domestic violence shelter 61 % (58) 

Written statement by the custodial parent 59 % (56) 

Verbal statement by the custodial parent 34 % (32) 

Verbal or written statement by mental health professional, clergy, 

medical, court, or social service agency 21 % (20) 

Verbal statement by a friend of the custodial parent 19 % (18) 

Eighty-three percent of local public assistance staff report they will assist clients in 

gathering information or evidence to document circumstances which warrant a good cause 

exception. Assistance would involve contacting courts, hospitals, police departments, or 

other agencies. For example, one worker said, “We ask [the client] for a copy of a 

restraining order. If they don’t have it with them, I will call the police asking them to fax 

a copy.” While most local offices wait until clients request assistance in gathering 

documentation, twenty-eight percent of respondents report their staff will automatically 

assist clients without a request. Prior to welfare reform, States were required to provide 

this type of assistance to clients upon request. Sixteen percent of local public assistance 

respondents report their staff will not assist clients in obtaining documents to corroborate 

their request for a good cause exception. Our research suggests, however, that gathering 

documentation for corroboration of claims is not a substantial barrier to most clients who 

seek an exception, whether or not staff assist them, and that, if necessary, staff may even 

waive the requirement for documentation. 

Local Public Assistance Staff Evaluate Requests for Good Cause Exceptions and 

Have Discretion in Deciding Whether Clients Qualify 

Respondents report that front line public assistance staff typically decide whether to grant 

good cause exceptions to requirements to cooperate with child support enforcement. 

Caseworkers explain that they have the advantage of dealing directly with TANF clients to 

7
evaluate their claims. Workers suggest that discussion with clients often helps them 

understand the client’s circumstances. As one worker reports, “It depends on the client's 

situation. You can usually tell [if the circumstances exist].” 

Public assistance managers and supervisors also often participate in good cause exception 

determinations. These administrators may simply consult with caseworkers, or they may 

actually make the final decision. During interviews, many caseworkers said they had 

limited experience with requests for exceptions and that they would seek input from a 

supervisor before making a final determination. They report, “Cases are so few that a 

worker would come to us to ask how to handle a case, because it is not a routine 

situation.” and “I wouldn’t take good cause for someone without having discussed it with 

at least another co-worker to make sure that I’m doing it right. I have the authority and 

it could be my judgement, but I would feel more comfortable taking it to my supervisor 

because it is not something that comes up every day. Maybe, once a year you get a client 

claiming good cause.” A few public assistance workers report routinely consulting their 

child support enforcement counterpart before deciding to grant or deny requests for 

exceptions. When this occurs, child support staff typically review and comment on the 

findings and basis for a proposed determination. 

Staff appear to have substantial discretion as they evaluate good cause exception requests. 

Even in the absence of written documentation, staff may grant an exception. For example, 

one caseworker describes, “In most cases, now, we just take her at her word, and she 

does not have to have any other evidence, like a police report. If she says she is afraid 

[and] has verification, fine. But if not, we will take her word for it.” Additionally, 

considering that so few clients request exceptions, staff appear to prefer to approve 

requests, lest they mistakenly deny a legitimate request. As one supervisor explains, "Very 

few claims are ever refused because the liabilities far outweigh the benefit of collecting 

that support." 

Staff use internal agency “determination forms” to process requests for good cause 

exceptions in all focus States. Some determination forms identify the circumstances for 

the request, and record client information, evidence provided, and the source of evidence. 

Other forms simply record whether the exception was granted. Local public assistance 

offices typically notify TANF clients in writing of their decision to grant or deny a good 

cause exception request. Such notice often includes information about any future steps 

the client needs to take. Clients whose requests for a good cause exception are denied can 

appeal the decision. Ninety percent of local public assistance staff report that clients may 

appeal a determination to a caseworker’s supervisor. If the dispute remains unresolved, 

clients can request a formal hearing. 

