Report to the Chairman, Committee on 

Finance, U.S. Senate 

United States General Accounting Office 

GAO

March 2004 CHILD SUPPORT 

ENFORCEMENT 

Better Data and More 

Information on 

Undistributed 

Collections Are 

Needed 

GAO-04-377 
www.gao.gov/cgi-bin/getrpt?GAO-04-377.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Cornelia M. 

Ashby at (202) 512-7215 or 

ashbyc@gao.gov). 

Highlights of GAO-04-377, a report to the 

Chairman, Committee on Finance, 

U.S. Senate 

March 2004

CHILD SUPPORT ENFORCEMENT

Better Data and More Information on 

Undistributed Collections are Needed 

OCSE reported that the amount of undistributed collections for fiscal year 

1999 was $545 million and $657 million for fiscal year 2002; however, these 

amounts may not be accurate. State agencies had different interpretations of 

what comprised undistributed collections and data reported by several state 

agencies were found to be unreliable throughout this time period. OCSE 

revised the reporting form, but data accuracy concerns remain, in part, 

because OCSE does not have a process to ensure the accuracy of 

undistributed collections data. 

Federal law, some state policies, and inaccurate or missing information were 

the underlying causes of nearly all types of undistributed collections. State 

agencies determined how long they held collections from joint tax refunds 

and if they held collections received before they were due. Federal law 

allows collections intercepted from joint tax refunds to be held for up to 

180 days and in response to GAO’s survey, 34 state agencies reported holding 

them for 180 days. Missing or inaccurate information, such as invalid 

addresses, also leads to undistributed collections. Based on state agencies’ 

survey responses, GAO determined the median value of the undistributed 

collections from joint tax refunds was about $1.8 million and the median 

value of four other types of undistributed collections exceeded $350,000. 

Median Amounts for Five Types of Undistributed Collections Reported by State Agencies as 

of June 30, 2003 

Types of undistributed collections 

Median amount

rounded

Number of State 

agencies that 

reported an 

Amount

From joint tax refunds $1,750,000 32

Received before they were due $466,000 33

Pending legal resolution $431,000 24

With an invalid address for custodial parents $399,000 35

With data problems (overpayments, no active 

case, missing or inaccurate data, etc.) $363,000 30

Source: GAO survey. 

State agencies GAO visited took steps to better understand and reduce 

undistributed collections. Of the 6 state agencies visited, 5 had analyzed 

their undistributed collections cases, 4 adopted performance goals, and 

officials from all 6 state agencies stressed the importance of researching 

collections that were missing information. In addition, officials stated that 

using automated processes to receive and distribute collections helped 

reduce the number of collections with missing or inaccurate information. 

OCSE has provided some assistance to help state agencies reduce their 

undistributed collections. However, the Department of the Treasury has not 

provided OCSE information that would allow state agencies to distribute 

collections from joint tax refunds to families sooner. Further, OCSE’s efforts 

to obtain this information have been minimal. 

Congress established the child 

support enforcement program in 

1975 to ensure that parents 

financially supported their 

children. State agencies administer 

the program and the Office of Child 

Support Enforcement (OCSE) in 

the Department of Health and 

Human Services oversees it. In 

2002, state agencies collected over 

$20 billion in child support, but 

$657 million in collections from 

2002 and previous years were 

undistributed—funds that were 

delayed or never reached families. 

One method used to collect child 

support, intercepting federal tax 

refunds, involves all state agencies, 

OCSE, and two Department of the 

Treasury agencies—the Internal 

Revenue Service (IRS) and the 

Financial Management Service 

(FMS). GAO was asked to address 

(1) how the total amount of 

undistributed collections changed 

over the years, (2) the causes of 

undistributed collections, 

(3) states’ efforts to reduce these 

funds, and (4) OCSE’s efforts to 

assist states. GAO analyzed OCSE 

data, administered a survey, visited 

6 state agencies and interviewed 

officials. 

GAO recommends that OCSE 

periodically review undistributed 

collections data and that OCSE, 

IRS, and FMS work together to 

identify a way to share information 

on collections held from joint tax 

refunds. OCSE did not explicitly 

agree or disagree with the 

recommendations. IRS and FMS 

agreed with the recommendation. 
Page i GAO-04-377 Child Support Enforcement 

Letter 1

Results in Brief 3

Background 5

OCSE Reported Millions in Undistributed Collections, but Data 

Were Unreliable 8

Federal Law, Some State Policies, and Inaccurate, or Missing 

Information Delayed or Prevented Distribution of Certain 

Collections 14

State Agencies Took Steps to Reduce Undistributed Collections 19

OCSE Has Assisted States’ Efforts to Reduce Undistributed 

Collections, but the Department of the Treasury Has Not 

Provided Information That Would Help States Distribute 

Collections from Some Joint Tax Refunds Sooner 25

Conclusion 30

Recommendations for Executive Action 31

Agency Comments and Our Evaluation 31

Appendix I Scope and Methodology 34 

Appendix II Survey of State Directors of Child Support 

Enforcement 36 

Appendix III Comments from the Department of Health and 

Human Services 43 

Appendix IV Comments from the Department of the Treasury 46 

Appendix V GAO Contacts and Staff Acknowledgments 48 

GAO Contacts 48

Staff Acknowledgments 48

Contents 
Page ii GAO-04-377 Child Support Enforcement 

Tables 

Table 1: Amount of Tax Refund Offset Collections from 1999 to 

2002 6

Table 2: Categories and Types of Collections to Be Reported as 

Undistributed 11

Table 3: Overestimates of Undistributed Collections and Year 

Reported 12

Table 4: Time Period Collections from Joint Tax Refunds Are Held 15

Table 5: Amounts for Nine Types of Undistributed Collections 

Reported by State Agencies as of June 30, 2003 19

Table 6: Summary of State Agencies’ Responses Regarding the 

Helpfulness of OCSE Efforts 28

Figures 

Figure 1: Types of Collections and Number of State Agencies That 

Included Them in Undistributed Collections Reported to 

OCSE 10

Figure 2: Number of Years State Agencies Reported Holding 

Collections before Declaring Them Abandoned Property 16

Figure 3: Portion of Collections Distributed to Parents 

Electronically 23
Page iii GAO-04-377 Child Support Enforcement 

Abbreviations 

CSE Child Support Enforcement 

EFT Electronic Funds Transfer 

FMS Financial Management Service 

FPLS Federal Parent Locator Service 

HHS Department of Health and Human Services 

IRS Internal Revenue Service 

OCSE Office of Child Support Enforcement 

PRWORA Personal Responsibility and Work Opportunity 

 Reconciliation Act 

TANF Temporary Assistance to Needy Families 

TOP Treasury Offset Program 

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Page 1 GAO-04-377 Child Support Enforcement 

March 19, 2004 

The Honorable Charles E. Grassley 

Chairman 

Committee on Finance 

United States Senate 

Dear Mr. Chairman: 

In 2002, the Office of Child Support Enforcement (OCSE), in the 

Department of Health and Human Services, reported that billions of 

dollars in child support were collected but that payments totaling 

$657 million were delayed or never reached the families for whom they 

were intended. These undistributed child support payments are a concern 

because child support is an important source of income for many families. 

According to a 2003 report, for 36 percent of poor children living in 

families headed by single mothers, child support payments comprised 

almost one-third of the family’s income in 2001. The 1996 Personal 

Responsibility and Work Opportunity Reconciliation Act (PRWORA)1

generally requires state child support enforcement agencies to disburse 

child support collections within 2 business days, if sufficient information 

identifying the recipient is provided. In addition, portions of child support 

collections must be distributed to state government programs, such as 

Temporary Assistance to Needy Families (TANF), to reimburse them for 

cash assistance provided to families. 

Although state child support enforcement agencies administer the child 

support program, the federal government plays a major role.2

 OCSE funds 

two-thirds of the program’s administrative costs; establishes policies and 

guidance; provides technical assistance, such as designing curricula and 

providing support for staff training; and oversees and monitors state 

agencies. Additionally, OCSE is responsible for taking the necessary steps 

to help resolve issues at the federal level that affect the child support 

program such as processes that prevent child support payments from 

reaching families in a timely manner. OCSE and state agencies collect 

 1

Pub. L. No. 104-193, § 312(b) (Aug. 22, 1996). 

2

In this report we will refer to the state child support enforcement agencies as state 

agencies. 

United States General Accounting Office 

Washington, DC 20548 
Page 2 GAO-04-377 Child Support Enforcement 

child support through various methods, such as intercepting the federal 

tax refunds of noncustodial parents—parents who do not have primary 

care, custody, or control of their children—who are delinquent in paying 

their child support.3

 If the noncustodial parent has a new spouse and files 

a joint tax return, generally, only the portion of the refund due to the 

noncustodial parent should be intercepted. Federal law allows state 

agencies to hold collections from certain intercepted federal joint tax 

refunds for up to 6 months to provide time for the new spouse to ask for 

his or her share of the refund by filing an “injured spouse” claim with the 

Department of the Treasury. 

In an effort to understand the issues associated with undistributed child 

support collections, you requested that we address the following 

questions: (1) How has the total amount of undistributed collections 

changed in the last few years? (2) What are the causes of undistributed 

collections? (3) What are state agencies doing to reduce undistributed 

collections? (4) How has OCSE assisted state agencies’ efforts to reduce 

the amount of undistributed collections? 

