. .

Department of Health and Human Servces 

OFFICE OF 

INSPECTOR GENERA 

CHILD SUPPORT FOR CHILDREN IN IVFOSTER CARE 

Richard P. Kusserow 

INSPECfOR GENERA 

MAY 199 
. .

l '


li;:!.I 'lm OFFCE OF INSPECfOR GEN 

The miion of the Offce of Inpetor General (OIG), as mandate by Public Law 95-452, as 

amended, is to protect the integrty of the Department of Health and Human Servce' (HS) . 

programs as well as the health and welfare of beneficiaries served by those program. 

statutory miion is carred out through a nationwide network of audits, investigations, and 

Th. 

inpections conducted by three OIG operating components: the Offce of Audit Servce, the 

Offce of Investigations, and the Offce of Evaluation and Inpections. The OIG also inorm 

the Secretary of HHS of program, ' and management problems, and recmmends courses to 

correct them. 

OFFCE OF AUDIT SERVICE 

The OIG's Offce of Audit Servce (OAS) provides all auditing servce for HHS, either by 

conducting audits with its own audit resource or by overseeing audit work done by others. . 

Audits examine the performance of HHS programs and/or its grantee and contractors in 

carrg out their respetive responsibilties and are intended to provide independent 

asesments of HHS programs and operations in order to reduce waste, abuse, and 

mismanagement and to promote ecnomy and effciency throughout the Department. 

OFFCE OF INGATIONS 

The OIG's Offce of Investigations (01) conducts criminal, civil, and admitrative. 

investigations of allegations of wrongdoing in HHS programs or to HHS beneficiaries and of 

unjust enrchment by providers. The investigative effort of 01 lead to crial convictions, 

administrative sanctions, or civ money penalties. The 01 also oversee State Medicaid fraud 

control units which investigate and prosecute fraud and patient abuse in the Medicaid program. 

OFFCE OF EVALUATION AN INSPECTONS 

The OIG's Offce of Evaluation and Inpections (OEI) conducts short-term management and 

program evaluations (called' inspections) that focus on isues of concern to the Departent, 

the Congres, and the public. The fidings and recmmendations contained in these inpection 

report generate rapid, accurate, and up-to-date information on the effciency, wlnerabilty, 

and effectivenes of departmental programs.


OEI's Atlanta Regional Offce staff prepared thi report under the direction of Jese 

Flowers, Regional Inpector General and Chrstopher Koehler, Deputy Regional Inpetor 

General. Pricipal OEI staff included: 

Atlanta Region Heaquars 

Ron Kali, Project Leader Susan Hardwick 

Maureen Witce, Lead Analyst Penny Thompson 

Wm. Mark Krhat Paula Bowker 

Jean Dufresne 
. 

Department of Health and Human Servces 

OFFICE OF INSPECTOR GENERA 

CHILD SUPPORT FOR CHILDREN IN IVFOSTER CARE 

"'''c.. 

Richard P. Kusserow 

OEI-091-O530 
EXECUTIVE SUMMARY 

PUR 

To determine the extent States collected child support from biological parents of 

chidren in Title IV-E funded foster care as required by the 1984 Chid Support 

Amendment Act. 

BACKGROUN 

Foster care is temporary removal of a chitd to live with someone other than a parent 

durig a time of crisis. Title IV-E Foster Care applies only to children who are or 

would be eligible for assistance from the Aid to Families with Dependent Children

(AFC) program if they were stil in the home of their birth parents. In Fiscal Year 

(FY) 1986 there were an estimated 110,749 children in IV-E Foster Care. By FY 1990 

the number had swelled to an estimated 173 152, representing a 56 percent increase in 

the 4-year period. 

The 1984 Child Support Amendment Act required State Title IV-D Child Support 

agencies to collect chid support from biologica parents on behalf of chidren receivig 

foster care maintenance payments under Title IV-E Foster Care ''where appropriate. 

MEODOLOY 

In conducting the study, we randomly selected eight States. Within each State, we 

selected 40 cases of children who were receivig IV-E Foster Care funds for a total of 

320 cases. We also intervewed State and local administrators of foster care and chid 

support programs. We conducted our review between February and May 1991. 

FIINGS 

Few chid support collecons are made on behal of Foster Cae chidren 

Collections are being made on behalf of 5.9 percent of foster care children in our 

sample. 

Few foster cae caes are referred to Chd Support agencies for possible collecons 

lV-D Child Support records exist on just 22 percent of parents of sampled IVFoster Care children. No records existed at IV-D Child Support agencies for 78 

percent of the parents of children in lV-E Foster Care. 
Empha on collecg chid support is low 

Policies are vague for when to intiate collections. Coordination between IV-E Foster Care and IV-D Chd Support agencies is lited. 

Efece referr 

in collecg chid support by Foster Cae agencies to Chd Support agencies improve succ

Chid support collections are low natiQnally, but a few localities have developed effective referral practices resulting in collections on behalf of 48 percent of IVFoster Care children. 

REMMATIONS 

Recmmendation 1. As a condition of receivig Federal matching funds for foster care admistration under Title IV- , the Administration for Children and Familes (ACF) should require States to develop and implement: 

criteria and procedures to assure that Foster Care agencies refer all 

appropriate IV-E Foster Care cases to IV-D Chid Support Enforcement agencies for establishing child support orders and collecting chid support; and 

Memorandum of Understanding between IV-E Foster Care agencies and IV-D Child Support agencies with respect to determinig "appropriate" cases for referral, and gathering and exchanging data. 

Recmmendation 2. In support of such State initiatives, ACF should provide guidance and plans for coordination between the IV-E Foster Care and IV-D Child Support Enforcement agencies. 

Implementation of these recommendations wil improve the well being of foster care 

children. They can lead to establishing paternity and locating absent parents, as well as establishing support orders with both cash and medical benefits for the chid. 

may encourage some parents to become more responsible for their chidren -- Ths

consistent with the Secretary s theme of "personal responsibility. 

Initiatives by ACF could substantially increase child support collections from biological 

parents of IV-E Foster Care children. It is not possible to calculate with great precision how much additional savings would accrue. However, we conservatively estimate up to 74 milion dollars could have been collected in FY 1990. Additionally, the amount will increase each year as the number of children in IV-E Foster Care rises. Such collections wil offset Federal and State tax dollars spent for care and 

maintenance of IV-E Foster Care children. Federal and State governments could achieve additional savings by requiring parental medical support of their children, thus offsetting expenditures on Medicaid. 
Recmmendation 3. The ACF should ensure that the Federal share of chid support dollars collcted on behalf of IV-E Foster Care chidren is correctly distnouted to the IV-E Foster Cae program rather than the IV-A AFDC program. 

COMM 

The ACF agreed with our recommendations and has intiated steps to improve 

coordination between child support and foster care agencies. The ACF has also 

initiated steps to remedy inappropriate distribution of child support dollars. Likewise 

the Assistant Secretary for Management and Budget (ASMB) concurred with our 

recommendations on both programmatic and financial grounds. 

The Assistant Secretary for Plannig and Evaluation (ASPE) agreed that more could be done to coordinate the provision of IV-D Child Support for IV-E Foster Care. The ASPE noted that better communication and coordination is needed and should be 

encouraged, but que tioned the extent that child support can or should be pursued. 