Most Public Assistance Offices Periodically Reassess Good Cause Exceptions 

Seventy-four percent of public assistance staff report their offices conduct periodic 

reassessments of good cause exceptions. About half of these respondents specify that 

8
they reassess every six months, while the others reassess every twelve months. If 

circumstances have changed and a good cause exception no longer applies, the public 

assistance agency may rescind the exception, again requiring TANF clients to cooperate 

with child support enforcement. About one-quarter of public assistance staff report that 

their office does not reassess clients with good cause exceptions. Most of these offices do 

not have routine procedures for reassessment, and a few appear confused about their 

office’s role, including some who believe the child support agency periodically reassesses 

clients with exceptions. 

Most State Child Support Agencies Do Not Pursue Paternity Establishment or 

Child Support Enforcement When a Good Cause Exception Is Granted 

Caseworkers explain that some TANF clients wish to pursue child support enforcement 

despite the existence of circumstances that warrant a good cause exception. According to 

policy documents, five focus States will not pursue paternity establishment or child 

support enforcement in cases in which the client has been granted a good cause exception. 

The other State has a policy allowing clients to determine whether the child support 

agency will pursue enforcement. However, 37 percent of local child support respondents 

report they will pursue support if the client wishes, including some local respondents from 

States with a policy not to pursue support. Some of these respondents may be unclear 

about State policy because they have never encountered a good cause case, but it appears 

that some local staff may use discretion in pursuing support. 

Local child support staff report they handle cases with good cause exceptions in one of 

four ways: the public assistance agency never refers the case to the child support agency; 

the case is referred, but the child support agency never adds it to their caseload; the case is 

referred and child support adds it to their caseload, but immediately closes the case, never 

pursuing enforcement; or, the case is referred and child support adds it to their caseload, 

but only pursues enforcement at the client’s request. 

PRESERVING CLIENT SAFETY 

The objective of granting good cause exceptions is often to protect clients and children 

from harm. In processing good cause requests, public assistance and child support staff 

report they have some mechanisms in place to help ensure this protection. Local offices 

may also promote additional services to assist clients, beyond exempting them from child 

support cooperation requirements. 

Nearly All Local Public Assistance and Child Support Offices Make Some Effort to 

Preserve Client Safety, and 78 Percent of Staff Believe Good Cause Exceptions 

Reduce the Threat of Harm 

Ninety-two percent of local child support and 96 percent of local public assistance staff 

report having procedures in place to preserve the safety of custodial parents and children 

9
who fear harm from noncustodial parents. These procedures often center on preserving 

confidentiality of case information, but may still be modest efforts and not yet fully 

implemented. Additionally, local child support and public assistance office efforts to 

preserve confidentiality may be limited by court documentation that is not kept secure. 

Staff from both agencies appear to appreciate the purpose of good cause exceptions, and 

78 percent of respondents in both agencies report they believe receiving a good cause 

exception reduces the threat of harm to the custodial parent and child. Table 2 outlines 

procedures local offices use to enhance client safety. 

Table 2: REPORTED PROCEDURES TO ENHANCE CLIENT SAFETY 

Procedures to Enhance Client Safety Public Assistance 

Focus Offices 

Child Support 

Focus Offices 

Referral to domestic violence shelter 80% (76 offices) 29% (25 offices) 

Referral to domestic violence counselor or group 76% (73) 29% (25) 

Measures to protect client address confidentiality 58% (56) 72% (63) 

Flag in automated system to identify cases 35% (34) 51% (44) 

Many Public Assistance and Some Child Support Staff Refer TANF Clients Who 

Report Domestic Violence Concerns to Community Resources 

As reported in Table 2, primarily public assistance, but also child support, staff report they 

refer clients to community resources when domestic violence is a concern. Typically, 

these referrals are to resources specific to domestic violence, such as women's shelters or 

violence counselors, but may include other community resources such as food banks, 

homeless shelters, churches and child care services. A few public assistance offices we 

visited actively coordinated these additional social services. For example, one urban office 

offered transportation to a nearby shelter. In other public assistance offices, staff may 

simply pass out brochures, distribute shelter phone numbers, or verbally mention the 

availability of such resources. As part of large social service agencies, some child support, 

and particularly public assistance offices, have counselors or social workers available onsite to assist clients with domestic violence issues. As one public assistance worker 

reports, “We are not trained, in that we don't have advanced degrees, but we refer 

[clients to services]. A lot of times they are in various emotional states and they just 

need a social worker to talk to them. They just need to tell their stories.” Staff are 

limited by the number of services available in their particular community. Although there 

is wide variation in available services, most communities appear to have agencies or nonprofit entities which assist victims of domestic violence. 