We obtained information from several sources that provided some data for 

all of the objectives. We conducted a mail survey of all 54 IV-D child 

support enforcement agencies. Forty-eight state agencies responded to the 

survey. We did not assess the reliability of the data the state agencies 

reported in response to our survey. However, we reviewed the data for 

completeness and reasonableness. We conducted site visits to 6 state 

agencies. We selected California, Florida, Iowa, New York, Texas, and 

Virginia because they represented diversity in amounts of undistributed 

collections, and geographical location, and they provided examples of 

statewide and county administered programs. We interviewed federal and 

state officials, reviewed related reports and analyzed applicable laws and 

regulations. In addition, we took specific steps to address each of the 

objectives. To address how undistributed collections have changed, we 

analyzed OCSE data for fiscal years 1999 to 2002 reported by state 

agencies. The fiscal year 1999 data was the earliest year with data 

comparable to fiscal year 2002; the most current data available at the time 

 3

Under some circumstances, the Secretary of the Treasury may collect past due child 

support by offsetting federal tax refunds and other types of federal payments. Collections 

from federal joint tax refunds are held only for non-TANF cases. In this report, the use of 

the word “non-TANF” means that the child support is owed to a custodial parent who is not 

a TANF recipient. Joint tax refunds subsequently mentioned in this report refer to federal 

non-TANF joint tax refunds. 
Page 3 GAO-04-377 Child Support Enforcement 

of our review. We assessed the reliability of undistributed collections data 

reported to OCSE and found that the data were inconsistent and 

unreliable. We also reviewed state and federal reports that discussed 

issues associated with calculating and reporting undistributed collections. 

To identify the causes of undistributed collections, steps state agencies 

have taken to reduce undistributed collections, and assistance OCSE has 

provided to state agencies, we reviewed relevant research and audit 

reports; examined OCSE guidance and documents related to funded 

projects; and interviewed child support advocates and experts. 

We conducted our work between May 2003 and March 2004 in accordance 

with generally accepted government auditing standards. See appendix I for 

more details on our scope and methodology and appendix II for a copy of 

our survey. 

OCSE reported that the amount of undistributed collections for fiscal year 

1999 was $545 million and $657 million for fiscal year 2002; however, these 

amounts may not be accurate because state agencies had different 

interpretations of what comprised undistributed collections and data 

reported by several state agencies were found to be unreliable throughout 

this time period. A little more than half of the 48 state agencies that 

responded to our survey reported that they included collections they 

would distribute in the next 2 business days and collections to be 

distributed to other government programs, while the others did not. In its 

2002 preliminary annual report, OCSE acknowledged the limitations of its 

data due to reporting discrepancies and has revised the reporting form and 

related instructions to provide state agencies with uniform definitions of 

undistributed collections. However, even with a new form and uniform 

definitions, concerns remain about data accuracy within state agencies. 

For example, 1 state reported in 2003 that it had overestimated its 

undistributed collections amount by more than $160 million due to 

accounting errors. Data accuracy concerns remain, in part, because OCSE 

does not verify or periodically review undistributed collections data as it 

does other performance and financial data. 

Federal law and some state policies as well as inaccurate or missing 

information were underlying causes for nearly all undistributed 

collections. Federal law allows collections from joint tax refunds to be 

held for up to 180 days. In response to our survey, 34 state agencies 

reported that they held these collections for 180 days. Inaccurate or 

missing case information also contributed to undistributed collections. For 

example, information needed to determine the correct amount of the 

collection to be distributed to custodial parents who are current or former 

Results in Brief 
Page 4 GAO-04-377 Child Support Enforcement 

TANF recipients was sometimes incorrect or missing, which caused 

payments to be delayed. Additionally, invalid addresses for custodial 

parents caused payments to be returned. Our analysis of state agency 

survey data found that many state agencies reported holding more that 

$1 million from joint tax refunds and several hundred thousand dollars in 

other types of collections. 

To better understand and reduce undistributed collections, state agencies 

we visited devoted resources to analyzing and resolving their 

undistributed collections, established performance goals, and encouraged 

the use of automated payment processes. Nearly all of the state agencies 

we visited conducted extensive analyses of the specific causes of 

undistributed collections. For example, 1 state agency commissioned a 

study with a private firm to determine the causes of undistributed 

collections based on a review of thousands of cases. Four state agencies 

adopted specific performance goals and 1 state agency had a goal to 

maintain an undistributed collections balance of no more than 1 percent of 

total collections. State agencies we visited highlighted the importance of 

dedicating staff to resolving cases with missing information and invalid 

addresses for custodial parents. Additionally, state agencies reported that 

the increased use of electronic processes for receiving and distributing 

funds reduced the amount of undistributed collections because fewer 

collections had missing or inaccurate information. Thirty-seven state 

agencies reported using direct deposit to distribute child support 

payments and 9 state agencies reported using debit cards, which work like 

other automated teller machine cards, credited with the child support 

payments. Officials from 2 state agencies we visited told us that these 

processes reduced the cost of operating the program. For example, 

officials from 1 state agency reported saving over $300,000 per month with 

the use of direct deposit. 

OCSE has provided some assistance to help state agencies reduce 

undistributed collections, but does not have the information needed to 

help reduce undistributed collections from some joint tax refunds. OCSE 

has focused attention on reducing undistributed collections, shared best 

practices and information with state agencies at child support 

conferences, and funded several projects related to undistributed 

collections. To address one of the causes of undistributed collections, in 

March 2003, OCSE issued guidance informing the state child support 

enforcement program directors that they could use the Federal Parent 

Locator Service (FPLS)—a computer matching system with access to 

federal information sources—to help locate custodial parents. However, 

the Department of the Treasury has not provided OCSE with some 

information on “injured spouse” claims filed with tax returns and resolved, 
Page 5 GAO-04-377 Child Support Enforcement 

that would allow state agencies to more quickly distribute collections from 

joint tax refunds. OCSE’s efforts to obtain more information on “injured 

spouse” claims have been minimal. 

In this report, we are recommending that the Secretary of Health and 

Human Services (HHS) direct the Commissioner of the Office of Child 

Support Enforcement to periodically review undistributed collections data 

from state agencies to help improve the accuracy of the data; and we are 

also recommending that the Secretary of Health and Human Services and 

the Secretary of the Treasury work together to identify a cost-effective 

approach for obtaining information related to intercepted tax refunds so 

that these collections can be distributed to families sooner. 

The Department of Health and Human Services and the Department of the 

Treasury provided written comments on a draft of this report. In 

commenting on the draft, the Department of Health and Human Services 

did not explicitly agree or disagree with our recommendations, but raised 

concerns about implementing them. The Department of the Treasury 

agreed with our recommendation. Copies of the written comments from 

the Department of Health and Human Services are in appendix III and the 

comments from the Department of the Treasury are in appendix IV.

Child support is not legally owed until a child support order is issued that 

stipulates the amount the legally identified noncustodial parent—the 

parent who does not have primary care, custody, or control of the child—

is required to pay and when these payments are due. The Child Support 

Enforcement (CSE) program, established in 1975 under Title IV-D of the 

Social Security Act,4

 established federal standards for state CSE programs 

to ensure that parents provide support to their children. Services provided 

through the CSE program include locating absent noncustodial parents, 

establishing paternity and support orders, and collecting and distributing 

child support payments. All 50 states, the District of Columbia, Guam, 

Puerto Rico, and the Virgin Islands operate CSE programs.However, many 

aspects of implementing the child support program are generally under the 

purview of the state rather than the federal government. 

For fiscal year 2002, OCSE reported over 16 million child support cases 

and collections of more than $20 billion. One method for collecting child 

support is intercepting federal tax refunds. Congress enacted the Federal 

 4

42 U.S.C. §§ 651-669b. 

Background 
Page 6 GAO-04-377 Child Support Enforcement 

Tax Refund Offset program in 1981.5 Initially the Internal Revenue Service 

(IRS), an agency within the Department of the Treasury, OCSE, and the 

state agencies operated the program. In 1998 the Financial Management 

Service (FMS), another agency within the Department of the Treasury, 

assumed primary responsibility for the program. Now, all state agencies, 

OCSE, IRS, and FMS play a role in the program. Table 1 shows the amount 

of collections offset from tax refunds from 1999 to 2002. 

Table 1: Amount of Tax Refund Offset Collections from 1999 to 2002 

Calendar year Child support offsets (in billions)

1999 $1.3 

2000 $1.4 

2001 $1.7 

2002 $1.5 

Source: OCSE. 

To start the offset process, state agencies identify those noncustodial 

parents that meet the program criteria. For example, for non-TANF cases, 

the amount of past due support the noncustodial parent owes must be at 

least $500. The state agencies, or OCSE on behalf of the state agencies, 

must send a written notice to the noncustodial parent at least 30 days in 

advance of sending his or her name to OCSE for the offset program. This 

notice includes, among other things, information about filing “injured 

spouse claims.”6

 State agencies send OCSE the names of the eligible 

noncustodial parents and the amount owed and OCSE transmits this 

information to FMS. FMS adds this information to its debtor file that 

includes information on those who owe child support as well as those who 

owe other federal debts.7

 IRS processes the tax returns, and then forwards 

information to FMS on those individuals who are due refunds. FMS 

compares this information to its debtor file and, if there is a match, offsets 

the refund by the amount of child support owed. After the refunds have 

been offset, FMS notifies the individual, and transfers the offset funds and 

 5

Omnibus Budget Reconciliation Act of 1981, Pub. L. No. 97-35, § 2331 (Aug. 13, 1981). 