We agree that child support should only be pursued in "appropriate" cases. However we continue to believe that the majority of children in foster care can benefit from 

IV-D Child Support servces, such as paternity establishment and locating absent parents. We hope our report increases the awareness of a need to integrate these servces. Many of the issues and problems cited by ASPE will be solved as States gain 

more experience in collecting child support on behalf of foster care children. The 

effective practice" sites which we examined demonstrate that this can happen. 

We thank ACF, ASMB and ASPE who commented on the report. We present the 

full text of comments in appendix E. 

iij 
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . 

. . . . . . . .. . . . . . . . . . . . . . .. .. . . .. 

TABLE OF CONTENTS 

EXCU SUMy 

INODUCTON. . 

FIINGS. . 

Few Child Support Collections Are Made 

On Behalf Of Foster Care Children. . . . . . . . . . . . . . . . . . 

Few Foster Care Cases Are Referred To


Child Support Agencies For Possib1e Collections


Emphasis On Collecting Child Support Is Low . . . . . . . . . 

Effective Referrals Improve Success In 

Collecting Child Support. . . . . 

RE(X A110NS 

.................................... 12


Discussion. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 

Agency Comments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 

ENNOTE. . 

APPENICE 

A: Title IV-E Foster Care Process. . . . . . . . . . . . . . . . . . . . . . .. AB: Information Collection Methods. . . . . . . . . . . . . . . . . . . . . . .. BC: Description Of "Effective Practice" Sites . . . . . . . . . . . . . . . " CD: Projected Child Support Collections . . . . . . . . . . . . . . . . . . " DE: Comments on Draft Report . . . . . . . . . . . . . . . . . . . . . . . . .. E-
INTRODUCTION


PUROS 

To determne the extent States collected child support from biological parents of children in Title IV-E funded foster care as required by the 1984 Chid Support Amendment Act. 

BACKGROUN 

Title IV-E Foster Cae 

Foster care is the temporary removal of a child to live with 

parent (or usual caretaker) during a time of someone other than a

crisis. The crisis may be caused by abuse or neglect of the child. 

The Adoption Assistance and Child Welfare Act of 

the Foster Care program for children from the 1980 transferred admiistration of 

Children (AFDC) program (Title IV- Aid to Families with Dependent

A of the Social Security Act) to the new Title IV-E Foster Care program. Title IV-E Foster Care applies only to chidren who are or would be eligible for AFDC if they were stil in the home of their birth parents. 

Servces provided by the IV-E Foster Care agencies are shown below. 

IV-E FOST CAR ACT 

o Make Reaonable Efort to Prevent Remov 

o IT Unsuccful, Remove Chd from an Unse Home 

a Place Chd in Appropriate Foster Cae 

o Determe Eligibilty for IVo Refer Parent(s) and Chd to Servce 

o Plan for the Long Term Welfare of Chd 

In Fiscal Year (FY) 1986, an estimated 110 749 children were in IV- FY 1990 the number had swelled to an estimated 173 E Foster Care. By

152, representing a 56 percent increase in 4 years. . 
Title IV-D Chd Support Enorcement 

The Chid Support Act of 1975 added Title IV-D to the Social Security Act. The goals of Title IV-D are to ensure that parents support their children to the extent possible 

family (parental) responsibilty increases, and the cost of welfare to taxayers decreases. The Act established child support enforcement agencies to help in obtaining support orders and to collect child support monies to reduce Federal public 

assistance expenditures. Servces provided by the IV-D Child Support agencies are shown below. 

IV- CH SUPPORT SERVICE 

Lote Parents 

Establih Paternty 

Establih a Support Order 

Receive and Distribute Collecons 

Establihig Chd Support Collecons for Foster Cae Chdren 

Section 11 of the 1984 Child Support Amendment Act required States to secure and 

enforce child support collections on behalf of children receiving foster care 

maintenance payments under IV-E Foster Care ' 'where appropriate. 

The 1984 amendment required States to follow the same procedures for securing and 

enforcing support orders for appropriate children under IV-E Foster Care as they do for AFDC children. In January of 1985, States were required to amend their Title IV-E State Plans to insure cooperative efforts with child support agencies. 

The IV-D Child Support agencies are responsible for collecting and distributing 

payments from absent parents. An "absent parent" is a biological parent not residing in the same home as a child. 
Unle most chidren in the AFC program who traditionally have one absent parent, 

chidren in IV-E Foster Care have two absent 

biological parents and may receive IVChild Support collections from both. 

We found, based on our case record review 

that IV-E Foster Care children need chid 

support servces. These chidren are young. 

More than two-thirds (67 percent) are under 10 years of age. Although foster care is 

intended to be "temporary" removal from the home, more than three-quarters of the IV- Foster Care children have been in foster care 

for more than a year. Ten percent of the 

children have been in foster care for over five 

years. 

Appendix A provides more detailed 

information about the process of placing a 

child in IV-E Foster Care and how the child 

is linked to IV-D Child Support servces. 

Foster Care Children 

Have Two Absent Parents 

Foster Care Child 

Biological Biological Father Mother 

dmini terig the Chd Support and Foster Cae Progr 

At the Federal level, HHS operates both programs within the newly-created Administration for Children and Famies (ACF). 

Care program is located in the Administration for Children Within ACF, the Title IV-E Foster

(ACYF), and the Title IV- , Youth and Famiies D Chid Support Enforcement program is in the Offce of Child Support Enforcement (OCSE). 

Each State is responsible for establishing and operating the IVIV-D Child Support programs under E Foster Care and

provisions of Federal statutes and HHS regulations. 

MEODOLOY 

We randomly selected eight States with probabilty proportional to size. The average 

number of children in the IV-E Foster Care program in FY 1989 determned The eight States represent approximately 64 percent of children in IV­ siz.

in FY 1989. The eight States were: California E Foster Care

Kentucky, Michigan and Pennsylvania. We conducted our review between February , New York, Minnesota, Arona, ilinois

and May 1991. 
With each State, we selected 40 caes of children who were receivig IV- Care funds at the time of our review E Foster , for a total of 320 caes. We reviewed records for each case at both the foster care agencies and IVD Chd Support agencies. 

Using a standardized discussion gude, we intervewed local and State foster care and child support program representatives to gather facts and data. We also intervewed 

the Federal Regional Offce IV-E Foster Care and IV- representing States in the sample. D Child Support staff

Appendix B describes information collection 


methods in further detail. 
FINDINGS 

FEW CH SUPPORT COlLONS AR MAE CAR CHRE ON BEH OF

Collecons Were Made On Behal Of 5. 

Saple 9 Percent Of Foster Cae Chdren In Ou 

A case review tracing the biological parents of the sampled children in IVCare revealed very few pay child support. Only 19 of the 320 children sampled had E Foster any child support colJections made on their behalf. 

On 11.6 Percent Of Sampled Chdren In Foster Cae Were Included In A Chd Support Order 

A child support order must be established to 

IV-E Foster Care children. Yet very few childcolJect child support from parents of 

Foster Care children. Only 37 of the 320 sampled children were included in an
 support orders are established for IVestablished child support order. 

AGENQE FOR 

FEW FOST CAR 

POSSmLE COLLCTONS 

CASES AR RE TO CH SUPPORT

No Recrds Exted At Chd Support Agencies For 78 Percent Of The Parents Of Chdren In IV-E Foster Cae 

Records existed at IV-D Child Support agencies on just 22 percent of parents of sampled IV-E Foster Care children. I The majority of the sampled children in Foster Care lived with one or both of their parents before they were placed in foster care. 

