United States General Accounting Office

GAO Report to Congressional Requesters

June 1998 CHILD SUPPORT

ENFORCEMENT

Certification Process

for State Information

Systems

GAO/AIMD-98-134

GAO United States

General Accounting Office

Washington, D.C. 20548

Accounting and Information

Management Division

B-279010 

June 15, 1998

The Honorable Daniel Patrick Moynihan

Ranking Minority Member

The Honorable John D. Rockefeller IV

Committee on Finance

United States Senate

This report responds to your request that we review the Department of

Health and Human Services (HHS) certification process for state child

support enforcement systems and its administration of the process and

determine the certification status of the state systems. The Family Support

Act of 1988 requires states to obtain HHS certification that their child

support enforcement systems meet federal requirements. All states were

to obtain this certification by October 1, 1997, or face the possibility of

substantial financial penalties for noncompliance after the deadline.1

Results in Brief Certification guidance issued by the Office of Child Support Enforcement

(OCSE) addresses the system requirements of the Family Support Act of

1988 and HHS’ implementing regulations. Our analysis of the certification

process shows that OCSE has administered this process consistently across

states since it began certifying child support enforcement systems in 1993.

It has used the same guidance for certification reviews and conducted

reviews that were similar in scope and length for each level of

certification. While OCSE published many certification reports on the

results of its certification reviews, its reporting was not always consistent.

For example, six preliminary certification review reports included an

inaccurate description of the criteria against which the systems’ financial

components were measured. As of March 31, 1998, OCSE had either

certified or conditionally certified 25 of the 54 child support enforcement

systems.2 OCSE had also conducted 13 additional reviews and was

preparing certification reports3

 for those systems.

1

Legislation to reduce the penalties for failure to certify state systems was pending as of March 31,

1998.

2

The 54 state systems consist of systems for the 50 states and for the District of Columbia, Guam,

Puerto Rico, and the Virgin Islands. The term system refers to the hardware and software components

of the child support enforcement systems.

3

OCSE conducted the review for one state during the week of March 30, 1998, and began preparing

that state’s report on April 6, 1998.

Page 1 GAO/AIMD-98-134 Child Support Systems Certification
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Background The Child Support Enforcement Program was established in 1975 to help

strengthen families and reduce dependence on welfare by helping to

ensure that the responsibility for supporting children was placed on

parents. The states operate programs to locate noncustodial parents,

establish paternity, and obtain support orders, along with enforcing actual

collections of those court-ordered support payments. The federal

government—through OCSE—funds 66 percent of state administrative and

operating costs, including costs for automated systems, and up to

90 percent of expenses associated with planning, designing, developing,

installing, and/or enhancing automated systems.

The Family Support Act of 1988 required that statewide systems be

developed to track determination of paternity and child support

collections. To address that requirement, OCSE developed regulations and

guidance for conducting certification reviews. In 1993, OCSE published a

certification guide,4

 which addresses the functional requirements for child

support enforcement systems. In general, the certification guide requires

that the systems be operational, statewide, comprehensive, and effective

and efficient. The guide also provides 53 specific requirements, which are

grouped into the following categories: case initiation, location of parents,

establishment of paternity, case management, enforcement, financial

management, reporting, and security and privacy. (See appendix I for the

system regulations and appendix II for descriptions of the guide’s specific

requirements by category.) The guide was developed to help OCSE’s

analysts ensure that certification reviews are conducted

consistently—using the same criteria and standards for documentation.

The analysts use the certification guide in conducting certification

reviews, and states refer to it in preparing for their certification reviews.

To ensure that states are meeting the functional requirements specified in

the certification guide, OCSE also developed a certification questionnaire.5

The questionnaire provides a series of questions for analysts’ use in

determining if the states’ systems address the functional requirements. The

format and content of the questionnaire mirror those of the certification

guide. In addition to the certification guide and questionnaire, OCSE has

provided supplementary guidance to (1) aid in developing and testing

specific areas such as financial requirements and (2) clarify and expand

4

Automated Systems for Child Support Enforcement: A Guide for States, U.S. Department of Health

and Human Services, Administration for Children and Families. (Revised June 1993.) (This guide

replaced draft guidance distributed in November 1992.)

5

Automated Systems for Child Support Enforcement: Child Support Systems, Certification

Questionnaire, U.S. Department of Health and Human Services, Administration for Children and

Families. (Revised January 1994.)