6

IRS Form 8379. 

7

The Treasury Offset Program (TOP) is a centralized debt collection program developed by 

FMS. TOP is designed to assist agencies in the collection of delinquent debt owed to the 

federal government. FMS disburses payments on behalf of over 400 federal agencies. 
Page 7 GAO-04-377 Child Support Enforcement 

information to OCSE. OCSE then distributes the funds and information to 

the appropriate state agency. 

When a noncustodial spouse has filed a joint tax return, FMS may offset 

the refund if either person owes child support. FMS, acting on behalf of 

the Secretary of the Treasury, must notify OCSE, which notifies the state 

agencies when the withholding is being made from a refund based on a 

joint return, and provides the names and addresses of each taxpayer. 

Under these circumstances, the state agency is permitted to delay 

distribution of the amount withheld until the Secretary of the Treasury 

notifies the state agency that the spouse has received his or her proper 

share of the refund. This delay may not exceed 6 months. However, the 

law allows a spouse 6 years to file an “injured spouse” claim. If the spouse 

files a timely “injured spouse” claim and is found to be entitled to a portion 

of the withheld amount, IRS will process the claim and allocate the 

appropriate amount to each person. If the spouse’s claim is filed after the 

funds have been forwarded to the state agency, and the spouse is found to 

be entitled to a portion of the withheld amount, FMS sends the spouse his 

or her portion and the state agencies must reimburse the Treasury. OCSE 

data shows that from March to August 2003, almost $200 million dollars 

were collected from offsets of non-TANF joint tax refunds. 

PRWORA amended portions of the Social Security Act, including some 

provisions that pertained to child support enforcement. One provision 

required state agencies to establish a state disbursement unit to centralize 

collection and disbursement of child support payments in order to receive 

federal funds.8

 In addition to distributing collections from noncustodial 

parents to custodial parents, state agencies also distribute collections to 

 8

State disbursement units are also responsible for collecting and disbursing all payments 

under support orders, including spousal support. 
Page 8 GAO-04-377 Child Support Enforcement 

other government programs such as TANF9 and Foster Care programs10 as 

reimbursement for benefits provided to families. For example, as a 

condition of receiving temporary cash assistance, parents must apply for 

child support enforcement services and agree to give all or a portion of 

their child support to the state. In fiscal year 2002, OCSE reported that 

custodial parents who were receiving public assistance comprised about 

three million cases, and those who formerly received public assistance 

comprised about seven million cases. 

State agencies are required to report collection and distribution 

information quarterly to OCSE through the Quarterly Report of 

Collections, Form OCSE-34A. On the form, net undistributed collections 

equal the total amount of undistributed collections, less those considered 

undistributable or abandoned property according to state laws. 

OCSE has reported millions in undistributed collections from fiscal year 

1999 to 2002, but the amounts may not be accurate. State agencies had 

different interpretations of what comprised undistributed collections and 

some state agencies reported data that were found to be unreliable 

throughout this time period. Although OCSE revised the reporting form for 

fiscal year 2004, which should improve consistency in the types of 

collections reported as undistributed, data accuracy remains a concern. 

OCSE does not audit or periodically review undistributed collections data 

as it does other performance and financial data. 

Although OCSE reported that the amount of undistributed collections for 

fiscal year 1999 was $545 million and $657 million for fiscal year 2002, 

OCSE also reported and our survey results indicated that state agencies 

 9

The 1996 Personal Responsibility and Work Opportunity Reconciliation Act created TANF. 

TANF emphasizes the importance of work and personal responsibility rather than 

dependence on government benefits. After 2 years of assistance, or sooner if the state 

determines that the recipient is ready, TANF adults are generally required to be engaged in 

work or work-related activities. A lifetime limit of 60 months (or less, at the state’s option) 

is placed on adults’ receipt of cash benefits. Families receiving TANF benefits or benefits 

under the federally assisted foster care program or the Medicaid program automatically 

receive CSE services free of charge. Under PRWORA, TANF recipients generally must 

assign their rights to current child support payments to the state. 

10Foster care programs are authorized under Title IV-E of the Social Security Act. 

OCSE Reported 

Millions in 

Undistributed 

Collections, but Data 

Were Unreliable 

Types of Collections 

Reported as Undistributed 

Differed 
Page 9 GAO-04-377 Child Support Enforcement 

varied in the types of collections they reported as undistributed. In its 

preliminary annual report for fiscal year 2002, OCSE acknowledged that 

interpretation of the data on undistributed collections was limited due to 

the variation in the types of collections included.11 This report indicated 

that some state agencies included collections to be distributed within 

2 business days; collections received before they were due; and collections 

to be distributed to other government programs, while other state agencies 

did not. In our survey, we asked state agencies if they included these types 

of collections as well as collections to be distributed pending legal 

resolution and collections received from intercepting joint tax refunds. Of 

the 48 state agencies that responded, nearly all indicated that they 

included collections received before they were due to the custodial parent, 

collections pending legal resolution, and collections received from joint 

tax refunds. Thirty of the state agencies responded that they included 

collections to be distributed in 2 business days and 28 state agencies 

included collections to be distributed to other government programs. 

Figure 1 illustrates the state responses. 

 11OCSE’s final annual statistical report for fiscal year 2002 was published November 2003. 
Page 10 GAO-04-377 Child Support Enforcement 

Figure 1: Types of Collections and Number of State Agencies That Included Them 

in Undistributed Collections Reported to OCSE 

OCSE has taken steps to improve data consistency. OCSE revised its 

34A form and related instructions in fiscal year 2003 to improve the 

consistency of undistributed collections data. According to OCSE officials, 

this change was also made to provide more information about the 

composition of undistributed collections. Prior to the changes, all 

collections were reported under one category, and it was not possible to 

distinguish between collections pending distribution and collections 

requiring further research in order to distribute them. 

As of fiscal year 2004, state agencies are required to report total 

collections under two categories. The first category, “undistributed 

collections pending distribution,” includes collections that state agencies 

reasonably expect to distribute through typical business processing in the 

future. For example, collections held because of a legal dispute over the 

amount of support owed will be distributed as soon as the matter is 

Number of state agencies

0

5

10

15

20

25

30

35

40

45

50

Did not include type of collection

Included type of collection

Received from

joint tax refunds

Pending legal

resolution

Received before

due date

To be distributed in

2 business days

To be distributed to

other government

programs

Source: GAO survey.

44 44 43

30 28

4 4 5

18 20
Page 11 GAO-04-377 Child Support Enforcement 

resolved. The second category, “undistributed collections unresolved,” 

includes collections that require the child support staff to obtain more 

information before they can be distributed. These include but are not 

limited to collections (1) lacking information to match them to a case, 

(2) missing current addresses for a parent, and (3) from checks that were 

issued but the time frame for which to cash them had expired. According 

to OCSE officials, another new reporting form has been developed for use 

beginning in fiscal year 2005 that will require state agencies to report 

amounts for 10 types of undistributed collections included under the two 

categories. These officials informed us that the form is subject to review 

and approval by the Office of Management and Budget. Table 2 

summarizes the two categories and the 10 types of collections to be 

reported as undistributed collections. 

Table 2: Categories and Types of Collections to Be Reported as Undistributed 

Undistributed collections pending distribution Undistributed collections unresolved 

Collections that were received within the past 2 business 

days following receipt, and pending distribution within 

federal timelines. 

Unidentified collections. 

Collections being held for up to 6 months that were offset 

from non-TANF joint tax refunds. 

Collections pending the location of the custodial or noncustodial 

parent. 

Collections received before they were due. Collections initially disbursed by check that remain uncashed and 

considered stale-dated and non-negotiable in accordance with state 

law and procedures. 

Collections held pending resolution of legal disputes and 

any timely appeal (Examples include contested paternity 

 or dispute over the balance of support owed.) 

Collections with inaccurate or missing information. (Examples include 

but are not limited to collections received that do not correspond to 

the amount owed or collections received for accounts that have been 

closed or have not yet been opened.) 

Collections processed but not yet distributed to other state 

 or federal agencies administering programs such as TANF. 

Other collections remaining undistributed. 

Source: Form OCSE-34A. 

In addition to differences in the types of undistributed collections that 

state agencies reported, 4 state agencies reported data accuracy problems 

in 2002 and 2003 that were found to be overestimates. The cumulative 

amounts of these undistributed collections ranged from about $5 million 

to $168 million and, according to state officials, the actual amounts of 

undistributed collections were lower than reported. The state agencies 

and the amounts of the overestimates are summarized in table 3. 

Some State Agencies 

Reported Inaccurate 

Amounts of Undistributed 

Collections 
Page 12 GAO-04-377 Child Support Enforcement 

Table 3: Overestimates of Undistributed Collections and Year Reported 

State agency Amount of overestimate Year reported

California $168,000,000a 2003

Michigan $25,000,000 2002

Missouri $5,000,000 2002

Nebraska $5,300,000 2003

Source: State agencies and GAO analysis. 