10
Protecting Client Addresses is a Common Practice of Local Public Assistance 

and Child Support Offices to Help Preserve Client Safety 

Noncustodial parents are likely to never be contacted for child support enforcement when 

a good cause exception has been granted. However, a few child support offices may 

continue to pursue support even when a good cause exception has been granted, and some 

clients who are at risk of domestic violence may choose not to request an exception in 

order to pursue support. Under these circumstances, child support and public assistance 

offices may contact noncustodial parents regarding their support obligations. In sending 

letters and documents, offices may inadvertently reveal the county of residence or even 

more specific location information about the client and children. A number of respondents 

report taking precautions in sending information to noncustodial parents in all cases, while 

others only take such measures when a client indicates a domestic violence problem. For 

example, some staff report that they are not allowed to use client or child address 

information in correspondence with noncustodial parents when a case is known to involve 

a risk of domestic violence. Other staff report they take no further action on such cases. 

Among focus State offices which report any precautionary procedures, 72 percent of child 

support and 58 percent of public assistance respondents report they take some measures 

to protect the confidentiality of client and child addresses. 

Most Local Offices Routinely Record Potential Domestic Violence Problems by 

Labeling Paper and Electronic Case Files Which Have Good Cause Exceptions 

Ninety-eight percent of local public assistance and 67 percent of child support staff in 

focus States keep client records which indicate the specific circumstances surrounding a 

good cause exception. Records indicate and differentiate between whether the exception 

was granted because of domestic violence, conception due to forcible rape or incest, 

pending adoption, or other exceptions. Most of these offices report their objective in 

differentiating files and flagging cases is to preserve client safety. 

Under welfare reform, States are required to place a Family Violence Indicator (FVI) on 

all relevant child support case files and are not allowed to release files which include an 

FVI if the State has reason to believe the release of this information may result in physical 

or emotional harm to the client or child.12 At the time of our data collection, several 

months prior to the Federal deadline for implementing the FVI, 35 percent of local public 

assistance and 51 percent of local child support staff report employing an automated flag 

in the agency computer system. Among local child support offices which do not keep 

specific records of the type of good cause circumstances, respondents report staff are 

made aware of safety concerns through their automated referral from the public assistance 

agency. 

Staff report several advantages to indicating the reasons for a good cause claim on the 

client’s record. First, with this information, offices may be able to implement and apply 

precautionary measures to more effectively protect the client and possibly even pursue 

11
child support. Second, records of any exceptions will already be established when clients 

later attempt to receive public benefits or pursue child support in another county or State. 

That area’s child support and public assistance staff are then notified of the potential for 

domestic violence when they review the case file. Transfer of files to other counties or 

States may also benefit from child support agencies actually opening and immediately 

closing a case, rather than not opening one at all. When the former occurs, the child 

support office in the client’s new location would receive notice of the good cause 

exception, regardless of whether the client continues to receive TANF benefits. 

A third benefit to differentiating records by the types of circumstances for a good cause 

exception is that offices may be able to use the information for future case analysis and for 

aggregate data collection. Numerous local child support (36 percent) and public 

assistance (48 percent) staff report they keep office statistics with this type of information. 

A quarter of the child support (24 percent) and public assistance (27 percent) staff report 

they refer to such information to determine how frequently the case has been, or should 

be, reviewed. Child support staff explain that the information is used to help determine 

whether child support should be pursued; however, most often such cases are routinely 

closed or staff cease all action on the case. 