Page 2 GAO/AIMD-98-134 Child Support Systems Certification
B-279010 

upon the requirements provided in the certification guide and

questionnaire.

OCSE uses its guidance to ensure that its staff consistently perform three

types of certification reviews: functional, level 1, and level 2. A functional

review occurs early in the development of a system before it is operational

in a pilot site. During functional reviews, analysts evaluate parts of the

system against the certification requirements to inform the state of the

work that remains before its system can be certified. A level 1 review

occurs when an automated system is installed and in operation in one or

more pilot locations. (OCSE created this level of review in 1990 due to state

requests for agency guidance prior to statewide implementation.) A level 2

review occurs when the system is considered by the state to be

operational statewide.6

 This review is required for final certification.

Systems are granted full certification when they meet all functional

requirements and conditional certification when the system needs only

minor corrections that do not affect statewide operation. According to

OCSE analysts, states whose systems receive either type of level 2

certification are exempt from penalties for failing to meet system

requirements imposed by the Family Support Act.

The Family Support Act of 1988 set a deadline of October 1, 1995, for

implementation and federal certification of such systems. However, when

only a few states met the deadline, the Congress passed legislation

extending it by 2 years, to October 1, 1997. Current law requires HHS to

impose substantial financial penalties on states that did not have certified

child support enforcement systems by October 1, 1997. The Congress,

under the House bill HR 3130 with Senate modifications SP 2286, is

considering legislation to reduce those penalties. OCSE certified 17 states

by the extended deadline and another 8 states since the deadline (as of

March 31, 1998).

In June 1997 we made several recommendations designed to strengthen

OCSE’s oversight of child support enforcement systems. Specifically, we

reported that the certification reviews are conducted too late for effective

oversight.7

 Because the reviews are conducted toward the end of the

system development projects, the reviews come too late for timely

6

According to OCSE analysts, if a state had a level 1 review prior to its level 2 review, the scope of the

level 2 review may be limited to those problems identified during the level 1 review.

7

Child Support Enforcement: Strong Leadership Required to Maximize Benefits of Automated Systems

(GAO/AIMD-97-72, June 30, 1997).

Page 3 GAO/AIMD-98-134 Child Support Systems Certification
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redirection of systems development without significant costs being

incurred.

Objectives, Scope,

and Methodology

Our objectives were to determine (1) whether HHS’ certification guidance

addresses the system provisions in the Family Support Act of 1988 and

implementing regulations, (2) whether HHS has consistently administered

the certification process, and (3) the certification status of the state

systems. Our work was done to determine whether OCSE’s certification

guidance completely addresses the system requirements in the act and

supporting regulations; it does not determine the overall adequacy of

OCSE’s certification review process. This issue was addressed in our

June 1997 report,8

 in which we identified weaknesses in HHS’ oversight of

these systems, including the timeliness of the certification reviews.

To document the certification process, we obtained and analyzed OCSE’s

guidance for certifying child support enforcement systems. To determine

whether this guidance addresses the legal and regulatory requirements for

child support enforcement systems, we compared the certification guide

and questionnaire to the child support enforcement system regulations.

We also analyzed whether the regulations addressed the system provisions

of the Family Support Act of 1988.

To determine whether OCSE consistently administered the certification

process, we obtained and reviewed all certification reports issued as of

March 31, 1998, and assessed how OCSE officials at headquarters and in one

regional office plan, administer, and report the results of certification

reviews. While we discussed this review process with these officials, we

did not visit states to observe OCSE conducting certification reviews or

conduct independent work to verify the information presented in OCSE’s

certification reports.

We performed our work at HHS headquarters in Washington, D.C., and at

the HHS regional office in Atlanta, Georgia. We conducted our work

between December 1997 and April 1998, in accordance with generally

accepted government auditing standards.

HHS provided written comments on a draft of this report. These comments

are highlighted in the “Agency Comments” section of this report and are

reprinted in appendix IV.

8

GAO/AIMD-97-72, June 1997.

Page 4 GAO/AIMD-98-134 Child Support Systems Certification
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OCSE Certification

Guidance Addresses

Law and

Implementing

Regulations

OCSE’s guidance for certification reviews generally complies with the

system provisions in the Family Support Act of 1988 and the implementing

regulations established by the Secretary of HHS. This guidance includes:

(1) the certification guide, which defines systems functional requirements

and (2) the certification questionnaire, which in essence, is the

certification guide presented in a questionnaire format.