Note: Not all state agencies could provide information needed to determine the exact time period 

associated with these overestimates. 

a OCSE officials reported that this amount was recalculated to be about $163 million and noted that 

this claim as well as similar claims from other state agencies are subject to federal review. 

Most of the errors were accounting mistakes discovered by the state 

agencies. Officials from the California Department of Child Support 

Services reviewed the state’s accounting of undistributed collections and 

found that some local officials had included collections in their totals 

multiple times because they had misinterpreted a policy. They thought that 

disbursements could only be reported if collections were also reported in 

the same period and, as a result, when they disbursed funds they again 

added these collections into their totals. This resulted in overstating 

amounts for total collections and for undistributed collections. Nebraska’s 

overestimate occurred partly because collections received before they 

were due for non-TANF cases were immediately distributed, but the 

officials did not show them as being distributed until the official due date. 

In Missouri, nearly all of the overestimate was spousal support collected 

by the state disbursement unit that was erroneously reported as child 

support collections. For the remainder, in Missouri, when a collection 

from a joint tax refund had been distributed to a custodial parent and the 

amount was later adjusted in the same reporting quarter because of an 

“injured spouse” claim, the adjusted amount was added as a new 

collection. An audit of Michigan’s child support program revealed that it 

failed to account for the distribution of payments that noncustodial 

parents paid directly to custodial parents. 

The reports related to these overestimates also indicated that having 

multiple jurisdictions involved with recording collections contributed to 

the errors. Local agencies in California used forms that did not always 

include the federal data elements used by the state agency to report 

undistributed collections. Nebraska discovered errors when its state 

disbursement unit took over the collection and distribution process from 

clerks at multiple courts. 
Page 13 GAO-04-377 Child Support Enforcement 

While OCSE is required to audit some child support data, it does not have 

a process to ensure the accuracy of data on undistributed collections. 

OCSE is required to audit the reliability of the performance indicators 

used as the basis for paying financial incentives to state agencies.12

Officials told us they are conducting these audits annually. To ensure the 

reliability of the data, OCSE selects representative sample cases for a 

detailed audit and reviews supporting documentation to check for errors. 

OCSE is also required to conduct financial audits to determine whether 

federal and other funds used to administer the program are being 

appropriately expended and properly accounted for. These audits are 

required to include an examination of collections and disbursements of 

child support payments for proper processing and accounting treatment. 

Although OCSE’s general instructions for the collection of data used for its 

annual report reminds state agencies that they should report reliable and 

complete information, OCSE officials told us they have only reviewed data 

on undistributed collections in special circumstances. For example, the 

Department of Health and Human Services and OCSE conducted at least 

three special reviews of California’s undistributed collections data since 

fiscal year 1994 that revealed problems with the accuracy and reliability of 

the data. According to OCSE officials, the agency does not have the 

resources to routinely review data on undistributed collections in the way 

it reviews other program data. 

Reviews of undistributed collections data do not have to be done the same 

way other program data are reviewed. To minimize the impact on OCSE’s 

resources, the reviews of the undistributed collections data could be done 

in conjunction with one of the other routine audits and could be limited to 

a portion of the state agencies on a rotational basis, for example, one third 

of the states each year. Without more accurate data on undistributed 

collections, OCSE cannot be certain about the amount of collections that 

are not being distributed to families in a timely manner. Further, without 

accurate data, OCSE cannot determine whether undistributed collections 

are more problematic for certain state agencies than for others. 

 1242 U.S.C. § 652(a)(4)(C). Moreover, the Child Support Performance and Incentive Act of 

1998 requires that states have complete and reliable data for purposes of computing 

incentives. 42 U.S.C. § 658a(b)(5)(B). The performance measures for incentive payment 

base amounts are paternity establishment, support order establishment, current payments 

distributed, and cost effectiveness. 42 U.S.C. § 658a(b)(4). According to HHS, the Secretary 

is required to conduct an audit for each fiscal year for incentive purposes. 

OCSE Did Not Hold State 

Agencies Accountable for 

Accurately Reporting 

Undistributed Collections 
Page 14 GAO-04-377 Child Support Enforcement 

The underlying causes for nearly all undistributed collections were federal 

law, state policies, as well as inaccurate or missing information. Federal 

law allowed state agencies to hold collections from joint tax refunds and 

state agencies set polices that guided how long these refunds and other 

collections were held. Invalid addresses for custodial parents or missing 

case information also contributed to undistributed collections. For 

example, information needed to determine the correct amount of the 

collection to be distributed to families who are or were receiving public 

assistance was sometimes inaccurate or missing, and delayed distribution 

of these collections. Our analysis of state agency survey data found that 

many state agencies reported holding more that $1 million from joint tax 

refunds and several hundred thousand in other types of collections. 

Federal law and policies in some state agencies contributed to certain 

collections being counted as undistributed. While state agencies are 

generally required to distribute collections in 2 days, federal law allows 

state agencies to hold collections from joint tax refunds for up to 180 days. 

Our survey results revealed that the majority of state agencies held 

collections intercepted from joint tax refunds for 180 days and a few 

distributed them in 1 to 2 days. Table 4 summarizes this survey data. 

Federal Law, Some 

State Policies, and 

Inaccurate, or Missing 

Information Delayed 

or Prevented 

Distribution of 

Certain Collections 

Federal Law and State 

Policies Determined How 

Long Certain Collections 

Were Held 
Page 15 GAO-04-377 Child Support Enforcement 

Table 4: Time Period Collections from Joint Tax Refunds Are Held 

Number of state agencies Number of days collections are held

4 1-2

2 23-30

2 60a

4 99-170

34 180b

Source: GAO survey. 

Note: Two state agencies did not answer this question. 

a

One state indicated that it distributed these collections 60 days after the end of the month it received 

them. 

b

We converted the responses that were 6 months to 180 days. One state reported that it distributed 

collections from tax refunds within 1 day following the 180-day hold and another state indicated 

2 days, following the 180-day hold. 

In addition, state agencies had policies on whether or not they held child 

support collections received before they were due.13 Depending on how 

early collections are received, they may be held for several months and 

counted as undistributed collections during that time. Twenty-one state 

agencies reported that they immediately distributed collections that were 

received before they were due for non-TANF cases and 20 state agencies 

reported that they held these collections until they were due. Seven state 

agencies had other policies. For example, 1 state agency reported that it 

authorized its case managers to distribute the collections based on the 

preferences of the custodial parent and another state reported it would 

hold as much as 1 month of support received before it was due and refund 

the remaining amount to the noncustodial parent. 

State policies regarding how long undistributed collections are held before 

they are declared abandoned affects reported amounts of undistributed 

collections. Eleven state agencies reported that their policies require 

undistributed collections to be declared abandoned property after 1 year, 

while 1 state indicated its policy was to hold collections for up to 7 years. 

Eleven state agencies did not specify a number of years after which 

undistributed collections were declared abandoned property. Figure 5 

shows the range of times reported by 44 state agencies. 

 13These collections are also referred to as future payments. 
Page 16 GAO-04-377 Child Support Enforcement 

Figure 2: Number of Years State Agencies Reported Holding Collections before 

Declaring Them Abandoned Property 

Notes: Three state agencies did not report whether or not they specified number of years. One state 

agency reported that it specified a number of years after which undistributed collections are 

reclassified as abandoned property, but did not indicate how many years. 

Some undistributed collections were the result of invalid addresses for 

custodial parents or missing information. State officials told us that 

custodial parents often moved without informing the child support agency 

of their new address and that the U.S. Postal Service did not forward 

collections to new addresses, but rather returned them to the child 

support enforcement agency. According to state officials, noncustodial 

parents did not always include identifying information on their payments. 

For example, state officials said they sometimes received money orders 

from noncustodial parents that were illegible or lacked information, such 

as the case number or full name, needed to match them to the right case. 

Missing or inaccurate information on TANF or former TANF cases 

contributed to undistributed collections. Officials from 2 state agencies we 

visited explained that some collections could not be distributed to the 

custodial parent until they determined the correct amount owed to the 

Inaccurate or Missing 

Information Contributed to 

Undistributed Collections 

Number of state agencies

0

2

4

6

8

10

12

1 year

2 years

3 years

5 years

7 years

11

5

8 8

1

11

Source: GAO survey.

No specified

number of years
Page 17 GAO-04-377 Child Support Enforcement 

government. According to Florida officials, this contributed to nearly 

50 percent of its approximate $28 million in undistributed collections. The 

state cited two major reasons for this problem: (1) data inaccuracies due 

to the conversion of cases from the former statewide system to the state 

agency’s new automated system and (2) difficulties exchanging 

information between the automated systems of the child support agency 

processing the payments and the TANF agency. A 2001 report issued by 

the Department of Health and Human Services’ Office of Inspector General 

found that 11 state agencies experienced difficulties in distributing child 

support to families leaving TANF.14 Among the reasons state agencies cited 

were problems exchanging information with TANF agencies and 

inaccurate addresses for custodial parents receiving TANF benefits. The 

report also noted that 28 of 51 state agencies surveyed reported problems 

with the automated exchanges of information between the child support 

enforcement and the TANF agencies. These problems included 

incompatible design of state TANF and child support enforcement 

agencies’ automated systems and timing of information exchanges, which, 

according to the report, could have caused child support payment delays 

and underpayments after clients left the TANF program. 