A Few Offices Assist Exempted TANF Clients in Creating a Safety Plan Outlining 

Actions They May Take to Escape Domestic Violence 

Requesting a good cause exception to child support cooperation requirements may open 

an opportunity for local agency staff to discuss an overall plan to safely escape domestic 

violence. Advocates for victims of domestic violence suggest that developing such a 

safety plan for the custodial parent and child to escape future violence may enable the 

child support agency to eventually pursue support. Commonly called “safety plans,” these 

documents are typically personalized to the particular client and outline emergency 

procedures which clients may take if they decide to leave their abuser, and may also 

provide information to ease their transition to independence. These plans can serve as a 

checklist to ensure the victim does not neglect important details and is able to leave their 

abuser under the safest possible conditions. Safety plans often contain phone numbers and 

locations of community resources, family, friends and police, as well as data on financial 

accounts and school records, and even instruction in physical self-defense. In our focus 

States, just eight percent of local public assistance and three percent of local child support 

staff report they routinely provide at-risk clients with information about developing 

personal safety plans. This assistance typically consists of distributing brochures outlining 

safety plans or providing samples of completed plans.13 

REASONS FOR CLIENTS NOT REQUESTING EXCEPTIONS 

Despite efforts to inform TANF clients about good cause exceptions, public assistance 

staff report they receive few requests for exceptions each year. Even some experienced 

workers indicate they have never had a client request an exception. Staff emphasize that 

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few, if any, clients fraudulently request an exception. Rather, both child support and 

public assistance staff suggest a number of reasons and disincentives which help explain 

limited client use of good cause exceptions. 

Some TANF Clients May Not Request An Exception Because They Want the State 

to Pursue Child Support Enforcement 

As reported above, most of our focus States have policies not to pursue child support 

enforcement in cases with good cause exceptions. As shown in Table 3, almost two-thirds 

of public assistance (66 percent) and child support (64 percent) staff report these policies 

are reasons that more potentially eligible clients do not request a good cause exception. A 

child support worker comments, “I think most of the custodial parents who have been 

abused still want to get the noncustodial parent to pay child support.” Child support 

income is potentially important to the self-sufficiency of TANF clients, and staff report 

that some clients who would qualify for good cause prefer to by-pass requesting an 

exception in hopes of eventually receiving child support. In addition to financial motives, 

some clients want to pursue support for reasons of fairness, “We get moms who feel the 

guy should not get off the hook for support by battering her. We refer them to legal 

services to help them prepare restraining orders and everything they might need to take 

action to protect themselves. If they want to pursue the case, it is up to them, but we feel 

they should have all necessary referrals to protect themselves.” 

Table 3: CHILD SUPPORT AND PUBLIC ASSISTANCE STAFF PERCEPTIONS OF 

REASONS WHY TANF CLIENTS DO NOT REQUEST GOOD CAUSE EXCEPTIONS 

Reasons Why Clients Do Not 

Request Good Cause Exceptions 

Public Assistance 

Focus Offices 

Child Support 

Focus Offices 

Want to pursue child support 66% (65 offices) 64% (61 offices) 

Claiming lack of information may be safer 59% (58) 54% (52) 

Easier to claim lack of knowledge 58% (57) 58% (56) 

Embarrassed to admit domestic violence exists 56% (55) 46% (44) 

Fear intervention by child welfare agency 34% (34) 43% (41) 

Fear retaliation from the noncustodial parent 28% (28) 25% (25) 

Don’t understand the good cause provisions 23% (23) 46% (44) 

Don’t know about the good cause provision 6% (6) 34% (33) 

Some TANF Clients May Not Request An Exception Because They Fear Further 

Abuse or Unwanted Intervention From Other Social Service Agencies 

Although all focus States have begun to implement safety procedures, clients may still be 

concerned that an abusive noncustodial parent may be able to locate them because their 

13
address or other information is not secure. This apparently prevents some clients from 

disclosing any information about their situation. Table 3 shows that 28 percent of public 

assistance and 25 percent of child support staff report some clients fear retaliation from a 

noncustodial parent. Additionally, in local interviews, several child support workers in 

each State expressed concern about the confidentiality of court proceedings. Their 

concerns include the need for a procedure to notify the judge of domestic violence 

concerns and the confidentiality of social security numbers and addresses on all court 

documents. For example, one child support administrator explained, “There is much 

frustration with the court process. Court documents are public information, and 

therefore he can find out all of her information. We cannot protect clients if it goes to 

court. If we are going after him she wants us to guarantee that we can protect her.” 