Our analysis showed that the certification guide and questionnaire address

key system elements of the law and implementing regulations. OCSE

included references to system and program regulations in both the

certification guide and questionnaire. We analyzed those references to

determine whether the certification guidance addressed the regulations

cited. The comparison in appendix III shows that each of the

implementing regulations is addressed in OCSE’s certification objectives.

For example, section 307.10(b)(1) of the regulation requires that child

support enforcement systems maintain identifying information on

individuals involved in child support cases. Seven different certification

objectives in the certification guidance address this requirement. Two of

those certification objectives, A-8 and D-4, demonstrate how the guide

addresses this requirement; respectively, they state that, “the system must

accept and maintain identifying information on all case participants,” and

“the system must update and maintain in the automated case record, all

information, facts, events, and transactions necessary to describe a case

and all actions taken in a case.”

Consistent

Administration of

Certification Reviews

OCSE has been consistent in the way it administers certification reviews.

Specifically, it used the same types of teams, the same guidance that was

discussed earlier, and the same method for certification reviews. Although

the scope and length of functional, level 1, and level 2 certification reviews

varied, OCSE has been generally consistent in the way that it conducted

each type of review.

OCSE’s review process is as follows. It begins preparing for a certification

review when the state notifies it that the state system is compliant and

ready for certification. When OCSE receives the request, it requires the state

to submit consistent documentation, which includes the completed

certification questionnaire. After OCSE receives the documentation, it

assigns a team to review the information and develop issues for discussion

during the certification review. These teams consistently included at least

one supervisor and two systems analysts. In some cases, regional analysts

also participated in the documentation review.

Page 5 GAO/AIMD-98-134 Child Support Systems Certification
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Following that review, certification teams are formed from staff who have

similar background and expertise. For example, the certification team

leaders are usually systems analysts from OCSE headquarters. These

leaders are assisted by teams from the Administration for Children and

Families regional offices responsible for the states being reviewed. The

regional teams are usually a combination of staff with systems, policy, or

audit expertise.

In performing the certification reviews, these teams consistently use the

certification questionnaire. OCSE used the same certification questionnaire

for all of its level 1 and level 2 certification reviews except one. The first

level 1 review was conducted before OCSE developed the certification

questionnaire.

OCSE analysts have also used a consistent method for conducting

certification reviews. Certification review teams spend approximately 1

week on-site conducting certification reviews. (Because functional

reviews and level 1 reviews are more limited in scope, those reviews do

not always take a full week.) During the certification review, the review

team usually holds an entrance conference at the state office and allows

the state staff to provide an overview of the child support enforcement

system. The next few days are spent reviewing the state’s responses to the

certification questionnaire and observing how adequately system screens

and functions address the federal requirements. This review at the state

office is often performed using a test version of the system—one that does

not include actual cases. To supplement the information obtained at the

state office, the certification team usually spends at least one day visiting

local offices to observe the system in operation. At the local offices, the

team interviews staff about their use of the system and the systems

training they have received. In addition, they have the staff process sample

cases to ensure that the system will handle them correctly, observe the

staff processing actual cases, and review reports and documents generated

by the system.

OCSE uses the certification guide and questionnaire in lieu of a manual to

instruct its staff on how to conduct certification reviews and relies heavily

upon on-the-job training to ensure that the reviews continue to be

conducted consistently. In one instance when a new certification staff

member was added, that person was paired with experienced staff for the

first two or three reviews after joining the review team, to gain experience

and learn how to consistently cover the issues addressed by the

certification teams.

Page 6 GAO/AIMD-98-134 Child Support Systems Certification
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Inconsistent

Reporting on

Certification Reviews

OCSE began reporting on the results of its certification reviews in 1994. In

general, the format and process for preparing certification reports has

been standardized. However, we noted that several reports contained

inconsistencies, such as including inaccurate descriptions of the criteria

against which the systems’ financial components were measured.

OCSE’s analysts used a standard template for preparing certification

reports. As a result, we found the certification reports to be very similar in

format and content. Even though the scope of the different reviews varied,

the reports for functional, level 1, and level 2 reviews addressed similar

topics. For example, they typically included a background section giving

the history of the development of and funding for the system and

describing the scope and methodology of the certification review. The

reports also presented both certification findings and management

findings. Certification findings are those system problems that must be

addressed prior to system certification. Management findings are optional

systems changes for management to consider. These findings often relate

to the efficiency of the states’ systems.

OCSE used a consistent process for reviewing the draft certification reports.