State officials also said that missing information from employers as well as 

inaccurate payments contributed to the amount of undistributed 

collections. For example, according to state officials, employers, including 

some federal agencies, did not always identify the cases for which the 

withheld wages were designated or mailed one check for multiple cases 

with the sum of the withheld wages not matching the total amount of the 

check.15 Additionally, some employers sent payments for more than was 

due. In its examination of undistributed collections, a report from a private 

firm indicated that in New York City, 40 percent of undistributed 

collections were from payments that were not due. In some instances 

employers sent inaccurate payments because the state agencies had not 

notified them that the amount to be withheld had changed. Such changes 

would be needed in cases such as those in which previously owed child 

support had been paid and only current support was to be withheld, or if 

 14Distributing Collected Child Support to Families Exiting TANF. Department of Health 

and Human Services, October 2001. OEI-05-01-00220. 

15Wage withholding is a procedure whereby an employer automatically deducts a specified 

amount from an employee’s wages or income to pay a child support obligation. All support 

orders issued after January 1, 1994, must contain provisions for wage withholding, except 

when there is a good cause not to require it or an alternative arrangement is reached by 

both parties. 
Page 18 GAO-04-377 Child Support Enforcement 

the child had reached the age at which child support payments terminated. 

Officials from 1 state agency we visited, told us that they waited to notify 

employers about changes in the amount to be withheld until overpayments had been collected. In other cases, officials told us that 

employers sent inaccurate payments because they did not always correctly 

calculate the amount to be withheld. For example, if a child support order 

stipulated that $100 was to be paid each month and $50 were deducted in 

each of 26 biweekly pay periods, at the end of the year, the noncustodial 

parent would have paid $1,300 instead of the $1,200 that was owed. 

Depending on the state’s policy, this $100 overpayment could be returned 

to the noncustodial parent, distributed to the custodial parent before it 

was due, or held until it was due. 

In response to our survey, 32 state agencies provided dollar amounts for 

undistributed collections from joint tax refunds. The median value 

reported for these collections was $1.8 million. Of these 32 state agencies, 

19 reported an amount of $1 million dollars or higher with 3 reporting 

amounts greater than $10 million dollars. In 15 state agencies this was the 

largest amount reported for any of the nine types of undistributed 

collections we listed on the survey. For the 9 state agencies that provided 

values for all nine types, we determined that undistributed collections 

from joint tax refunds ranged from 27 to 48 percent of total undistributed 

collections. Our survey requested data as of June 2003, and OCSE officials 

explained that the amount of undistributed collections from joint tax 

refunds is generally higher in March through September. 

Many officials cited the potential financial loss as the primary reason they 

are unwilling to assume the risk of releasing these collections before 180 

days. State agencies are fully responsible for payments made in error and 

must either attempt to recover money that has been distributed to 

custodial parents or suffer the financial loss that comes from reimbursing 

the Treasury for the “injured spouse” claims. One state agency we visited, 

Texas, reduced the time it held collections from joint tax refunds from 

120 days to 90 days after analysis of its data showed that the benefit of 

distributing these collections outweighed the financial risk of holding 

them. 

While high values were consistently reported for undistributed collections 

from joint tax refunds, our analysis also revealed that the median value of 

four other types of undistributed collections that state agencies reported 

exceeded $350,000. These undistributed collections included those 

received before they were due, pending legal resolution, with an invalid 

Many State Agencies 

Reported Holding More 

than $1 Million from Joint 

Tax Refunds and Several 

Hundred Thousand Dollars 

in Other Types of 

Undistributed Collections 
Page 19 GAO-04-377 Child Support Enforcement 

address for custodial parents, and with data problems. Table 5 illustrates 

the median amounts and ranges reported for the nine types included in our 

survey as well as the number of state agencies that reported an amount. 

Table 5: Amounts for Nine Types of Undistributed Collections Reported by State Agencies as of June 30, 2003 

Source: GAO survey. 

Note: The types of undistributed collections are slightly different from the types OCSE uses because 

we administered our survey before the 34A form was officially revised. 

State agencies we visited took various steps to better understand and 

resolve undistributed collections. They devoted resources to analyzing 

their undistributed collections to help identify the specific causes. 

Additionally, 4 state agencies we visited established specific performance 

goals and all state agencies we visited emphasized regular monitoring of 

undistributed collections. State agencies also implemented processes to 

resolve cases with missing information and used electronic processes that 

helped to reduce the number of collections with invalid addresses for 

custodial parents and unidentified collections. 

To help reduce their undistributed collections, officials from 5 of 6 state 

agencies we visited stated that they devoted resources to better 

understanding these collections. Beginning in 2000, California assembled a 

team from various units within the state child support enforcement 

Types of undistributed collections 

Median amount 

(rounded)

Minimum 

amount 

Maximum 

amount (in 

millions)

Number of 

state agencies 

that reported 

an amount

Collections from joint tax refunds $1,750,000 0 $13.9 32

Collections received before they were due $466,000 0 $8.0 33

Collections pending legal resolution $431,000 $9,700 $10.2 24

Collections with an invalid address for custodial parents $399,000 $1,300 $5.2 35

Collections with data problems (overpayments, no active 

case, missing or inaccurate data, etc.) $363,000 0 $14.2 30

Collections sent to custodial parents that can no longer be 

cashed $125,000 0 $5.8 19

Collections lacking sufficient information to identify them $94,000 $1,100 $4.5 35

Collections to be distributed in 2 business days $65,000 0 $4.7 26

Collections to be distributed to other government programs $6,200 0 $3.7 20

State Agencies Took 

Steps to Reduce 

Undistributed 

Collections 

State Agencies Analyzed 

and Monitored 

Undistributed Collections 
Page 20 GAO-04-377 Child Support Enforcement 

agency, such as the fiscal and information technology units, to analyze 

their undistributed collections. The initiative lasted 3 years and included 

the design and implementation of a new collections and distribution 

reporting system, verification of the amount and sources of undistributed 

collections, and publication of a report in June 2003. Another state agency, 

New York, awarded a yearlong, million dollar contract to a private firm to 

analyze its undistributed collections. The contractor developed a sampling 

plan and reviewed thousands of undistributed collections to determine 

their sources and how long the money had been held. In addition, the 

contractor evaluated technological solutions and identified general 

strategies for reducing the largest types of undistributed collections. 

Officials from 4 state agencies we visited emphasized that in order to 

reduce undistributed collections, it is necessary to establish performance 

goals and measures and compare program results with those goals. Four 

of the state agencies we visited established performance goals and 

measures to help them monitor undistributed collections. Florida 

established a series of performance accountability measures, including 

resolution of collections requiring additional research and timeliness of 

disbursements, to track the overall operation of its disbursement unit. 

Virginia established its goal for undistributed collections at 3 percent of 

monthly collections and was considering lowering that baseline to 

2 percent as well as maintaining less than $50,000 in unidentified 

collections. An objective in California’s strategic plan is to ensure that no 

more than 1 percent of collections due families remain undistributed at 

any time. Texas established benchmark amounts for each type of 

undistributed collections. 

Officials from all of the state agencies we visited highlighted the 

importance of monitoring undistributed collections to ensure that goals 

are being met. Three of the state agencies we visited had detailed 

automated reports to help them monitor undistributed collections. These 

reports varied from state to state, but the examples provided included data 

on the total dollar value of undistributed collections, number of cases, 

number of collections, and dates collections were received. Also, several 

state agencies produced data reports for each field or local office. For 

example, a monthly management report in Virginia enabled the state 

officials to monitor the performance of its 22 district offices. According to 

our survey, nearly all state agencies indicated that they routinely produced 
Page 21 GAO-04-377 Child Support Enforcement 

statistical data on undistributed collections. For example, 27 state 

agencies produced daily reports and 12 produced weekly reports.16

State agencies we visited dedicated staff and focused resources on 

resolving cases with missing information and invalid addresses. Some 

state agencies used automated methods to receive and transmit 

collections. Additionally, 1 state agency automated two processes that 

helped reduce its undistributed collections. 

Officials from all of the state agencies we visited highlighted the 

importance of dedicating staff to researching collections involving missing 

information. In Virginia, the state disbursement unit separated collections 

with missing information, such as a social security or case number, from 

those with this information. The team contacted employers, courts, or 

other state agencies to obtain the needed information. A database of the 

most difficult collections along with contact information and instructions 

was maintained in order to reduce processing time on similar collections 

received in the future. The team typically resolved unidentified collections 

within 72 hours. Other state disbursement units we visited also had 

specific staff dedicated to researching payments with missing information 

in order to distribute them as soon as possible. 

State agencies also focused resources on resolving cases with invalid 

addresses for custodial parents. State officials cited the importance of 

allowing staff to access federal, state, and private databases to locate 

custodial parents. Officials in 1 state said they had a contract with a 

private vendor because they found this information to be most useful. 

Virginia’s system automatically searched databases to match cases that 

needed information. Such databases included FPLS,17 state licensing 

agencies, and credit bureaus. In Texas, an indicator was added to case 

records to allow field workers to automatically refer cases with invalid 

addresses to special enforcement investigators. In addition, a new report 

 16Three of the 27 state agencies that reported producing daily reports also reported that 

they produced weekly reports. 