Further, most have permanency plans to return the children to the home of their parent(s). Yet, few foster care agencies have effective policies or procedures to refer 

cases to a IV-D Child Support agency. 

Referr Are Crtica To Intiate The Chd Support Collecon Proc 

When the IV-D Child Support agencies we visited receive a referral 

, they tyically provide all servces to IV-E Foster Care cases. Yet the clear majority of sampled children in IV- , because referrals are not made

opportunity to receive IV- E Foster Care are being deprived the D Chid Support servces they are entitled to receive. 
For IV-E Foster Care children not referred, IV-D Chid Support agencies cannot 

&tablih paternty without legally-established paternty, a 
 ineritance rights or chid cannot obtain insurance rights. Also possibly vital information regarding genetically-lined medical problems wi not be known. 

Lote the absnt parent: without the absent parent(s) being located cannot form social relationships with the parent(s). , the chid

parent or a close relative of an absent parent may be able to assume custody of In some cases an absent

the foster care child. 

&tablih a support order and collec chid support payments: when certain criteria are met, administering agencies may save portions of chid payments collected from the parents for a child. The child support payments from support

parents may also be used to provide amenities such as clothing or enrollment in a 

class for a child while in foster care. The support order and established 

pattern may continue after a child collection leaves IV-E Foster Care.


EMHAIS ON COLLCTG CH SUPPORT IS LOW 

Policies For When To Intiate 

Collecons Are Vague


Federal policies place no emphasis or focus on collectig child support for Foster Care 

children 

Until an April 1991 reorganition of HHS, the IV-E Foster Care and IV- Support programs were operated by two separate D Child

Development Servces (OHDS) administered the IV- divisions. The Offce of Human

Family Support Administration (FSA) administered the IV­ E Foster Care program and the

No one was directly responsible for insuring coordination between both programs. D Child Support program.

Although extensive Federal guidance requires the IVregularly update cases to IV- A AFDC program to refer and D Child Support agencies OHDS and FSA concernig child support , the only action issued from collections on behalf of IV- children was a "Memorandum of Understanding E Foster Care

" signed in May of memorandum only established procedures for reporting dollar amounts of collections 1986. The

between OHDS and FSA. 

Within OHDS and FSA regional offces isolated initiatives have occurred since 1986 to increase reported collections on behalf of IV-E Foster Care children. However uniform national strategy addresses this issue. , no 

The separation of the IV-E Foster Care and IV-D Child Support at the Federal level is mirrored at State and local levels. In virtually every 

analysis State or county included in our , the two programs were administratively isolated from each other. 
, 

The only strong Federal focus is on compliance in reporting. Therefore 

collections on behalf of IV- , chid support E Foster Care chidren is often little more than a bookkeeping function. 

Criteria concerning "where appropriate" are inadequate or non-extent 

No Federal directive defines '

'where appropriate " yet the law uses the phrase to lit conditions or circumstances where child support should be pursued. Only one State 

policy uses the term. This State policy 

are referred. Seven of the eight defies "appropriate" so broadly that no cases States have no wrtten criteria as to when chid support should or should not be pursued. Without criteria 

little meaning to program staff. 'where appropriate" has 

Cordiation Between Foster Cae And Chd Support Agencies Is Lited 

Mission and roles are not clearly understood or accepted 

Few staff within IVunderstanding of their role in interrelating their different programs€

E Foster Care and IV-D Child Support agencies had a clear€

servces can complement each other. The agencies , or how their€

regular meetings. hold no formal cross trainng or€

The focus and approach of IVconsiderably. Foster care staff are oriented to and talk in terms of an individual chid. E Foster Care and IV-D Child Support agencies varied

They form interpersonal relationships with the familes they serve. On the other hand€

most IV-D Child Support staff view themselves as adversaries of "€

The child support staff tend to be "bottom line oriented. absent parents.€

Some foster care workers regard gatherig information for a referral to IV- Support agencies as "paper pushing, D Chid " or as "not my job. opinions that families of IV- " These workers expressed E Foster Care children are "too poor to pay. unaware of the range of servces IV- " They are D Child Support agencies can provide. Further they are unaware of or underestimate the ability that Child Support 

demonstrated for collecting money in economically-similar AFDC agencies have 

cases. 

Some foster care workers philosophically oppose pursuing child support. Some dread€

an unpleasant confontation with the parent(s). Others 

child support wil be may believe that enforcing€ detriental to the parent!child relationship. They do not believe that child support serves to stabilize the family unit and help insure its future integrty. 

Infonnalion is not shared or exchanged 

If a case is not referred to the IV-D Child Support agency, and IV- workers need to establish paternity or locate an absent parent(s) they must do this E Foster Care

themse)ves. Foster care workers are not trained in this work nor are they given €

to the information resources of IV-D Child Support agencies. access 
.

When a referral is made by a IV-E Foster Care agency, inormation necessary for pursuig chid support is seldom given. To support a IV-D Chd begi the process of obtaing chid Support agency must obtain tiely, accurate

inormation concernng the family. The inormation , and complete

, such as social security numbers or employment information, is often available in IV-E Foster Care fies by foster care workers , or is known , but it is not shared in the referral. As a result, IV- Support staff must gather inormation that a IV-E Foster Care agency already has. D Chid

Although foster care workers track a family 

understand the importance of communicating status s status, few foster care workers

agency. For example changes to a IV-D Chid Support , as part of the servce to a family, a foster care worker might learn that a previously incarcerated father has been released and become employed. 

Without the IV-E Foster Care worker promptly agency, the IV-D agency must learn this critical information independently. Likewise inormng the IV-D Child Support

IV-D Child Support workers may obtain information on the family that foster care 

workers need. 

Almost 60 percent of the cases we reviewed had discrepancies between the two 

agencies' files. Some discrepancies were as uncomplicated as a current address. 

Others had more serious ramifcations. For example

stated the father was " , one IV-E Foster Care cae fie unknown." The IV-D Child Support' agency, however identifed the father and had an open case on , had him. In another case Care case file stated the father was " , the IV-E Foster unkown" and all parental rights involuntariy termnated. The IV-D Child Support agency, on the other hand father and was on the brink of servng the man with a court order for child support , had identifed the

payments. 

Such lack of communication and sharing of information may cause problems with the 

therapeutic relationship a social worker is building with a family. In one case 

parent and foster care worker established suffcient trust to allow a child to return , the

home. However, at about the same time, a IV-D Child Support agent served a summons to bring the parent to court. The parent s anger at the " damaged the reunification process. government
Nineteen percent of the total child suppon dollars collected in our sample for Foster Care 

chilen were mistakenly distruted to the AFDC program 

Of the $22 524 collected in the. year prior to our review on behalf of the sampled IVFoster Care children, $4 260 (19 percent) was not distributed to the IV- agency to offset maintenance payments for the children. E Foster Care

Many of the sampled children in IV-E Foster Care were included in active AFDC 

grants before the time of removal from their home to a foster care placement. In 

some instances, AFDC agencies made a referral for IV-D Chid Support servces whie a chid was stil at home. In such instances, IV-D Child Support agencies had the case classifed as an "AFDC case." In some localities, communications were so ineffective that the Child Support agency was not notified when a child was removed from an AFDC grant and placed in IV-E Foster Care. 