According to an OCSE supervisor, division management reviewed all

certification reports for consistency prior to their issuance. In addition,

the office requested comments from states before publishing the final

reports. According to OCSE officials, the nature, extent, and timeliness of

the states’ comments varied and, when appropriate, states’ comments

were incorporated into the final certification reports.

While OCSE published many standardized certification reports on the

results of its certification reviews, we noted three types of exceptions with

the reporting process. First, OCSE certified two state systems in July and

December 1997, respectively, by sending a brief letter to each state instead

of issuing a complete standardized written report. The division director

explained that standardized reports were not prepared for those systems

because the certification team found no problems with them during the

review. Second, according to officials, a report was not published for one

state’s level 1 review because the level 2 review was requested before the

earlier report was published.

Finally, the reports for one level 1 and five functional reviews contained a

qualifying statement not contained in the boilerplate language of the

standardized reports. This qualifying statement said that, in order to even

be conditionally certified, a system must process the financial component

Page 7 GAO/AIMD-98-134 Child Support Systems Certification
B-279010 

of all sample cases correctly, in accordance with predetermined results. In

contrast, the other standardized reports’ paragraph on this subject did not

contain this qualification.

The division director told us that the boilerplate language in the

standardized reports was appropriate and that the qualifying language in

the six reports was incorrect. She said OCSE will conditionally certify a

system even though it does not process all sample cases correctly, as long

as the majority of the financial transactions are processed accurately and

the state has reasonable explanations for any variances. She added that

none of the systems was denied level 2 certification based on the

qualifying statement, and that she was unaware of any other systems that

were denied certification for failing to process all test cases correctly.9

 The

division director also noted that the problem was not widespread because

only one lead analyst was responsible for the incorrect language.

However, the review process did not prevent the incorrect language from

being incorporated into the six published reports. Finally, she said that,

until we brought this issue to her attention, she was not aware that any

reports included this language; and that she would act to ensure that such

qualifying language did not appear in future reports.

Current Status: Many

Systems Not Certified,

More Reviews

Scheduled

As of March 31, 1998, OCSE had either certified or conditionally certified 25

of 54 child support enforcement systems, representing approximately

38 percent of the reported average national caseload for fiscal year 1995.

OCSE had conducted 67 certification reviews for the 54 state systems as of

March 31, 1998. Some states have had several levels of review. Figure 1

shows the highest level of certification for the 54 child support

enforcement systems as of March 31, 1998.

9

We did not verify whether any states were denied certification based on the results of their sample

test cases, nor did we assess the sample case test process to determine if all cases should, or should

not, be processed as a condition of certification.

Page 8 GAO/AIMD-98-134 Child Support Systems Certification
B-279010 

Figure 1: Certification Status of 54

State Systems as of March 31, 1998a

Level 2 pending

(46%)

(24%)

(9%)

(15%)

Level 1 review (2%)

Level 1 pending (2%)

Functional review

Functional pending (2%)

No review

Level 2 certified

aLevel 2 certified state systems include 7 systems that were fully certified and 18 systems that

were conditionally certified as of March 31, 1998.

Source: HHS.

On page 10, as figure 2 indicates, 25 state systems were level 2 certified as

of March 31, 1998. Figure 2 shows the status of level 2 certification for

each state.

Page 9 GAO/AIMD-98-134 Child Support Systems Certification
B-279010 

Figure 2: Status of State Level 2 Certification Reviews as of March 31, 1998

1

WA

ID

MT

WY

CO

UT

CA

AZ

NM

OK

TX

HI

AK

AR

ND

SD

NE

MN

MO

WI

MI

OH

PA

ME

MA

RI

CT

DE

WV

KY

NJ

TN

VA

NC

FL

GA

OR

NV

KSa

IL IN

LA

MS

AL

IA

NY

NH

VT

MD

SC

Certified (7)

Conditionally certified (18)

Level 2 review conducted but report not yet published (13)a

States without a level 2 review (16)

PR

DC

VI

GU

aThe systems division director stated that OCSE will not certify Kansas’ system based upon its

February 1998 level 2 certification review.

Source: HHS.

Page 10 GAO/AIMD-98-134 Child Support Systems Certification
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Since the October 1997 deadline, OCSE’s certification review workload has

increased substantially, as shown by figure 3. OCSE conducted 13 level 2

certification reviews for the first quarter of calendar year 1998,10 equaling

the number of level 2 reviews conducted in 1997—the most done in any

previous year.