Fear of harm and immediate prevention of harm to their family may take precedence over 

disclosing any information about the noncustodial parent, including circumstances which 

would qualify for a good cause exception. For example, public assistance staff explain, 

“We have a lot of women who won’t apply for assistance no matter how much we 

convince them it’s confidential. It scares them to even talk. They are concerned that he 

could find out where she is.” 

Some staff do not agree that pursuing support will automatically place a client at further 

risk. In interviews, staff indicated that courts may take action to protect the client, such as 

issuing restraining orders. A child support administrator reports, “It's not always the case 

that enforcing child support in domestic violence cases endangers the mom. The judge 

deals with domestic violence issues and it is out of our hands ... they handle that in family 

court.” Other tactics intended to minimize contact between the client and the 

noncustodial parent may allow offices to pursue support despite the threat of violence.14 

As also seen in Table 3, numerous child support (43 percent) and public assistance (34 

percent) staff believe that custodial parents may fear that disclosure of domestic abuse 

may lead to an intervention by the child welfare agency. By admitting to a State agency 

that the household is at risk of violence, the client may be inviting an investigation that 

could jeopardize her custody. A public assistance administrator says, “I think many 

clients just don’t bother to claim it and provide the documentation. Others don’t want to 

disclose that sort of thing. Child protective services (CPS) sometimes gets involved. If 

the mother claims that the child is in danger, she might fear the CPS will take the kids 

away.” Clients may also fear that police will be called to arrest the noncustodial parent for 

abuse, especially if child support enforcement in their State is part of a law enforcement 

agency. 

Some TANF Clients May Not Request An Exception Because They Find it Safer 

and Easier to Claim a Lack of Knowledge About Absent Parents 

Clients who fear retaliation or child welfare agency involvement, as well as clients who 

wish to avoid the process of requesting and corroborating circumstances that warrant a 

good cause exception, may find it safer and easier to simply cooperate with child support 

14
enforcement than to request an exception. As shown in Table 3, 59 percent of child 

support and 54 percent of public assistance respondents believe that clients may view 

claiming a lack of knowledge about absent parents as safer than requesting a good cause 

exception. Similarly, 58 percent of respondents from each agency perceive that clients 

may view claiming a lack of knowledge as easier than requesting an exception. A public 

assistance administrator explains, “I think rather than claim good cause they just tell us 

they don’t know because it’s shorter and faster or because they think that nothing will 

happen. So many of our clients have gone on and off welfare that they think because 

they didn’t have to worry about it before, why should they have to worry about it now.” 

As we report elsewhere, claiming a lack of knowledge about absent parents does not 

release clients from otherwise cooperating with child support enforcement efforts 

including keeping appointments for interviews, court hearings and genetic testing.15 

However, formally attesting to a lack of knowledge does satisfy the cooperation 

requirements of three of our focus States and may satisfy requirements to cooperate in 

“good faith” in other States. Therefore, through this strategy clients may avoid being 

penalized for noncooperation, avoid providing information about a noncustodial parent, 

and avoid requesting and corroborating a good cause exception. The primary 

disadvantage of the strategy for clients is that they are far less likely to have child support 

collections as a source of income once they stop receiving TANF benefits. 

Some TANF Clients May Not Request An Exception Because They Do Not Fully 

Understand Benefits and Requirements, and Staff May Not Provide Guidance 

Table 3 also shows that while 34 percent of child support workers report they believe 

more clients do not request exceptions because they do not know about them, only six 

percent of local public assistance staff believe this is a reason. The difference here is likely 

to lie in the fact that it is primarily public assistance staff who are responsible for notifying 

clients of their right to request a good cause exception. Perhaps more importantly, 23 

percent of public assistance and 46 percent of child support staff responding suggest that 

clients do not seek an exception because, although they are aware of the good cause 

exception, they do not fully understand it. Clients often receive a large amount of 

information and answer many questions during their initial interview, of which only a small 

part involves discussion of good cause exceptions. It may be difficult for clients to 

understand the significance of the provisions unless workers make a special effort to 

emphasize them. 