No one had "reclassified" 15 of the 640 cases (2.3 percent) for parents of our sample. These 15 chidren in cases were classified as IV-A AFDC cases rather than IV- Foster Care cases at the IV-D Child Support agencies. One State had no system to

notif the IV-D Child Support agency when an AFDC child enters IVIn other places E Foster Care. , inadequate systems allowed cases to slip through improperly classifed. In these situations any child support collections made on behalf of IVchidren were mistakenly distributed to the IV- E Foster Care

were used to offset Federal and State IV- A AFC program. These collections A AFDC assistance payments rather than IV-E Foster Care maintenance payments. 

SUPPORT 

EFCT REFE IMROVE SUCC IN COlLCTG

Within our national review, a few IV-D Child Support programs dilgently pursue both parents of aIJ cases received. Yet these programs are limited by 

made or the sketchy information provided in the referrals. IV- few referrals being

D Child Support agencies sometimes pursued cases of parents of children in IV-E Foster Care without the knowledge of the IV"E agency. 

While collections are low nationally, we found a few localities exceed the national 

average making collections on behalf of IV-E Foster Care children. These programs have demonstrated the abilty to 

refer most parents of IV-E Foster Care children to a IV-D Child Support agency, 

establish more support orders, and 

collect more child support on behalf of rV-E children.€
, 

Although such localities were outside the scope of our sample 

viewed as "effectve practce , we visited two that we " sites - Lancater County, Pennsylvana and Olmstead County, Miesota.2 These counties have taken the intiative to develop programs for 

effectively referrng cases and utilg foster care workers to collect and exchange necessary inormation to pursue chid support. In these 

received chid support collections on behalf of 48 percent of children. counties IV-E Foster Care

Based on a case record review, the following chart compares national performance averages to the performance average found at the " 

effective practice" sites. 

IV- D Child Support For 

IV - E Foer Care Children 

70% Ca88 For Mothers Ca$88 For Fahers 

70% 

80% &8% 

80% 

50% 

50% 

40% 38% 42% 

30% 35% 40% 

30% 

1&% 1:% 20% 

10% 

Supprt Colle 

Order. Ion. Ro",. Support CoI18.tlono 81 IV.O Orer. 

Naiona Iwr8Q8 B8t PraclcAlrag. 

As the chart shows effective practice" sites consider a higher percentage of both mothers and fathers able to support their children. Although " 

refer just under twce the percentage of cases to the IV- effective practice" sites

our national sample D agency as did the sites in , they issue orders on five times as many mothers and almost four times as many fathers. The "effective practice" sites also collect on a higher ratio of support orders when compared to our national sample. 
We attributed the signcat collections at the " priciples, effective practice" sites to the followig

Considerig Chd Support a Priority


Havig Efece Pattern of Communcation Progr Between IV-E and IVBeing More Awae of Both Biologica Parents' Income Source 

Havig One Person or Ofce to Cordiate IV-E Foster Cae Referr 

Including Medca Support in More Support Orders 

Reportg Collecons to the IV-E Foster Cae Agency 

Appendix C highlights program operations in Lancaster and Olmstead counties. 

A recent study completed by the Region II ACF also shows a high level of collections is possible. The study examined child support collections for children in IV-€

Care in New York City. The study showed many of the same problems we E Foster 

encountered concernng the agencies' failure to exchange important inormation and inadequate policies concernng referrals. Over 70 percent of referrals to New York€

City' s Child Support agency had "incomplete data and/or documents percent had " " and almost 20 inconsistent or conflcting data. 

The ACF study showed, despite the problems, 42 percent of the cases opened at the IV-D Child Support agency had active support orders. Of these 

receivig monthly , 62 percent were collections. Of the nonmade in the past year payig cases 80 percent had a tax offset , so at least some money was collected. Many of the cases without active support orders were improperly referred or contained outdated 

information. 
RECOMMENDATIONS 

Recmmendation #1 

As a condition of receiving Federal matching funds for Foster Care administration 

under Title IV- , ACF should require States to develop and implement: 

criteria and procedures to assure that Foster Care agencies refer all appropriate 

IV-E Foster Care caes to IV-D Child Support Enforcement agencies for establishing child support orders and collecting child support; and 

a Memorandum of Understanding between IV-E Foster Care agencies and IV- Child Support Enforcement agencies with respect to determning "appropriate cases for referral, and gathering and exchanging data. 

Recmmendation #2 

In support of such State initiatives, ACF should provide guidance and plans for 

coordinating the IV-E Foster Care and IV-D Child Support Enforcement programs. ACF could: 

Develop training and technical assistance modules to assist States in implementing 

new policies and procedures on child support for children in IV-E Foster Care. 

Publish a compendium periodically of the techniques used by successful States in 

increasing their collections. 

Publish periodic report showing statistics nationally and by State on the IV- Foster Care and lV-D Child Support initiative. 

- Direct regional offces of ACF to monitor States in their region using performance 

standards and monitoring mechanisms. 

As discussed below, we believe these first two recommendations will increase: the 

number of support orders; the number of collections; the average amount collected per case; and the number of children receiving medical support. 

Recmmendation #3 

The ACF should ensure that the Federal share of child support dollars collected on 

behalf of IV-E Foster Care children is correctly distributed to the IV-E Foster care program rather than the IV-A AFDC program. 
DISCUSSION 

We found few foster care caes are referred for chid support servces. When referrals 

are not made, the clear majority of sampled foster care children are being deprived of an opportnity to receive servces they are entitled to receive. IV­ servces can be beneficial to a child. For example D Chid Support child can obtain inheritance rights or insurance rights. Child support agencies , when paternity is established a

location procedures can assist foster care agencies in dilgently searching for absent 

parents. When an absent parent is located 

appropriate social relationships with the parent. In some cases , a foster care chid may be able to fonn

close relative of an absent parent may be able to assume custody of a foster care an absent parent or€

child. When a support order is established and child support collections are being made, administerig agencies may, when certain conditions are met, use a the payments to provide amenities for a child while in foster care. portion of may also provide important medical insurance for a child. The support order 

When parents cooperate with child support agencies and assume fiancial 

responsibilty for their chid while in foster care €

building parental responsibility. it can be an important step toward 

A Federal effort is needed to insure that child support servces are provided to benefit 

children in IV­E Foster Care and to increase 

Such action clearly responds to the Secretary child support collections on their behalf. 

responsibilty toward their children and the community by making initiative regarding parental

parents responsible€ for their chidren s financial support. The recent HHS reorganiztion integrating OHDS (responsible for the Title IV-E Foster Care program) and FSA (responsible for the Title IV-D Child Support program) into the Administration for Children and Famies provides an opportunity to improve the management of IV- for children in IV-E Foster Care. DChid Support 

Based on Our representative sample, we believe a Federal initiative could increase IV-D Child Support collections on behalf of IVtax dollars spent for care and maintenance of IV­E Foster Care children thus offsetting

possible to calculate with great precision how much additional savings would accrue. E Foster Care children. It is not

The final result wi depend on many factors including 

- the number of children in IV-E Foster Care 

- the percentage of support orders issued on behalf of IVE Foster Care children 

- the amount of support ordered 

- the amount actually collected, and 

- the administrative cost of collecting €

child support. 
However, we believe our proposals would increase the number of support orders and 

the number and amount of collectons. The simplifed ilustration below shows possible estimated collectons if the percentage of children for whom collections are€

made were increased to various levels.€

Posible Collecons at Varous Rates 

Percent Of Chldren 

For Whom Collections 

Are Made 

(in millions)


Year 

Collections 

(FY 1990)


$15 

$30 

$45 

$60 

$74 

Net Federal


Share of 

Collections 

$4. 