17FPLS is a computerized national location network operated by OCSE. FPLS obtains 

address and employer information, as well as data on child support cases in every state, 

compares them and returns matches to the appropriate states. This helps child support 

enforcement agencies locate noncustodial parents. 

State Agencies Took Steps 

to Address Missing 

Information and Improve 

Payment Processes 

Resolving Missing Information 

and Invalid Addresses 
Page 22 GAO-04-377 Child Support Enforcement 

was created to show all cases with collections held due to missing 

addresses so that field staff could focus their efforts on these cases. This 

change resulted in the distribution of almost $1 million in the first 

4 months of implementation. Also, state officials from the 4 state 

disbursement units we visited told us that customer service 

representatives routinely verified addresses when contacted by custodial 

or noncustodial parents. 

Officials from 4 of the 6 state agencies we visited encouraged employers to 

use Electronic Funds Transfer (EFT) when transmitting collections to the 

state disbursement unit as a way to improve efficiency and reduce 

undistributed collections. According to OCSE officials and a 

representative from the American Payroll Association, converting to 

electronic payments for child support means having to purchase software 

or make programming changes to payroll systems, which can initially be 

costly. As an alternative to EFT, 5 state agencies, including 1 we visited, 

Florida, developed a process to allow employers to send payments to the 

state disbursement unit over the Internet. A state agency’s Web based 

payment service operates much like other online banking services in that 

an employer registers for the service, receives a user identification and 

password and can then access the Web site each pay period to make the 

payments for each of its employees. State agencies generally offered these 

services free of charge to employers. 

State agencies also provided alternative ways for noncustodial parents to 

transmit their payments. Florida offered noncustodial parents the option 

of paying their support over the Internet. Texas had a pilot project with a 

grocery chain to allow noncustodial parents to pay their child support at 

their stores, and then the stores would transmit the payment to the state 

disbursement unit electronically. In another pilot project, New York 

partnered with a private vendor that sells money orders. Noncustodial 

parents could provide the payment to the vendor who would then transmit 

the payment electronically to the state disbursement unit. 

In addition to receiving collections electronically, many state agencies 

distributed collections to parents electronically. Thirty-seven state 

agencies that responded to our survey indicated they offered direct 

deposit—a process whereby money is directly transferred to a checking or 

savings account—and 9 reported that they issued a state debit card. 

Officials from all the state agencies we visited explained that direct 

deposit is not an option for many of their customers because they do not 

have bank accounts. For anyone without a bank account, a state debit 

card is an alternative. The card may be used to purchase goods or services 

Using Automated Processes
Page 23 GAO-04-377 Child Support Enforcement 

as well as to obtain cash. Safeguards have been included that prevent 

custodial parents from withdrawing cash or making purchases that would 

cause an overdraft of the available child support funds. In response to our 

survey, most state agencies indicated that they send 40 percent or fewer of 

their collections to parents electronically. Figure 6 shows the portion of 

collections that state agencies reported distributing to parents 

electronically. 

Figure 3: Portion of Collections Distributed to Parents Electronically 

While most state agencies offered at least one form of electronic 

distribution to parents, in 2003, Iowa began requiring all parents to receive 

collections electronically. Exceptions to this requirement were based on 

individual circumstances.18 Officials told us that as of January 2004, about 

95 percent of custodial parents in Iowa were receiving collections 

electronically. 

Automated processes to receive and distributed collections can help 

reduce undistributed collections. According to state agency officials, 

 18Officials told us that some exceptions were granted to individuals, for example, if they 

could not reasonably access a financial institution. 

Number of state agencies

0

2

4

6

8

10

12

14

16

18

0 1-20 21-40 41-60 61-80 81-98

Percent

8

17

15

3

1

4

Source: GAO survey.

0

99-100
Page 24 GAO-04-377 Child Support Enforcement 

methods that allow state agencies to receive collections electronically can 

help reduce undistributed collections due to fewer incorrect or 

unidentified collections. Electronic methods for distributing collections to 

families can also reduce the number of undistributed collections. With 

direct deposit and state debit cards, funds are transferred from the state 

directly to a financial institution and even if the custodial parent changes 

addresses, the collections can continue to be deposited. As such, by using 

direct deposit and state debit cards, undistributed collections due to 

invalid addresses of the custodial parents and those due to paper checks 

that can no longer be cashed are reduced. 

In addition to reducing undistributed collections, officials from 2 state 

agencies told us that electronic distribution to parents reduces many 

processing costs and requires limited manual intervention. Iowa officials 

predicted a combined savings to the state and federal government of about 

$35,000 a month by sending collections to parents electronically. Officials 

in Texas reported a cost savings of $1.34 per transaction by using direct 

deposit versus mailing a check, a savings of over $300,000 in a typical 

month. 

Additionally, Texas automated two of its child support processes that will 

help prevent undistributed collections. In 2000, Texas established an 

automated mechanism to issue refunds to noncustodial parents for 

collections that exceeded the amount owed. Previously, manual 

intervention was required to release these collections. According to 

officials, this program saved hundreds of hours of staff time and enabled 

them to quickly process refunds. Also in 2000, Texas developed an 

automated process to issue new wage withholding orders to employers 

when circumstances of cases changed, such as a reduction in the amount 

owed. In the first 60 days after implementation, Texas issued over 15,000 

new orders to employers. 

Many state agencies reported earning interest and program income. OCSE 

issued a memorandum in 1989 that encouraged state agencies to deposit 

all child support collections in interest-bearing accounts. According to our 

survey, 32 state agencies reported that they kept all undistributed 

collections in interest-bearing accounts, 4 state agencies reported keeping 

some undistributed collections in interest-bearing accounts and 11 state 

agencies reported that they did not keep their collections in these 

accounts. One state agency did not answer the question. State agencies are 

required to deduct interest earned and income from program costs and 

can charge fees to help recover some of their administrative costs. For 

example, state agencies are required to charge non-TANF families an 

State Agencies Reported 

Earning Interest and 

Income 
Page 25 GAO-04-377 Child Support Enforcement 

application fee, and can charge fees for tax refund offsets and various 

services and expenses such as case maintenance fees, or a fee to establish 

a support order. Our prior reports concluded that most states either did 

not charge fees or charged minimal fees.19 For fiscal year 2002, state 

agencies reported earning almost $50 million in interest and income. The 

amounts reported ranged from $0 to $15 million. 

OCSE has provided some assistance to help state agencies reduce their 

undistributed collections. OCSE focused attention on reducing 

undistributed collections, shared best practices, and funded projects. 

However, OCSE does not have information on some “injured spouse” 

claims that could reduce the amount of time collections from some joint 

tax refunds are held. 

In fiscal years 2002 and 2003, OCSE focused on reducing undistributed 

collections. In its fiscal year 2002 annual report, OCSE stated that it was 

taking actions to understand the composition of undistributed collections 

and identify efforts state agencies could take to distribute more collections 

to families. Additionally, OCSE emphasized that improved customer 

service by state agencies helps reduce undistributed collections. 

According to state officials, customer service representatives are 

 19U.S. General Accounting Office, Child Support Enforcement: Opportunity to Defray 

Burgeoning Federal and State Non-AFDC Costs, GAO/HRD-92-91 (Washington, D.C.: June 

5, 1992); Child Support Enforcement: Opportunity to Reduce Federal and State Costs,

GAO/T-HEHS-95-181 (Washington, D.C.: June 13, 1995); and Child Support Enforcement: 

Clear Guidance Would Help Ensure Proper Access to Information and Use of Wage 

Withholding by Private Firms, GAO-02-349 (Washington, D.C.; Mar. 26, 2002). 

OCSE Has Assisted 

States’ Efforts to 

Reduce Undistributed 

Collections, but the 

Department of the 

Treasury Has Not 

Provided Information 

That Would Help 

States Distribute 

Collections from 

Some Joint Tax 

Refunds Sooner 

OCSE Provided Some 

Assistance to State 

Agencies 
Page 26 GAO-04-377 Child Support Enforcement 

encouraged to ask for updated information from parents, thereby reducing 

the number of cases with incorrect addresses. In fiscal year 2003, OCSE 

partnered with the National Council of Child Support Directors to refine 

the categories of undistributed collections and obtain state data and best 

practices. Also, OCSE issued guidance in March 2003 to reduce the 

number of cases with invalid addresses. This guidance informed state 

agencies that they could access FPLS to locate custodial parents as well as 

to locate noncustodial parents. 

OCSE funded research and provided technical assistance to state agencies 

to help them reduce undistributed collections. Between fiscal years 2000 

and 2002, OCSE awarded three contracts. The first contract awarded in 

fiscal year 2000, for about $135,000, funded research to identify 

approaches for reducing undistributed collections in 11 state agencies 

with large caseloads or amounts of collections. In addition, this contractor 

reviewed undistributed collections in two New York counties and 

identified factors in their business processes and automated systems that 

prevented them from further reducing these collections. According to 

OCSE, a second contract was also awarded in fiscal year 2000 for about 

$112,000 that funded research focused on understanding the extent and 

causes of undistributed collections across state agencies and highlighting 

best practices for distributing such collections. Additionally, OCSE 

officials said that a third contract was awarded in fiscal year 2002 for 

about $300,000 that funded research to review undistributed collections in 

5 state agencies. 