While 68 percent of public assistance staff report they include information about domestic 

violence and client safety in their staff training programs, only 48 percent of child support 

respondents report similar information in their training. Several child support 

administrators told us that because it is the public assistance office which normally decides 

whether to grant good cause exceptions, they assume public assistance workers are trained 

to identify domestic violence, so there is little need to train their own 

15
staff. If staff are not trained to provide education and outreach to identify good cause 

circumstances, clients may not understand that they can request an exception or how to do 

so. Without assistance from a worker, some clients may not identify themselves as 

potential candidates for good cause exceptions. As one child support administrator 

comments, “You may see some signs, but without training we don’t really know how to 

identify the signs.” A public assistance administrator adds, “We have had very limited 

training in domestic violence issues. We deal with it purely on what the client tells us on 

a client-by-client basis. We have no real standardized procedures.” 

Additionally, although the term “good cause” has a formal meaning in child support 

cooperation regulations, we found staff sometimes also use the term, for example, to refer 

to the client’s difficulty in arranging transportation to an appointment as a “good cause” 

for not cooperating. While most workers appear to know that they use the same term to 

refer to a variety of situations, multiple use of the term “good cause” can create confusion 

and misunderstanding among staff and clients. 

Some TANF Clients May Not Request An Exception Because They Find It Difficult 

to Disclose Circumstances of Domestic Violence 

Also shown in Table 3, about half of public assistance (56 percent) and child support (46 

percent) staff report they perceive that clients are embarrassed to admit they are victims of 

domestic violence. Clients may not want to disclose their circumstances to a stranger, 

especially if the worker is not able to take time to carefully explain the good cause 

exception and make an effort to gain the client’s trust. Clients may also be intimidated by 

the volume of information collected during an interview, particularly in the public 

assistance office. Public assistance interviews can last from 30 minutes to two hours, 

covering a wide range of topics. Some public assistance offices assign a single caseworker 

to handle nearly all aspects of a client’s case, in part to allow the client to develop a 

relationship with that worker. However, clients in other offices may communicate with 

different workers who specialize in various aspects of their case. The physical setting of 

the office, particulary if interviews take place in a large room with no partitions for 

privacy, may also affect the client’s willingness to divulge information. 

Creating an atmosphere that eases disclosure may be more difficult with victims of 

domestic violence than with other clients. One male public assistance worker says, “ 

... when I talk to someone who has been in an abusive relationship, I find I have to be 

especially soft when I talk to them, tone everything down, and make them see I 

understand, and not to frighten them ....” Clients may be even more hesitant to confide in 

child support staff since they are likely to ask more questions specific to the father, and 

may be housed in a law enforcement agency that some clients may perceive as threatening. 

One worker explains that they consider client comfort, “We let her know that we are 

going to help her as best we can, [and] that we understand the situation. So we get them 

to open up as much as possible, but still there is a shame factor, and we know she usually 

does not tell us everything.” 

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RECOMMENDATIONS 

Successful operation of the child support enforcement program requires effective, 

cooperative action by both the Office of Child Support Enforcement and the Office of 

Family Assistance. Therefore, we recommend that the Assistant Secretary for the 

Administration for Children and Families (ACF) encourage States to: 

Develop Strategies That Allow TANF Clients Who May Be at Risk of Domestic 

Violence to Safely Pursue Child Support 

Child support agencies typically do not pursue child support for TANF clients who are 

granted a good cause exception, yet victims of domestic violence would likely benefit 

from the additional income child support could provide. ACF should assist States in 

developing practices which would allow clients who are at risk of domestic violence to 

decide whether the State’s child support agency will pursue support and help protect 

clients who decide to do so. This might include taking precautions during court 

appearances, making further referrals to community resources, and assisting clients to 

develop safety plans. 