$9. 

$13. 

$18. 

$22. 

Estimated 

Federal 

Savigs 

$2. 

$4. 

$6. 

$9. 

$11. 

(Appendix D provides details concernng these estimated collections. 

We believe our estimate of possible collections is conservative. The estimate supposes only 29 percent of all child support money ordered will be collected. In our "

practice effective " sites, 80 percent of the money parents are ordered to pay is collected. A study of recent IV-E Foster Care referrals for child support enforcement in New York 

City showed over 60 percent of the open cases had current support payments. 

Also, Federal and State governments could achieve additional savigs by 

biological parents of IV- requirig E Foster Care chidren to provide medical support thereby offsetting Medicaid expenditures. The average Medicaid costs per chid in 1990 

$811 per year.4 We found that in the two " 

effective practice" sites 42 percent of the

were

children received medical support from a parent, covering some of the costs. practice could be applied in other States and counties resulting Ths

in substantial savigs nationally. 

Additionally, children who are removed from IV-E Foster Care to the custody of absent parents or their families represent Federal and State savings to the IVCare program and a major benefit to a child. E Foster

Further, 19 percent of the total child support dollars collected for our sampled IVFoster Care children was erroneously distributed to the IV-A AFDC program instead of the IV-E program. A one-time correction of the "misclassification" would transfer an additional $2.5 milion to the IV-E program. (See appendix D for details regarding this estimated transfer.)€
._ ..

AGENCY COMM 

We thank the Admstration for Chdren and Familes (ACF), the Assistant Secretary for Management and Budget (ASMB) and the Assistant Secretary for Plannng and 

Evaluation (ASPE) who commented on the draft report. Their comments and our responses are summarized below. Appendix E shows the full text of the comments 

provided by ACF, ASMB and ASPE. 

ACF Comments 

The Admiistration for Chidren and Families (ACF) agreed with our recommendations to improve coordination between the child support and foster care 

programs. The ACF plans, through its regional offces, to examine the status of coordination systems in each State. The ACF will include the issue of coordination in its Joint Planning Guidance to be issued in fiscal year 1992. The ACF has also included the issue as part of their 1992 strategic 

Support Enforcement (OCSE) and the Administration for Children€ plan. Further, the Offce of Chid

Families have already begun a joint initiative to improve coordination. , Youth and

OCSE audits will more closely monitor the distribution of child support collections. Additionally,

Finally, OCSE will issue a letter to the States alerting them of the problem of€

incorrect distribution.€

OIG Response 

The ACF planned actions should improve communication and coordination between 

foster care and child support agencies and remedy inappropriate distribution of chid 

support dollars collected on behalf of children in IV-E Foster Care. These should enhance parental responsibilty and directly benefit children in foster care. actions

ASMB Comments 

The Assistant Secretary for Management and Budget (ASMB) concurred with the 

recommendations of the report from both a programmatic and fiancial 

The ASMB agreed that pursuit of child support for lV- viewpoint. 

E Foster Care chidren holds the promise of both greater parental responsibility and direct benefits to the chid.€

The ASMB expressed some concern over different objectives of foster care and child 

support staff at the Federal level.€

OIG Response 

Regarding ASMB's concern over the diferent objectives of child support and foster€ care staff, we believe that as ACF implements its plan for better coordination and€

monitorig the differences should be minimized. 
ASPE Comments€

The Assistant Secretary for Planning and Evaluation (ASPE) agreed that more 

coordination between foster care and chid support is needed. However€

concerns about 1) the conflctig objectives of child support and famy reunication , ASPE raised

2) whether our savings projections included the cost of pursuing child support 

how well actual collections compared to our projections. , and 3) 

OIG Response 

1) Regarding ASPE's concern about collecting child support for children in IV- Foster Care, we agree that chid support should only be pursued in " cases. However appropriate , we continue to believe that the majority of chidren in foster care can benefit from IV-D Child Support servces, such as paternity establishment and locating absent parents. We hope our report increases the awareness of a need to integrate these servces. Many of the issues and problems cited by ASPE will be solved as States gain more experience in collecting child support on behalf of foster care 

children. The "effective practice" sites which we examined demonstrate that this can happen. 

2) The ASPE commented that our projected 

savings did not include the cost of pursuing child support. We agree. We did not adjust our 

account for the Federal share of State administrative cost estimate of savigs to

determnig the because of diffculties in marginal cost of increasing collections. However ASPE' s concerns we reduced the estimated savings by 50 percent to incorporate , in response to

consideration for the administrative cost of increasing collections. 

3) The ASPE commented that in fiscal year 1990 OCSE collected $10.3 behalf of children in IV-E Foster Care miion on , but we projected collections of $8. Our estimates were based on a random sample of foster care children. The variation 3 mion.

between ours and OCSE estimates are probably the result of sampling error.€
ENNOTE 

Some States have an alternate system of obtaing chid support foster care. The cases usually are run through juvenile for chidren in

court and tyically include a provision for child support as part of the original removal order. Juvenie 

do not use Federal child support guidelines when court establishing orders have collection powers (such as wage withholding) available to IV­ , nor do they

Support agencies. Of the few cases D Chld

in our sample referred to these systems one had any collections. The total amount of these , only 

per year. collections amounted to $180 

We do not believe these two sites are the only " effective practice they necessarily "best" of all sites in the nation. " sites, nor are

study, Federal and State program administrators explicitly named these two Durig selection of cases for this

counties as "atyical" for their exceptionally high level of collections and 

practices. To learn what " unique atyical" practices might result in high collections repeated the case review process and accompanying structured intervews , we 

in these two counties. We reviewed "universe" data for these counties to verify the validity of the sample. 

Review of Child Su art Enforcement Title IV- Pro!!am Interface D and Foster Care Title IV- ew Yor Diane Schwart Willam Meltzer Jones. Administration for Children and Families (Region and Allen 

II). June, 1991. 

Medicaid 1990 figure Courtesy of Health Care Financing Administration 

of Data Management and Strategy, Offce of Program Systems , Bureau 

Medicaid Statistics. , Division of 
APPENDIX A€

TI IV- FOS CA PROC 

Afer a child is removed from a home - usually by the police or by child protection 

authorities - the chid is placed in some tye of emergency care. A remov order 

signed by a court and a more permanent place for the child is found. Some States 

and localities allow parents to volunta place their children in foster care. 

The preferred placement is in a "homelie" setting where a child will be cared for by 

foster pants. Usually foster parents are certifed volunteers who take chidren into 

their homes. The IV-E Foster Care program provides a Federal match (at the same 

rate as Medicaid) for States' expenses for foster care maitenance payments. These 

are costs directly related to care and lodging for eligible children. 

Local foster care agencies work with former cutodial parent(s) - usually the biological 

parent(s) who last had legal custody of a child - to develop a permanency plan. The 

permanency plan is a step-by-step action plan to determine what will happen with a 

child. In accordance with the Adoption Assistance and Child Welfare Act of 1980, the 

majority of permanency plans are designed to return a child to the former custodial 

parente s) as soon as possible. 