Figure 3: Level 2 Certification Reviews

Conducted, June 1, 1994 - March 31,

1998a

14

12

10

8

6

4

2

0

1994 1995 1996 1997 1998

Calendar Year

Number of reviews conducted

13 13

8

5

1

aThis graph reflects all level 2 reviews conducted, including reviews for the 25 certified systems.

The 1998 reviews were conducted during the first 3 months of the calendar year.

Source: HHS.

The OCSE systems director told us, however, that the increased workload

did not affect the staffing or quality of the certification reviews. She

explained that (1) her staff traveled extensively, used newly acquired

laptop computers, and worked long hours to manage the increased

workload and (2) additional OCSE staff supported the system certification

staff by relieving them of administrative duties. The systems director said

that management chose to maintain its experienced review teams rather

than add additional staff to conduct certification reviews. She said she

prohibited the certification staff from taking vacations to ensure that the

scheduled work was expeditiously completed. OCSE is currently

10The first quarter of calendar year 1998 is the second quarter of OCSE’s fiscal year 1998.

Page 11 GAO/AIMD-98-134 Child Support Systems Certification
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documenting the results of and preparing certification reports for the

certification reviews performed in 1998. The systems director said she

expects the rate of certification reviews to decline sharply because, as of

March 31, 1998, only one request for a certification review was pending.

Conclusions OCSE’s certification guidance addresses the system requirements of the

Family Support Act of 1988 and HHS’ implementing regulations, and OCSE

has administered the certification process consistently across states.

Further, while OCSE, in general, used a standardized format and process in

preparing certification reports on the results of its reviews, these reports

were not always consistent.

Recommendation We recommend that the Assistant Secretary of the Administration for

Children and Families increase OCSE’s oversight of the reporting process to

ensure that the reports consistently address criteria for evaluating the

financial components of state systems.

Agency Comments The Assistant Secretary for Children and Families agreed with our

recommendation to increase OCSE’s oversight of the reporting process. She

stated that OCSE would increase its oversight and consistency of reporting

by subjecting the functional and level 1 reports to the same degree of

management review being provided to the level 2 reports.

We will provide copies of this report to the Assistant Secretary,

Administration for Children and Families, Department of Health and

Human Services; the Director of the Office of Management and Budget;

and appropriate congressional committees. We will also make copies

available to others upon request.

Page 12 GAO/AIMD-98-134 Child Support Systems Certification
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Please contact me at (202) 512-6253 or by e-mail at

willemssenj.aimd@gao.gov if you have any questions concerning this

report. Major contributors are listed in appendix V.

Joel C. Willemssen

Director, Civil Agencies Information Systems

Page 13 GAO/AIMD-98-134 Child Support Systems Certification
Contents

Letter 1

Appendix I 

Child Support

Enforcement Systems

Regulations

16

Appendix II 

Child Support

Enforcement System

Requirements

Provided in OCSE

Certification Guide

and Questionnaire

19

Appendix III 

Comparison of

Regulations to OCSE’s

Certification

Objectives for Child

Support Enforcement

Systems

22

Appendix IV 

Comments From the

Department of Health

and Human Services

24

Appendix V 

Major Contributors to

This Report

27

Page 14 GAO/AIMD-98-134 Child Support Systems Certification
Contents

Related GAO Products 28

Figures Figure 1: Certification Status of 54 State Systems as of March 31,

1998

9

Figure 2: Status of State Level 2 Certification Reviews as of

March 31, 1998

10

Figure 3: Level 2 Certification Reviews Conducted, June 1, 1994 -

March 31, 1998

11

Abbreviations

AFDC Aid to Families With Dependent Children

APD advance planning document

C.F.R. Code of Federal Regulations

GAO General Accounting Office

HHS Department of Health and Human Services

OCSE Office of Child Support Enforcement

TANF Temporary Assistance for Needy Families

Page 15 GAO/AIMD-98-134 Child Support Systems Certification
Appendix I 

Child Support Enforcement Systems

Regulations

45 C.F.R. 307.10:

Functional Requirements

for Computerized Support

Enforcement Systems

At a minimum, each state’s computerized support enforcement system

established under the title IV-D state plan at § 302.85 of this chapter must:

(a) Be planned, designed, developed, installed, or enhanced in accordance

with an initial and annually updated APD [advance planning document]

approved under § 307.15; and

(b) Control, account for, and monitor all the factors in the support

collection and paternity determination processes under the state plan. At a

minimum this must include:

