Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

JUNE GIBBS BROWN 

Inspector General 

JULY 1999 

06-98-00052 

PATERNITY ESTABLISHMENT 

Use of Alternative Sites for 

Voluntary Paternity Acknowledgment 
OFFICE OF INSPECTOR GENERAL 

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

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

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

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

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

legislative, regulatory, and operational approaches to correct them. 

Office of Evaluation and Inspections 

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

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

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

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

effectiveness of departmental programs. 

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

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

Principal OEI staff included: 

REGION 

Blaine Collins

Ruth Ann Dorrill

Marnette Robertson

Clark Thomas, Ph.D.

Nancy Watts

Lisa White

FIELD 

Lucille Cop 

Vincent Greiber 

Ianna Kachoris 

Thomas Purvis 

Graham Rawsthorn 

HEADQUARTERS 

Alan Levine, Program Specialist 

Linda Hall 

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

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

http://www.dhhs.gov/progorg/oei 
Use of Alternative Sites for Voluntary 

Paternity Acknowledgment 

PURPOSE 

This report describes the early implementation efforts of State child support agencies to offer 

voluntary paternity acknowledgment services through alternative sites. 

RESULTS IN BRIEF 

We found about half of the States currently offer acknowledgment services through some of their 

public assistance offices. Few States, however, have yet expanded services to other sites that 

child support agencies believe are potentially important to their paternity establishment efforts. 

State efforts to encourage participation have met reluctance by some entities due to time demands 

on limited staff and lack of financial incentives. Typical services offered through alternative sites 

include distribution of public outreach materials explaining voluntary acknowledgment and, to a 

lesser degree, personal assistance to parents in completing paternity acknowledgments. Many 

State child support agencies have yet to develop adequate methods of monitoring and evaluating 

alternative sites. We offer a number of suggestions to promote use of alternative sites by 

capitalizing on and refining effective practices now being used in some localities. 

BACKGROUND 

As part of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996, 

Congress requires State child support agencies to provide voluntary paternity acknowledgment 

services through in-hospital acknowledgment programs and through “the State agency responsible 

for maintaining birth records.”1 To further expand services to unmarried parents, the Act allows, 

but does not require, States to offer acknowledgment services through “other entities.”2 If States 

use this added flexibility to expand acknowledgment services, the law requires State child support 

agencies to administer alternative sites in the same manner as in-hospital programs. 

The Office of Child Support Enforcement (OCSE) recently issued regulations on paternity 

establishment.3 These regulations specify that “... State procedures governing hospital-based 

programs and birth record agencies must also apply ...” to alternative sites designated by the 

State. The regulations also impose certain requirements on alternative sites involved in 

acknowledgment efforts, including “... undergoing training, being evaluated annually, providing 

oral and written information to mothers and putative fathers, and transmitting the 

acknowledgments to the State registry of birth records.” States may decide which entities to use, 

but OCSE regulations provide a list of possible alternative sites including child support, public 

assistance, and food stamp offices, public health clinics (including WIC centers), private health 

care providers, Head Start and child care facilities, child care providers, Community Action 

1
Agencies and Community Action Programs, secondary schools, Legal Aid agencies, private 

attorneys, and similar entities that provide health, welfare and/or social services. 

This report focuses on expansion of acknowledgment services through these discretionary 

alternative sites. Excluded from this discussion are the voluntary paternity acknowledgment 

services provided through hospitals, other birthing centers, vital records offices and local child 

support offices.4 We received survey responses on alternative site activity from all States and the 

District of Columbia.5 The following preliminary findings are provided to assist OCSE in its 

efforts to monitor State progress and provide technical assistance to promote early 

implementation efforts. 

This study was conducted in accordance with the Quality Standards for Inspections issued by the 

President’s Council on Integrity and Efficiency. 

FINDINGS 

Public Assistance Agencies Participate in Voluntary Paternity Acknowledgment Efforts in 

Twenty-six States. 