Occasionally, a foster care worker (or the parent) will determine that a chid can never 

return home. This determination is usually reached because the problems causing 

removal are so extreme or are insurmountable. For many such cases the permanency€

plan will be adoption.€

For adoption to take place, proper legal proceedings must terminate parenta rights of 

both parents. This termination can be voluntary or involuntary. If a parent is absent 

and their whereabouts are unknown, a "dilgent sech" must be made to satisfy legal 

requirements before a child ca be eligible for adoption. 

A child' s case must be reviewed every six months and the permanency plan updated. 

The family s progress towards improving the home situation is tracked by an assigned 

foster care case worker. In cases of voluntary placements, a child must be returned to 

the parent(s) upon his/her request. 

Coordination between IV-E Foster Care and IV-D Child Support programs begis 

with a referr from a foster care agency. The child support agency attempts to locte 

the absent parent(s). An "absent parent" is a biological parent not residing in the 

home the chid is in. Paternty wi be establihed if necessary. The child support 

agency will go through the court proceedings to establish a support order. A support 

order is an order issued by a court requiring the absent parent(s) to provide chid 

support. The agency will then collec monies from the absent parent(s) and ditribute 

them in accordance with the court s ruling and Federal regulations. 
APPENDIX B 

INRMTION COIL0N MEODS 

We analyzed a listing of Title IV-E Foster Care program population for each State in 

1989 to determine which States to include in our sample. We drew a two-stage cluster 

sample. First, we selected eight States at random with probabilty proportional to size. 

The average number of chidren in the IV-E Foster Care program in 1989 determed 

size." 

The selected States represented approximately 64 percent of the total average number 

of children in IV-E Foster Care in 1989. The eight States were: 

Arzona 

Californa 

Ilinois 

Kentucky 

Michigan 

Minesota 

New York 

Pennsylvania 

Second, we selected a sample of 320 IV-E Foster Care children. We randomly 

selected 40 children per State from the active lV-E Foster Care population. As 

necessary, we oversampled to compensate for cases which were not available at the 

time of our on-site visit (i.e., in court that day). The method of random sampling 

varied from State to State because of variations in administration and organition of 

lV-E Foster Care and IV-D Child Support programs in the sampled States. For State 

administered programs, we drew a random sample of all cases. In States where the 

IV-E Foster Care program is administered by counties, we selected two counties and 

drew a random sample of all cases within those counties. 

Once the cases were selected at lV-E Foster Care agencies, we gathered information 

on each case and the referral process via a uniform data gathering instrument. We 

gathered names, social security numbers, and other identifers, as available, on both 

parents and the IV-E Foster Care child. We then used these identiers at IV-D Child 

Support agencies to determine if the: 

Foster care agencies had referred a IV-E Foster Care case to IV-D Child Support 

agencies and the IV-D agencies had received it; 

IV-A AFDC agencies had referred a case to lV-D Child Support agencies on the 

parent(s) as an AFDC-eligible case; or€
IV-E Foster Care agencies had not referred the cae, but IV-D Chd Support agencies had been able to open a correctly classifed IV-E cae on the parent(s) anywy (Le., the IV-D Chd Support agents independently search cour records). 

In these instances IV-E Foster Care agencies are unaware of IV-D Chd Support agencies actions. 

When a IV-D Chid Support case corresponding to the IV-E Foster Care case was 

found, we checked the IV-D case to see if it was correctly identifed as a IV-E case (as opposed to a IV-A case) and if any collections were being distributed to the IVFoster Care program. 

We gathered additional facts and data by intervewing people most directly 

knowledgeable about the extent child support is collected on behalf of children in 

IV-E Foster Care. We used structured intervew guides. Offcials in the eight-State sample included: foster care case workers, eligibilty workers and their program managers; child support staff, supervsors and court offcers; State IV-E Foster Care€

and IV-D Child Support program managers and staff; and in the regions where the€

eight sample States are located, Federal IV-E and IV-D program managers and staff. 
APPENDIX C€

DESCRON OF "E PRACTCE" SIT 

Although their programs difer, Lancaster County, Pennsylvania and Olmstead County, 

Minnesota have developed successful programs, interrelating IV-E Foster Care and 

IV-D Child Support. 

Lacater County, Pennlva 

The philosophical orientation and program organiztion make Lancaster County, 

Pennsylvania an "effective practice" site. First, the belief permeating the system is 

parental responsibility, including financial responsibilty. 

County managers encourage foster care servce workers to think about chid support€

as part of overall therapy for a family. They gather necessary information on the chid€

and family and refer it to the fiscal offcer for eligibilty determination and possible€

child support. During all processes everyone assumes the parent(s) will shoulder some€

of the financial responsibilty for their child while in foster care. Program managers€

and staff believe that parents who are not asked to contribute will have a fiancial€ incentive not to strive for the return of their children. Parents must produce evidence€

that they are unable to financially support their child in order to be exempt from chid


support. 

In preparig the eligibility porton of a case, the fiscal offcer is also preparing the 

chid support case. The fiscal offcer does most of the routine work in preparig a 

case for the court to issue a support order. When necessary, two IV-D Chd Support 

offcers work with the fiscal offcer to faciltate the process. 

Lines of communication are smooth, with the fiscal offcer acting as a liaison between 

the IV-E and IV-D programs. The computer system also ties in IV-A AFDC records 

IV-D Child Support records and the IV-E Foster Care records, so all information is 

instantly exchanged. 

The fiscal offcer also monitors changes in family status. During a six-month eligibilty 

review, the foster care staff and fiscal offcer reassess every case for child support. 

The fiscal offcer also monitors collections on the computer, printing out weekly and 

monthly reports. Program and county managers also review the monthly printouts. 

C - 1€
APPENDIX D 

PROJE CH SUPORT COlL0NS 

The followig projections are based on the premise that our study sample represent 

tyical cases. Based on the current collection rate and amount, we estimated up to 

$74 million could have been collected in FY 1990 from parents of chidren in IVFoster Care if support orders were issued for 50 percent of the cases. 

To calculate this estimate, we weighted the 320 sampled cases to reflect the 

percentage of total number of children in IV-E Foster Care nationally. With these 

weights assigned , we recalculated the percentages of parents ordered to pay support 

and percentages of parents actually paying support. 

National &tiates 

Mothers Fathers Total 

Percent With Support 

Orders 11.0% 11. 

Amount Ordered 088 000 $22 755 000 $28 844 000 

Percent Payig Child 

Support 

Amount Collected $336 000 949 000 285 000 

. Due to the small number of orders and collecons and the wide range of amounts ordered 

and collected (collections ranged from $5 per month to $20 per month) the precion of thes 

estimates is low. 

From the estimate of collections, we project that approximately $255 miion might be 

available if every case had a support order and the entire amount of the average 

current order was collected. 

Acknowledging that collections are not made on every support order, we created a 

hypothetical sample where the percentage of children for whom collections are made 

on their behalf is increased. These percentages assume the current collection rate of 

29 percent remains constant. 

D - 1€
Estiate of Potenti Collecons 

(in mions)€

Percent Of Chdren Estimated Child 

For Whom Support Collected 

Collections Are Made (FY 1990) 

$15 

$30 

$45 

$60 

$74 

Net Federal Estimated 

Share of Federal 

Collections Savigs 

$4. $2. 

$9. $4. 

$13. $6. 

$18. $9. 

$22. $11. 