(1) Maintaining identifying information such as Social Security

numbers, names, dates of birth, home addresses, and mailing

addresses (including postal zip codes) on individuals against

whom support obligations are sought to be established or enforced

and on individuals to whom support obligations are owed, and other

data as required by the Office;

(2) Periodically verifying the information on individuals referred

to in paragraph (b)(1) of this section with federal, state, and

local agencies, both intrastate and interstate;

(3) Maintaining data necessary to meet federal reporting

requirements on a timely basis as prescribed by the Office;

(4) Maintaining information pertaining to

(i) Delinquency and enforcement activities;

(ii) Intrastate, interstate and federal location of absent

 parents;

(iii) The establishment of paternity; and

(iv) The establishment of support obligations;

(5) Collecting and distributing both intrastate and

interstate support payments;

(6) Computing and distributing incentive payments to political

subdivisions which share in the cost of funding the program

and to other political subdivisions based on efficiency and

effectiveness if the state has chosen to pay such incentives;

(7) Maintaining accounts receivable on all amounts owed,

collected, and distributed;

(8) Maintaining costs of all services rendered, either

directly or by interfacing with state financial management

and expenditure information;

(9) Accepting electronic case referrals and update information

from the state’s title IV-A program and using that information

Page 16 GAO/AIMD-98-134 Child Support Systems Certification
Appendix I 

Child Support Enforcement Systems

Regulations

to identify and manage support enforcement cases;

(10) Transmitting information electronically to provide data to

the state’s AFDC [Aid to Families With Dependent Children;

now Temporary Assistance for Needy Families (TANF)] system so

that the IV-A agency can determine (and report back to the

IV-D system) whether a collection of support causes a change

in eligibility for, or the amount of aid under, the AFDC program;

(11) Providing security to prevent unauthorized access to, or

use of, the data in the system;

(12) Providing management information on all IV-D cases under

the state plan from initial referral or application through

collection and enforcement;

(13) Providing electronic data exchange with the state Medicaid

system to provide for case referral and the transfer of the

medical support information specified in 45 C.F.R. 303.30 and

303.31;

(14) Providing electronic data exchange with the state IV-F

program for purposes of assuring that services are furnished

in an integrated manner unless the requirement is otherwise

met through the exchange conducted under paragraph (b)(9)

of this section;

(15) Using automated processes to assist the state in meeting

state plan requirements under part 302 of this chapter and

Standards for program operations under part 303 of this

chapter, including but not limited to:

(i) The automated maintenance and monitoring of accurate

records of support payments;

(ii) Providing automated maintenance of case records for

purposes of the management and tracking requirements in

§ 303.2 of this chapter;

(iii) Providing title IV-D case workers with on-line

access to automated sources of absent parent employer and

wage information maintained by the state when available,

by establishing an electronic link or by obtaining an 

extract of the data base and placing it on-line for access

throughout the state;

(iv) Providing locate capability by automatically referring

cases electronically to locate sources within the state

(such as state motor vehicle department, state department

of revenue, and other state agencies), and to the Federal

Parent Locator Service and utilizing electronic linkages

Page 17 GAO/AIMD-98-134 Child Support Systems Certification
Appendix I 

Child Support Enforcement Systems

Regulations

to receive return locate information and place the 

information on-line to title IV-D case workers throughout

the state;

(v) Providing capability for electronic funds transfer for

 purposes of income withholding and interstate collections;

(vi)Integrating all processing of interstate cases with the

computerized support enforcement system, including the

central registry; and

(16) Providing automated processes to enable the Office to

monitor state operations and assess program performance 

through the audit conducted under section 452(a) of the Act.

Page 18 GAO/AIMD-98-134 Child Support Systems Certification
Appendix II 

Child Support Enforcement System

Requirements Provided in OCSE

Certification Guidea

 and Questionnaire

(A) Case Initiation

A-1 The system must accept, maintain, and process information for non-AFDC services.

A-2 The system must automatically accept and process referrals from the State’s Title IV-A (AFDC) agency.

A-3 The system must accept and process referrals from the State’s Title IV-E (Foster Care) agency.

A-4 The system must automatically accept appropriate referrals from the State’s Title XIX (Medicaid) agency.

A-5 The system must automatically accept and process interstate referrals.

A-6 The system must uniquely identify and edit various case types.

A-7 The system must establish an automated case record for each application/referral.

A-8 The system must accept and maintain identifying information on all case participants.