Beginning in fiscal year 2000, OCSE made projects designed to reduce 

undistributed collections a priority for demonstration grants, and awarded 

five grants.20 In fiscal year 2000, OCSE awarded one grant for about 

$188,000, and in fiscal year 2002, OCSE awarded four grants—one each to 

Texas, and the District of Columbia and two to Indiana—for a total 

amount of about $500,000. The goals for each of the fiscal year 2002 

projects were different. For example, the goal for one project was to 

 20Section 1115 of the Social Security Act authorizes OCSE to provide funding to state Title 

IV-D agencies for demonstration activities intended to add to the knowledge and to 

promote the objectives of the Child Support Enforcement Program. The four priority areas 

for fiscal year 2002 were to (1) increase the rate of cases with collections through better 

use of automation and improved public-private collaboration projects for interstate cases, 

(2) increase the rate of cases with collections from low-income noncustodial parents, 

(3) reduce and limit the amount of undistributed collections by having states better track 

and distribute more of the undistributed child support that they have collected, and 

(4) further the national goals of the Child Support Program. 
Page 27 GAO-04-377 Child Support Enforcement 

evaluate the use of state debit cards as a way to reduce undistributed 

collections. 

Further, OCSE actively encouraged more use of EFT, which as previously 

stated can help reduce undistributed collections. In July 2003, the OCSE 

Commissioner sent a letter to 80 private sector employers that employ a 

large number of noncustodial parents encouraging them to use EFT to pay 

the child support they withheld from their employees’ wages. During 

several conferences sponsored by employer organizations, OCSE 

promoted electronic payment by distributing literature and making 

presentations. Additionally, in 2002 OCSE staff assisted the NACHA—

Electronic Payments Association’s Child Support Task Force by helping to 

identify issues associated with promoting the electronic collection and 

distribution of child support payments. OCSE also worked with several 

federal agencies on issues related to electronic payment. For example, 

OCSE worked with the Defense Finance and Accounting Service to 

encourage more use of electronic payments. 

OCSE shared information about initiatives state agencies took to reduce 

undistributed collections in its publications. Each month OCSE published 

its “Child Support Report” with information about various child support 

topics. Descriptions of successful state efforts related to undistributed 

collections were featured in several editions. OCSE also published an 

annual compendium of best practices in child support enforcement and 

several of the entries in its 2002 edition were related to undistributed 

collections. 

In addition to these publications, OCSE has discussed or arranged 

sessions on undistributed collections at conferences, forums, and training 

sessions. OCSE officials also reported that regional meetings have 

included sessions focused on reducing undistributed collections. For 

example, officials from Region VII organized a workshop where 

perspectives on reporting and best practices were addressed.21 In July 

2003, OCSE initiated monthly audio conference calls to foster discussions 

on implementing best practices such as electronic funds distribution. As of 

 21Region VII includes Iowa, Kansas, Missouri, and Nebraska. 
Page 28 GAO-04-377 Child Support Enforcement 

December 2003, OCSE had arranged five calls with a range of 25 to 

38 state agencies participating.22

As part of our survey, we asked state agencies how helpful various OCSE 

efforts related to undistributed collections have been. For the most part, 

state agencies reported that OCSE’s efforts have been helpful and many 

reported that discussions of best practices at forums were greatly or 

extremely helpful. However, several state agencies reported that OCSE’s 

efforts were hardly or not at all helpful. Table 6 summarizes the state 

agencies’ responses. 

Table 6: Summary of State Agencies’ Responses Regarding the Helpfulness of 

OCSE Efforts 

OCSE effort 

Hardly or not 

at all helpful

Somewhat or 

moderately 

helpful 

Greatly or 

extremely 

helpful

Have not 

participated 

in effort

Dissemination of 

best practices 5 31 9 2

In-person training 7 9 4 27

Discussion of 

best practices at 

forums 7 18 15 7

Policy documents 8 30 6 2

Source: GAO survey. 

Note: One state did not answer this question at all and 1 state did not provide a response about the 

helpfulness of the policy documents. 

OCSE and state agencies are not receiving information from the 

Department of the Treasury about approved “injured spouse” claims that 

are submitted at the time a tax return is filed. Such information is 

important because state agencies may delay disbursement of tax-offset 

collections for a period of up to 180 days to allow for the possibility of a 

reversal based on an “injured spouse” claim. IRS officials explained that 

while they do not know the type of debt owed when they process the 

claims, they have estimated that about 55,000 “injured spouse” claims 

related to the offset of non-TANF joint tax refunds for child support have 

 22OCSE told us that these discussions are recorded and available to state agencies that 

could not participate in the original call. 

The Department of the 

Treasury Has Not Provided 

OCSE Information on 

Collections from Some 

Joint Tax Refunds 
Page 29 GAO-04-377 Child Support Enforcement 

been filed with the tax returns each year.23 Additionally, these officials 

commented that when the claims were filed with tax returns and 

approved, the amount due the “injured spouse” was allocated before the 

file was sent to FMS. However, the information FMS sent to OCSE, which 

was then forwarded to the state agencies, did not identify these collections 

as having had their “injured spouse” claims satisfied. As our survey results 

show, most state agencies delayed distributing all collections from joint 

tax refunds. 

IRS officials explained that federal law and current processes have played 

a role in determining the information provided to OCSE on approved 

“injured spouse” claims. IRS officials stated that their disclosure statute24

allows, but does not require, them to provide OCSE and the states with 

information on specific tax offsets for payment of past due child support. 

The officials also explained that they include data on the payment file they 

send to FMS that could enable FMS to determine whether the “injured 

spouse” claim has been processed. Furthermore, the IRS officials said that 

it would be very costly to reprogram the IRS data systems to enable them 

to provide OCSE information on “injured spouse” claims. 

FMS officials we spoke with stated that until recently, they were not aware 

that OCSE needed notification on the payment of injured spouse claims25

and they expressed concern about the cost associated with changing their 

system in order to provide the information to OCSE. The FMS officials 

added that neither IRS nor OCSE emphasized the need for information on 

injured spouse claims when FMS became responsible for and set up their 

systems to support the tax-offset program. Furthermore, in order for FMS 

to send OCSE more information about injured spouse claims, they would 

 23About 182,500 injured spouse claims were filed related to offsets for child support and 

about 60 percent, 110,000, were filed with the original return. Approximately half of the 

claims are for non-TANF cases. 

2426 U.S.C. § 6103(l)(10). 

25Under the Social Security Act provision on collection of past-due support from federal tax 

refunds, a state “may delay distribution of the amount withheld until the State has been 

notified by the Secretary of the Treasury that the other person filing the joint return has 

received his or her proper share of the refund, but such delay may not exceed six months.” 

42 U.S.C. § 664(a)(3)(B). While this section of law does not explicitly require Treasury to 

affirmatively inform OCSE or the states that an injured spouse claim has been paid, we 

believe that the statute contemplates that Treasury notify the state when the other person 

filing the joint return has received his or her share of the refund. See H.R. Conf. Rep. No. 

98-925, at 56 (1984). 
Page 30 GAO-04-377 Child Support Enforcement 

have to reprogram their data files and change at least two data systems. 

They also stated that it would take at least 3 years to modify the systems 

and would be very costly. FMS officials suggested that the more costeffective solution would be for IRS to send OCSE the requested 

information 

Although the offset program has been operating for almost 20 years, 

OCSE’s efforts to obtain the information on “injured spouse” claims from 

the Department of the Treasury began in late 2001. According to OCSE 

officials, they have discussed the need for additional information with 

officials from the Department of the Treasury on several occasions. 

Further, in February 2003, OCSE’s Commissioner sent a letter to the 

Department of the Treasury requesting that the two agencies involved in 

the Tax Offset Program, IRS and FMS, provide information that identifies 

which joint tax refunds involve “injured spouse” claims. FMS and IRS 

formed a work group to investigate ways to shorten the process related to 

satisfying these claims. However, according to an FMS official, there has 

been little movement in response to OCSE’s letter and as of January 2004, 

the Department of the Treasury had not responded to OCSE’s letter. If the 

Department of the Treasury provided OCSE and state agencies with 

information on the satisfied “injured spouse” claims filed with the initial 

tax returns, state agencies could immediately release the offset collections 

to the families. 

Receipt of child support is critical for many custodial parents and their 

children. However, no one is certain about the amount of child support 

collections that are not distributed to families on time, if at all. By revising 

the quarterly collections form, OCSE has taken the first step to improving 

data about undistributed collections, but more reliable data are needed in 

order for OCSE and the state agencies to know more about undistributed 

child support collections and to be able to take appropriate actions to help 

reduce them. 

While the total amount of undistributed child support collections is 

uncertain, it is clear that millions of dollars being held for months are 

collections from joint tax refunds. State agencies need more information 

about those “injured spouse” claims that are filed with the tax returns and 

approved. As the federal partner and overseer of this program, it is 

OCSE’s role to work with other federal agencies, such as the Department 

of the Treasury, to remove barriers that hinder fulfilling its mission. 

Furthermore, since collections held from joint tax refunds represent a 

large amount of state agencies’ total undistributed collections, it is in the 

Conclusion 
Page 31 GAO-04-377 Child Support Enforcement 

best interest of the child support program for OCSE to focus more 

attention on getting this information. Additionally, the Secretary of the 

Treasury needs to provide OCSE and state agencies information about 

satisfied “injured spouse” claims. If the Department of the Treasury 

provides this information, collections held from some joint tax refunds 

could reach families sooner. 