The Federal share is ba on the ratio of the Federal share to the total of child support 

collections made on behalf of AFC children, as reported by OCSE. The percentage in 199 

use for determining Federal share of collecions wa 30.38 percent 

We are unable to calculate the marginal change in administrative cots that might be 

attributable to additional collecons. Hower, to roughly estimate poible Federal savings, we 

arbitrarily reduce the net Federal share of collecons by 50 percent. 

We believe our estimates are conservative for the reasons summaried below. 

The estimate reflects a 29 percent collection rate for current support orders. Ths 

low rate reflects many of the problems detaied in this report such as the lited 

exchange of information between foster care -and child support workers. The 

effective practice" sites achieve an 80 percent rate of collections on current 

support orders. Support orders in effective practices sites are also frequently 

updated, so the average dollar amount per support order is higher than is shown 

in this estimate. 

The ACF Region 11 offce conducted a recent study of referrals of IV-E Foster 

Care children to IV-D Child Support servces in New York City and showed a 

high rate of collections is possible. That study also showed problems in the 

referral processes and a lack of information exchange. Yet, when the IV-D Chid 

Support agency correctly opened IV-E Foster Care cases, they achieved over a 60 

percent collection rate. 

A potential savings to the Medicaid program from parent s medical support 

of their IV-E Foster Care children exists. In 1990 the average cost per Medicaid 

child was $811 per year. Although medical support only covers a porton of the 

total Medicaid expenditures, signficant savings may be possible. In "effective 

practice" sites 42 percent of the children received medical support from a parent. 

We did not include potential savings such as these in our estimates above. 

D - 2

A IV-D Chd Support agency occsionally locates an absent parent (such as an 

absent father for whom paternty had not been established) who is wig and 

able to provide a home for their child. In our sample, the IV-D Chd Support 

agency had located the alleged father of a IV-E Foster Care child. A paternity 

test proved the man was. the child' s father. The father who had been unaware of 

the child's existence, was concerned with the conditions that forced the child to be 

placed in foster care. The man then requested the child corne live with him and 

his family. File records showed the man s request was in the process of being 

reviewed and the child was expected to soon leave foster care. This is an example 

of the benefits a child may experience if they receive appropriate, coordinated 

servces. It also represents a source of savings to the IV-E program which we did 

not include in our estimates. €

The amount collected will increase as the number of children in IV-E Foster Care 

rises. We estimate the increase in children to be 12 percent per year, based on€

the average rate of increase between 1986 and 1990. Potential collections will also 

increase as dollar amounts of child support collected increase due to inflation and 

improved methods of collections (such as wage withholding and tax intercepts). 

The rate of increase established for AFDC and Foster Care cases in 1986-1990 

was 4.75 percent. Provided that these rates continue over the next five years€

Federal and State governments could cumulatively collect over $1 bilion in child


support on behalf of IV-E Foster Care children by 1996. We did not include such 

calculations in our estimates. 

Additionally a one time increase in collections would be realized if all cases 

misclassified" for distribution purposes were corrected. In our review, 19 percent of 

the total dollars collected on behalf of children in IV-E Foster Care was mistakenly 

distributed to the IV-A AFDC program. If this percentage is representative of the 

national rate of mistaken distribution, $2.5 milion should go to the IV-E Foster Care 

program. 

D - 3

APPENDIX E 

COMM ON DRA REORT 

E - 1 
. . 

. ..,. ....::\

DEPARTMENT OF HEALTH &. HUMAN SERVICES 

ADMINISTATION FOR CHILDREN AND FAMILIE 

Office of the Assistant Secretary, Suite 600 

370 L' Enfant Promenade, S. 

Washington, D.C. 20447 

March 27, 1992€

To: Richard P. Kusserow

. Inspector General 

From: Jo Ane B. Barart f" 

Assistant Secretary 

Children and Fami\es. 

Subj ect: Comments on the Offic Of Inspector General' s Draft

Report: "Child Support for Foster Care Children,

OEI-04-91-Q0530 

Attached are the Administration for Children and Families 

comments on your draft inspection report entitled: "Child 

support for Foster Care Children. 

We agree that there is a need to improve coordination be Neen the 

child support and foster care programs. We have provided 

specific comments on each of the recommendations discussed on€

page 12 of the report. We have also provided additional comments€

on our plans to implement the recommendations.€

Thank you for the opportunity to respond to the recommendations€

in this draft report.€

Attachment 

:l :J 0'- ". iI --

:!r 

\=83 
COMtS OF TH ADMIISTRTION FOR CHTTnRE AN FAMLI ON TH 

OFFICE OF INSPECTOR GE' S DRA INSPECTON RERT--CHLD 

SUPORT FOR FOSTE CA CHLDRE rOEI-04-91-0530\ 

Following are the Administration for Children and Families I 

comments on the recomendations discussed on page 12 of the 

above-captioned report. 

OIG Recommendation 

As a condition of receiving Federal matching fuds for Foster€

Care administration under Title IV-E, the Administration for 

Children and Families (ACF) should require states to develop and

implement:€

criteria and procedures to assue that Foster Care agencies 

refer all appropriate IV-E Foster cae cases to IV-D Child 

Support Enforcement agencies for establishing child support 

orders and collecting child support and 

a Memorandum of Understanding between IV-E Foster Care 

agencies and IV-D Child Support Enforcement agencies with 

respect to determining " appropriate" cases for referral 

gathering and exchanging data between the units, cross 

training, and inter-unit consultation on cases. 

ACF Comment:€

We believe that the substance of this recommendation is already 

in place. The Administration for Children, Youth and Families 

(ACYF) sent policy issuances to all State agencies which 

administer or supervise the administrtion of titles IV-B and IVE of the Social Secuity Act. These policy issuances are 

described below: 

Program Instruction, ACYF-PI-85-l, dated January 1, 1985, 

which requires States to amend their title IV-E State plans 

to include an amendment for the collection of child support 

payments made on or after October 1, 1984, as required by 

section 471 (a) (17) of the social Security Act. 

Information Memorandum, ACYF-IM-84-27, dated December 12, 

1984 , which transmitted to State child welfare agencies the 

Office of Child Support Enforcement' s (OCSE) Notice of 

Proposed Rulemaking regarding the child support enforcement 

amendments of 1984. The Information Memorandum exlained 

the responsibilities of both the title IV-D Child Support 

Enforcement agency and the title IV-E Foster care agency for 

implementation' of the requirements. The issuance states 

that it is the responsibility of the title IV-E agency to 

refer all cases with assignents to the title IV-D agency 

and to ensure that funds collected are appropriately 

managed.€
Page 2


The Informtion Memorandum recommended that each state 

title IV-E agency arange a meeting with the state 

title IV-D agency to clarify the procedures for assignent 

of title IV-E cases and deterine whether and under what 

conditions the agency would pursue support payments for


cases not receiving Federal funding. This recommendation


was based upon the fact that there is variation in state


laws and regulations governing the operation of title IV-D


agencies. 

The Information Memorandum also states that each quarer,


states must report to ACYF the title IV-E foster care


collections made as an adjustment to exenditures, and that 

it is the responsibility of the state title IV-E agency to 

initiate the action that will result in the assignent of 

rights to support for a child receiving title IV-E foster 

care maintenance payments. This does not apply to adoption 

assistance payments made under title IV-E.


copies of these policy issuances, ACYF-PI-85-1 and ACYF-IM-84-


27, are attached.