(B) Locate

B-1 The system must electronically interface with all appropriate sources to obtain and verify locate, asset and other

information on the non-custodial/putative parent or custodial parent. The system must automatically generate any

needed documents.

B-2 The system must record, maintain, and track locate activities to ensure compliance with program standards.

B-3 The system must automatically resubmit cases to locate sources.

B-4 The system must automatically submit cases to the Federal Parent Locator Service (FPLS).

(C) Establishment

C-1 The system must automatically track, monitor, and report on the status of paternity establishment and support

Federal regulations and State laws and procedures for establishing paternity.

C-2 The system must automatically record, track, and monitor information on obligations, and generate documents to

establish support including medical support.

C-3 The system must accept, maintain, and process information concerning established support orders.

C-4 The system must accept, maintain, and process information concerning medical support services.

(D) Case Management

D-1 If the State chooses to have case prioritization procedures, the system must automatically support them.

D-2 The system must automatically direct cases to the appropriate case activity.

D-3 The system must automatically accept and process case updates and provide information to other programs on

a timely basis.

D-4 The system must update and maintain in the automated case record all information, facts, events, and

transactions necessary to describe a case and all actions taken in a case.

D-5 The system must perform routine case functions, keep the caseworker informed of significant case events,

monitor case activity, provide case status information, and ensure timely case action.

D-6 The system must automatically support the review and adjustment of support obligations.

D-7 The system must allow for case closure.

D-8 The system must provide for management of all interstate cases.

D-9 The system must manage Responding-State case actions.

D-10 The system must manage initiating-State case actions.

(E) Enforcement

E-1 The system must automatically monitor compliance with support orders and initiate enforcement actions.

E-2 The system must support income withholding activities.

(continued)

Page 19 GAO/AIMD-98-134 Child Support Systems Certification
Appendix II 

Child Support Enforcement System

Requirements Provided in OCSE

Certification Guidea and Questionnaire

E-3 The system automatically must support Federal tax refund offset.

E-4 The system must automatically support State tax refund offset.

E-5 The system must automatically identify, initiate, and monitor enforcement actions using liens and bonds.

E-6 Where action is appropriate under State guidelines, the system must support Unemployment Compensation

Intercept (UCI).

E-7 The system must be capable of forwarding arrearage information to credit reporting agencies.

E-8 The system must support enforcement through Internal Revenue Service full collection services when previous

enforcement attempts have failed.

E-9 In cases where previous enforcement attempts have failed, the system must periodically re-initiate enforcement

actions.

E-10 The system must support the enforcement of spousal support.

E-11 The system must automatically monitor compliance with and support the enforcement of medical insurance

provisions contained within support orders.

(F) Financial Management

F-1 With the exception of those cases with income withholding in force, the system must automatically bill cases with

obligations.

F-2 The system must automatically process all payments received.

F-3 The system must support the acceptance and disbursement of payments using electronic funds transfer (EFT)

technology.

F-4 The system’s accounting process must be uniform statewide, accept and maintain all financial information, and

perform all calculations relevant to the IV-D program.

F-5 The system must distribute collections in accordance with 45 C.F.R. 302.32, 302.51, 302.52, 303.72, and 303.102.

F-6 The system must generate notices to AFDC and former AFDC recipients, continuing to receive IV-D services,

about the amount of support collections; and must notify the IV-A agency about collections for AFDC recipients.

(G) Reporting

G-1 The system must maintain information required to prepare Federal reports.

G-2 The system must provide an automated daily on-line report/worklist to each caseworker to assist in case

management and processing.

G-3 The system must generate reports required to ensure and maintain the accuracy of data and to summarize

accounting activities.

G-4 The system must provide management reports for monitoring and evaluating both employee, office/unit, and

program performance.

G-5 The system must support the expeditious review and analysis of all data that is maintained, generated, and

reported by the system.

(H) Security and Privacy

H-1 The State must have policies and procedures to evaluate the system for risk on a periodic basis.

H-2 The system must be protected against unauthorized access to computer resources and data in order to reduce

erroneous or fraudulent activities.

H-3 The State must have procedures in place for the retrieval, maintenance, and control of the application software.

H-4 The State must have procedures in place for the retrieval, maintenance, and control of program data.

H-5 The system hardware, software, documentation, and communications must be protected and back-ups must be

available.