Enhance Local Office Training to Improve Staff Understanding of Good Cause 

Exceptions and Better Equip Workers to Assist TANF Clients At Risk 

For effective use of good cause exceptions, staff should understand the benefits and 

requirements associated with exceptions, be able to identify individuals who may be 

eligible for an exception, and be prepared to assist clients in requesting and corroborating 

an exception. ACF should assist States in developing training tools that both clarify State 

policy and address ways to individually assess and work with clients who are at risk of 

domestic violence to improve their safety and cooperation. 

Evaluate Their Standards and Practices for Protecting TANF Client Confidentiality 

and Assess the Need for Further Federal Guidelines 

Clients who perceive themselves at risk of domestic violence may fear disclosure of 

personal information, discouraging them from either cooperating with child support or 

requesting a good cause exception. ACF should assess agency practices in contacting 

noncustodial parents, including the use of identifying information on correspondence and 

court documents, and encourage all agencies involved to promote a safe environment for 

clients. Also, ACF should explore with States the feasibility of labeling all cases with 

good cause exceptions or risk of domestic violence, both to enhance confidentiality and to 

improve caseload analysis. In communicating with States on these issues, ACF should 

assess whether further Federal guidance is needed. 

ACF did not provide comments in response to our draft report and recommendations. 

17
ENDNOTES 

1. The Personal Responsibility and Work Opportunity Act of 1996 

2. 45 CFR 323.42. 

3. 45 CFR 323.40. 

4. Ibid. 

5. The Federal Office of Child Support Enforcement (OCSE) has helped facilitate a number 

of national meetings to further explore the ramifications of these changes, and created 

materials to provide assistance to States in implementing the policy regarding good cause 

exceptions. OCSE has also funded several demonstration projects to test different models 

for using good cause exceptions and assisting clients at risk of domestic violence. 

6. 42 U.S.C. Section 654(29). 

7. We do not attempt to assess any change in agency responsibility for administering good 

cause exceptions among our focus States as a result of welfare reform. 

8. In a related matter, welfare reform legislation also instituted the Family Violence Option 

(FVO), a provision designed to take into account the effect of domestic violence on a 

client’s ability to meet program requirements. States which adopt the FVO may exempt 

TANF clients from child support cooperation requirements, as well as work and other 

program requirements, and avoid Federal penalties for failure to meet work participation 

rates if the State demonstrates that their failure was due to exempting clients for 

“Federally recognized good cause domestic violence waivers.” In order to grant these 

waivers, States must assess clients for a history of domestic violence, refer such 

individuals to counseling or supportive services, and assure that waivers from program 

requirements are accompanied by an “appropriate service plan.” Federal Register: April 

12, 1999 (Volume 64, Number 69), page 17881. At the time of data collection, three of 

our focus States had passed the FVO. We determined that it was too early in the 

implementation of this provision to assess the impact of adopting the FVO. 

9. For example, the Office of Child Support Enforcement reports that only 4,196 clients (of a 

total AFDC-TANF caseload of 6,461,723 clients) requested a good cause exception to 

child support cooperation requirements in 1997, and only 2,296 exceptions were granted 

by States. The Federal Office of Child Support Enforcement, 22nd Annual Report, 

Appendix C, Tables 46 and 26, respectively. 

10. See, for example, “Domestic Violence: Prevalence and Implications for Employment 

Among Welfare Recipients,” Government Accounting Office, November 1998, 

GAO/HEHS-99-12. 

18
11. The frequency of assessments may increase as States implement the FVO, which requires 

States to screen public assistance applicants for a history of domestic violence. 

12. 42 U.S.C. 654(26)(B)(C). 

13. States which adopt the Family Violence Option are required to develop appropriate 

service plans for victims of domestic violence, which would typically include safety 

considerations. 

14. A recent report produced collaboratively by OCSE and The Center for Law and Social 

Policy, “Models for Safe Child Support Enforcement,” describes a number of strategies 

employed by States in order to enhance client safety while pursuing support. 

15. For more information on cooperation requirements, please refer to our companion report 

entitled, Client Cooperation with Child Support Enforcement: Policies and Practices, OEI 

06-98-00040, 2000. 

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