To better measure the amount of and help reduce undistributed 

collections, we are making three recommendations. 

We recommend that the Secretary of Health and Human Services direct 

the Commissioner of OCSE to 

• review undistributed collections data from state agencies periodically in 

conjunction with one of the other routine reviews to help improve the 

accuracy of the data and 

• work closely with the Department of the Treasury to identify a costeffective approach for obtaining information on “injured spouse” claims in 

order to enable collections from some joint tax refunds to reach families 

sooner. 

We also recommend that the Secretary of the Treasury direct the 

Commissioner of IRS and the Commissioner of FMS to work together with 

OCSE to identify a cost-effective approach for providing OCSE 

information needed to identify those collections that have had their 

“injured spouse” claims satisfied so that these collections can be 

distributed to families sooner. 

We received written comments on a draft of this report from HHS. These 

comments are reprinted in appendix III. The department did not explicitly 

agree or disagree with either of our recommendations. In response to our 

recommendation to review undistributed collections data, HHS stated that 

conducting these reviews in conjunction with the data reliability audits 

would substantially increase the time needed to complete them due to the 

variability of the undistributed collections data and that the data reliability 

audits must be completed on time. As we stated in our report, such 

reviews of undistributed collections data could be done in a number of 

ways and would not necessarily have to be done with data reliability 

audits. Also, HHS stated that its audit resources are insufficient to 

routinely audit any other function or area except data reliability. We also 

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 
Page 32 GAO-04-377 Child Support Enforcement 

noted their concern about limited resources in the report. With regard to 

the recommendation that OCSE work with IRS and FMS, HHS stated that 

it has been working with IRS and FMS. We added more detail to this 

section in the report. HHS also agreed with our finding that information on 

approved injured spouse claims could significantly reduce undistributed 

collections and get money to families in a timelier manner. However, the 

HHS comments also noted concerns about a direct exchange of 

information between IRS and OCSE because OCSE’s current interaction is 

strictly with FMS, and it would be more complex, time consuming and 

costly to add the additional interfaces and processing that would be 

required for a direct exchange with IRS. We did not recommend a specific 

approach for sharing the information. 

We also received written comments on a draft of this report from the 

Department of the Treasury. These comments are reprinted in appendix 

IV. The Department of the Treasury agreed with our recommendation. In 

commenting, the Acting Chief Financial Officer stated that although 

neither IRS nor FMS can readily provide OCSE information on satisfied 

injured spouse claims, and that significant programming changes would be 

needed, IRS and FMS would work together with OCSE to develop a costeffective way to advise OCSE when injured spouse claims have been 

satisfied. 

In addition to written comments, officials from HHS, FMS, and IRS 

provided technical comments. We incorporated these comments in the 

report as appropriate. 

As arranged with your office, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 30 days from its 

issue date. At that time we will send copies of this report to appropriate 

congressional committees, the Secretary of Health and Human Services, 

the Secretary of the Treasury, and other interested parties. In addition, this 

report will be available at no charge on GAO’s Web site at 

http://www.gao.gov. 
Page 33 GAO-04-377 Child Support Enforcement 

If you have any questions regarding this report, please call me on (202) 

512-8403. Other contacts and acknowledgments are listed in appendix V. 

Sincerely yours, 

Cornelia M. Ashby 

Director, Education, Workforce, 

 and Income Security 
Appendix I: Scope and Methodology 

Page 34 GAO-04-377 Child Support Enforcement 

To accomplish our objectives, we conducted a mail survey of all 54 IV-D 

child support enforcement directors, conducted site visits to 6 state 

agencies, interviewed federal and state officials, as well as reviewed 

related reports and analyzed laws and regulations. 

We sent each director a self-administered mail-back questionnaire. To 

ensure that our survey questions were clear, unbiased, specific, and easy 

to understand, we pretested the survey instruments in 3 state agencies and 

discussed the appropriateness of the survey questions with OCSE. We 

electronically mailed follow-up letters and replacement copies of the 

survey to nonrespondents to encourage response. Forty-eight state 

agencies participated in the survey. Nonrespondents included Arizona, 

Indiana, Guam, Mississippi, New Jersey, and Virgin Islands. We requested 

data as of June 30, 2003, and administered the survey from September to 

November 2003. We did not assess the reliability of the data reported by 

state agencies in response to our survey. However, we reviewed the data 

for completeness and reasonableness. 

We visited Virginia, New York, Florida, Texas, Iowa, and California. We 

selected the state agencies so as to obtain diversity in the amount of 

collections and balances of undistributed collections, geographic location, 

number of clients served, and whether the child support program was 

county or state administered. Of the state agencies we visited, 3—Iowa, 

Texas, and Virginia—had undistributed collection balances lower than the 

national average of 3 percent and were cited by the Office of Child Support 

Enforcement (OCSE) as having best practices in reducing and or 

improving payment distribution practices. Two of the state agencies—

California and New York—had balances of undistributed collections that 

were higher than the national average of 3 percent while 1 state, Florida, 

had a balance of about 3 percent. 

In addition to our overall approach, we took specific steps for each of the 

objectives. To address how the data on undistributed collections has 

changed in the last few years, we reviewed and analyzed OCSE data on 

undistributed collections for fiscal years 1999 to 2002 as reported by state 

agencies. We began with fiscal year 1999 data because that was the earliest 

year with data comparable to fiscal year 2002; the most current year data 

were available at the time of our review. As a part of our analysis we 

(1) reviewed and compared the data for each fiscal year and (2) identified 

issues associated with the calculation and reporting of undistributed 

collections through interviews with state and OCSE officials. Additionally, 

we analyzed survey responses that identified the types of funds state 

agencies classify and report as undistributed collections. We cited findings 

Appendix I: Scope and Methodology 
Appendix I: Scope and Methodology 

Page 35 GAO-04-377 Child Support Enforcement 

from an internal review conducted in California, however, we did not 

verify the methodology used in this review. To identify the causes of 

undistributed collections, we reviewed relevant literature and past audit 

reports on the causes of undistributed collections. We cited relevant 

findings from two of these reports. The report issued by the Department of 

Health and Human Services Office of Inspector General was conducted in 

accordance with Quality Standards for Inspections issued by the 

President’s Council on Integrity and Efficiency. We did not verify the 

methodology used in the report produced by a private firm. We also 

reviewed laws, regulations, and policies governing child support 

distribution practices to gain an understanding of the required time frames 

for distribution of child support payments. We interviewed child support 

advocates and experts to obtain their opinions on the causes for 

undistributed collections. 

To identify what state agencies are doing to reduce undistributed 

collections and to determine what guidance OCSE has given state agencies 

to help reduce undistributed collections, we reviewed relevant documents 

and agency audit reports. We also reviewed documents issued by the 

National Council of Child Support Directors and collected information on 

relevant OCSE-funded research. In addition, we also interviewed child 

support advocates and experts, as well as federal and state officials to 

obtain their perspectives on how OCSE has helped state agencies reduce 

undistributed collections and additional actions that OCSE can take. 
Appendix II: Survey of State Directors of 

Child Support Enforcement 

Page 36 GAO-04-377 Child Support Enforcement 

Appendix II: Survey of State Directors of 

Child Support Enforcement 
Appendix II: Survey of State Directors of 

Child Support Enforcement 

Page 37 GAO-04-377 Child Support Enforcement 
Appendix II: Survey of State Directors of 

Child Support Enforcement 

Page 38 GAO-04-377 Child Support Enforcement 
Appendix II: Survey of State Directors of 

Child Support Enforcement 

Page 39 GAO-04-377 Child Support Enforcement 
Appendix II: Survey of State Directors of 

Child Support Enforcement 

Page 40 GAO-04-377 Child Support Enforcement 
Appendix II: Survey of State Directors of 

Child Support Enforcement 

Page 41 GAO-04-377 Child Support Enforcement 
Appendix II: Survey of State Directors of 

Child Support Enforcement 

Page 42 GAO-04-377 Child Support Enforcement 
Appendix III: Comments from the Department 

of Health and Human Services 

Page 43 GAO-04-377 Child Support Enforcement 

Appendix III: Comments from the 

Department of Health and Human Services 
Appendix III: Comments from the Department 

of Health and Human Services 

Page 44 GAO-04-377 Child Support Enforcement 
Appendix III: Comments from the Department 

of Health and Human Services 

Page 45 GAO-04-377 Child Support Enforcement 
Appendix IV: Comments from the Department 

of the Treasury 

Page 46 GAO-04-377 Child Support Enforcement 

Appendix IV: Comments from the 

Department of the Treasury 
Appendix IV: Comments from the Department 

of the Treasury 

Page 47 GAO-04-377 Child Support Enforcement 
Appendix V: GAO Contacts and Staff 

Acknowledgments 

Page 48 GAO-04-377 Child Support Enforcement 

Carolyn M. Taylor (202) 512-2974, taylorcm@gao.gov

Rebecca A. Christie (312) 220-7720, christier@gao.gov 

In addition to those named above the following individuals made 

important contributions to this report: Vernette Shaw, Carolyn Boyce, 

Jay Smale, Corinna Nicolaou, James Rebbe, and Paul Schearf. 

Appendix V: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts 

Staff 

Acknowledgments 

(130260) 
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