(Table notes on next page)

Page 20 GAO/AIMD-98-134 Child Support Systems Certification
Appendix II 

Child Support Enforcement System

Requirements Provided in OCSE

Certification Guidea and Questionnaire

Source: OCSE’s Automated Systems For Child Support Enforcement: A Guide for States.

aThe certification guide is currently being revised to incorporate changes required by welfare

reform. The new version will refer to Temporary Assistance for Needy Families, the program that

replaced Aid to Families With Dependent Children.

Page 21 GAO/AIMD-98-134 Child Support Systems Certification
Appendix III 

Comparison of Regulations to OCSE’s

Certification Objectives for Child Support

Enforcement Systems

Child Support Systems Certification Objectives (A-H)

A-1 A-2 A-5 A-3 A-4 A-6 A-7 B-1 A-8 B-4 C-3 B-2 C-1 C-2 C-4 D-1 D-2 D-3 D-4 D-5 D-6 D-7 B-3

Sections 1-16 of system

regulations [45 C.F.R.]

307.10(b)(1)

307.10(b)(2)

307.10(b)(4)

307.10(b)(3)

307.10(b)(5)

307.10(b)(7)

307.10(b)(6)

307.10(b)(8)

307.10(b)(9)

307.10(b)(11)

307.10(b)(10)

307.10(b)(12)

307.10(b)(14)

307.10(b)(13)

307.10(b)(15)

307.10(b)(16)

Page 22 GAO/AIMD-98-134 Child Support Systems Certification
Appendix III 

Comparison of Regulations to OCSE’s

Certification Objectives for Child Support

Enforcement Systems

Child Support Systems Certification Objectives (A-H)

D-8 D-9 D-10 E-1 E-2 E-3 E-4 E-5 E-6 E-9 E-7 E-8 E-10 E-11 F-2 F-1 F-5 G-2 F-3 F-6 G-1 G-3 G-4 G-5 H-1 H-2 H-3 H-4 H-5 F-4

Note: The shaded boxes in the chart indicate that the identified certification objective addresses

part, or all, of the specified component of the child support enforcement system regulations in 45

C.F.R. 307.10 (b). Collectively, the certification objectives address all components of the system

regulations.

Source: GAO analysis of the regulations in appendix I and the certification objectives in appendix

II.

Page 23 GAO/AIMD-98-134 Child Support Systems Certification
Appendix IV 

Comments From the Department of Health

and Human Services

Page 24 GAO/AIMD-98-134 Child Support Systems Certification
Appendix IV 

Comments From the Department of Health

and Human Services

Page 25 GAO/AIMD-98-134 Child Support Systems Certification
Appendix IV 

Comments From the Department of Health

and Human Services

Page 26 GAO/AIMD-98-134 Child Support Systems Certification
Appendix V 

Major Contributors to This Report

Accounting and

Information

Management Division,

Washington, D.C.

Mark E. Heatwole, Senior Assistant Director

Norman F. Heyl, Business Process Analyst

Anh Q. Le, Information Systems Analyst

Letitia Downer, Intern

Michael P. Fruitman, Communications Analyst

Atlanta Regional

Office

Amanda C. Gill, Analyst In Charge

Cynthia J. Scott, Evaluator

Office of General

Counsel

Edda Emmanuelli-Perez, Senior Attorney

Page 27 GAO/AIMD-98-134 Child Support Systems Certification
Related GAO Products

Child Support Enforcement: Privatization: Challenges in Ensuring

Accountability for Program Results (GAO/T-HEHS-98-22, Nov. 4, 1997).

Child Support Enforcement: Leadership Essential to Implementing

Effective Automated Systems (GAO/T-AIMD-97-162, Sept. 10, 1997).

Child Support Enforcement: Strong Leadership Required to Maximize

Benefits of Automated Systems (GAO/AIMD-97-72, June 30, 1997).

Child Support Enforcement: Early Results on Comparability of Privatized

and Public Offices (GAO/HEHS-97-4, Dec. 16, 1996).

Child Support Enforcement: Reorienting Management Toward Achieving

Better Program Results (GAO/HEHS/GGD-97-14, Oct. 25, 1996).

Child Support Enforcement: States’ Experience with Private Agencies’

Collection of Support Payments (GAO/HEHS-97-11, Oct. 23, 1996).

Child Support Enforcement: States and Localities Move to Privatized

Services (GAO/HEHS-96-43FS, Nov. 20, 1995).

Child Support Enforcement: Opportunity to Reduce Federal and State

Costs (GAO/T-HEHS-95-181, June 13, 1995).

(511240) Page 28 GAO/AIMD-98-134 Child Support Systems Certification
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