In addition, we are undertaking the following activities:


Each regional office will be asked to examine the system 

for the coordination of title IV-D and title IV-E 

requirements in each State, and report to the ACY 

Commissioner on the status of each state, highlighting

problem and providing recommendations for regional and/or 

Central Office action; and


We will include this issue as an explicit effort to be


undertaken as a part of title IV-B joint planning in the


Joint Planing Guidance to be issued to regions in fiscal


year 1992.


OIG Recommendation 


In support of such state initiatives, ACF should provide


and plans for coordinating the IV-E Foster Care and IV-D


Support Enforcement program. ACF could:


guidance Child 

Develop training and technical assistance modules to assist


states in implementing new policies and procedures on child


support for children in IV-E Foster Care.


Pulish a compendium periodically of the techniques used by 

successful States in increasing their collections. 

Pulish periodic reports showing statistics nationally and 

by state on the IV-E Foster Care and IV-D Child support initiative. 
Page 3 

Direct regional offices of ACF to monitor States in 

region using performce stada and monitoring mechanism . 

their€

ACF Comment: 

Our FY 1992 strategic plan addresses the need to improve 

coordination between the child support and foster cae program. Top level staff from OCSE and ACY have already met to begin a joint initiative between the two agencies, designed to encourge mutual progr coordination and outreach at the Federl level. 

Tentative plans include briefing centrl and regional office staffs of both progr to improve knowledge of each others

mission and fuctions , as well as pulicizing their linge with aricles in the Child Support Report newsletter, which is sent to

a national audience of individuas inolved or interested in 

child support. 

As part of the review of 

examining State policies reporting the collection 

titleIV-E State plans, ACY is and procedures for collecting and of child support fuds. 

OIG Recommendation '3 

The ACF should ensure that the Federal share of child support 

dollars collected on behalf of IV-E Foster care children is 

correctly distributed to the IV-E Foster Care progr rather than the IV-A AFC program. 

ACF Comment: 

The OCSE audit process looks at control over collections and 

distribution; however , due to the small numer of foster care 

cases , the OCSE auditors have not uncovered situations simlar to 

the ones described in the OIG drft report. We are confident that , as the numer of referrals , and this foster care cases in 

the system increases , the OCSE audit will more closely monitor

this programatic area. OCSE will, in the near future , issue a . "Dear Colleague " letter to State child support agency directors 

urging them to take appropriate steps to remedy the problem 

uncovered by the OIG , if such action is appropriate in their State. 
,,. !:: . . .. ..,nI, 

. DEPAR1IiIMIJULTH IL HUMAN SERVICES 

CiFF!CE OF i ISf'ECrC:= J(L. 

ef.: :€

;::3 I G : ; 9: 59 I 6 €

Richard P. Kusserow


Inspector General 


From 	 Arnold R. Tompkins 14. 

Assistant Secretary for anagement 

Subject:	 OIG Draft Report: "Child Support

Children, OEI-04-91-00530 

0t at th .b. y 

W8Iin. D.C. 201 

We have reviewed the subject draft report, and wish to concur


with comments. The recommendations in the report are well
 advised on both programatic and financial grounds. Pursuit of 

child support for IV-E children holds the promise both of greater


parental responsibility for children (and potentially, investment


in, and conmitment to these children), and of direct benefits to


the children (e.g., paternity establishment, location of absent


parents, continued collections after a child leaves foster care) 


We offer the following comments on this report. The report


indicates that one reason collections are low is the divergent


orientation of the Foster Care and Child Support agencies at the


State and local level. Specifically, notes the report in regard
 to State staff: 

Foster care staff are oriented to and talk in terms of an


individual child. They form interpersonal relationships
 with the families they serve. On the other band, most IV-D


Child Support staff view themselves as adversaries of


absent parents. The child support staff tend to be


"bottom line oriented.


We question whether, at the Federal level, there aren 't similar 

problems which need to be addressed, and whether there are 

actions which ACF can take to reduce tensions between the goals 

of he IV-D program (collecting funds to offset income 

maintenance costs) and the IV-E program (using the benefits of 

the child support process, including paternity and support order 

establishment and parental involvement). 

In Appendix D, page 3, the report states that "Federal and State 

governents could collect over $1 billion in child support on 

behalf of IV-E Foster Care children by 1996. " The report needs 

to clarify that this is a cumulative amount over five years. 

currently stated, the report gives the impression that by 1996, 

$1 billion could be' collected annually. Finally, on page 7 of 

ti.	 port, in the first paragraph under the be ding "Mi sion . and 

rc:es are not clearly understood or accepted, " 1n the th1rd 11ne, 

the wc=d compliment should be changed to "complgment. 
. 

. .

'00:

. DEPARTMENT Of HEALTH &. HUMAN SERVICES Ofce of tho Secota 

W..hinglon. D.C. 20201


h....-

TO: 

FROM: 

SUCT : 

Richard Kusserow


Inspector General


Assistant Secretary for


Planning and Evaluation


OIG Draft Report: "Child Support for Foster care Children " OEI-04-91-00530 

Thank you for the informtive draft report on the use of Child
 Support services for children in foster care. I agree that much
 more could be done to coordinate the provision of Child Support


Enforcement services for children entering the title IV-E Foster


Care system. Better communication and coordination between staff


in IV-D and IV-E agencies is certainly needed and should be


encouraged. 

However, I believe your draft does not address several important issues, and therefore oversimplifies the exent to which Child Support collections for foster care children can or should be


pursued. I strongly suggest that the report include a discussion
 of the following issues along with a suggestion that they be 

resolved before additional requirements are placed on state


agencies. 

The report does not adequately address the real and


perceived conflicts between the activities and goals of


the IV-D program (maximizing collections) and those of

the IV-E program (maximizing family reunification). Before ACF can provide guidance and states can develop


criteria, there needs to be some resolution of these


policy conflicts. Included in the list of issues which


could lead to conflicts are: pursuing child support


from a two-parent family; pursuing child support from a


custodial parent when a child was involuntarily removed


from the parent(s); pursuit of child support from a


parent receiving AFDC; pursuit of child support when


contact with and by the non-custodial parent could be disruptive to the permanency planing or reunification process involving the child and his or her (former) custodial parent. Finally, in our jUdgment, the report does not distinguish between financial support as a


strategy for family involvement and reunification, and


child support as pursued under state Child Support


Enforcement guidelines and enforcement procedures.


8il ;111;'; 0 I ';;I Z


:'::is; Q =:n:f= 

G::/1i3:J31: 
Page 2 - Richard XUserow€

The amount of savings potential fro IV-E collections€ cited in the report is overly optimistic. It does not


seem to take into account the cost of providing Child


Support Enforcement services. The 1990 Child Support
 Anual Report to Congress reports that states spent


$947 million to collect $1. 754 billion in child support
 collections on behalf of AF recipients. This results


in an average cost-effectiveness ratio of 1. 85. This


low cost-effectiveness ratio would reduce the savings


potential by about 45 percent.


Informtion on the actual level of child support€ collections made on behalf of IV-E children was not 

included in the report. In Fiscal Year 1990, IV-D 

agencies collected $10. 3 million on bealf of IV-E 

children. This is 30 percent more than the amount


estimated in Appendix D, based on sample information.


If you have any questions, please call Jane Baird at 245-2409.


L- /€

Martin .L:l€