State child support agencies have involved public assistance offices in acknowledgment efforts 

more frequently than other alternative sites. Sixteen States report offering acknowledgment 

services through one hundred percent of local public assistance offices, while ten other States 

report partial implementation. Providing voluntary acknowledgment services through public 

assistance offices seems a natural fit in many States for several reasons. These agencies 

administer Temporary Assistance to Needy Families programs and often handle eligibility for 

Medicaid, food stamps and other human service programs. Caseworkers at public assistance 

offices often see clients with children who do not have paternity established. Clients may feel 

more comfortable dealing with their public assistance caseworker who assists them with child 

care, transportation and work-related matters. Application and re-determination interviews 

provide opportunities for clients to receive information and sign voluntary paternity 

acknowledgment forms. Additionally, in many States, child support and public assistance 

agencies have very strong inter-agency relationships, making training and coordination efforts less 

challenging than with other alternative sites. 

Participation by Entities Other Than Public Assistance Offices is Still Very Limited. 

State child support agencies have begun to offer voluntary acknowledgment services through a 

variety of other alternative sites. Table 1 lists the number of States that report using alternative 

sites in their acknowledgment programs.6 Two sites on the list, public health clinics and food 

stamp offices, may be viewed as expansions of service within agencies that already offer 

acknowledgment services. In many States, public health clinics, the second most frequently used 

alternative site, are administered through the vital records agency. Therefore, many of these 

States have simply expanded voluntary acknowledgment services beyond their vital records 

offices to public health clinics. Similarly, food stamp programs are often administered through 

2
public assistance offices. Other activities, however, clearly represent expansions of service to new 

locations. Several States now use Women, Infant and Children (WIC) centers, high schools and 

Head Start agencies in their acknowledgment programs. Some additional entities, such as 

fatherhood organizations, appear to offer voluntary acknowledgment services, yet may not be 

counted as alternative sites by State child support agencies.7 

TABLE 1: Participation and Importance of Alternative Sites in State 

Voluntary Paternity Acknowledgment Programs 

Alternative Site States Currently 

Using Site 

States Considering 

Site ‘Important’ 

Public Assistance Offices 26 36 

Public Health Clinics 15 26 

High Schools 11 18 

Food Stamp Offices 10 21 

Head Start Agencies 9 21 

Private Doctors’ Offices 9 19 

WIC Centers 8 22 

Middle Schools 5 12 

Medicaid HMO Facilities 2 16 

Pre-natal Clinics N/A 26 

It is important to note that the responses summarized in Table 1 do not reflect the extent to which 

a particular site participates Statewide. That is, use of an alternative site may occur in only one or 

a few locations within a State. Some State child support agencies are testing alternative sites 

through ‘pilot’ programs or have initiated participation only in selected geographic areas which 

may be expanded in the future. 

Participation by Certain Alternative Sites is Seen as Important by Child Support Agencies. 

As listed in Table 1, State child support agencies believe participation by several alternative sites 

is important to their voluntary paternity establishment programs. More than half of States view 

public assistance offices, public health clinics and pre-natal clinics as important sites for 

acknowledgment services. More than a third of States consider WIC centers, Head Start offices, 

food stamp offices, doctors’ offices and high schools as potentially important to their 

acknowledgment programs. However, many of the possible alternative sites listed in 

OCSE regulations are not viewed as important by most respondents. For example, only nine 

respondents indicated that providing voluntary acknowledgment services through child care 

3
providers would be important to their program. As expected in early implementation, more States 

view alternative sites as important than currently use those sites in their acknowledgment efforts. 

Most State Child Support Agencies Have Made at Least Some Outreach Efforts to Alternative 

Sites, But Some Entities are Reluctant to Participate. 

To expand acknowledgment services, most States have made contact with other entities. Fifteen 

State child support agencies, however, report making no efforts to expand acknowledgment 

services to alternative sites.8 Most agencies indicate they use one of the following methods to 

attract new participants: presentations at meetings and/or conferences (33 States), conversations 

between key personnel (28), memos/letters sent to alternative site local offices (21), or phone 

calls to alternative site local offices (16). According to one child support administrator 

responsible for outreach to other entities, personal contact is critical because key people at the 

alternative sites must be committed to the program. This official offered several examples of sites 

that participated in paternity establishment efforts, but failed to generate many acknowledgments. 

He suggested that other sites were more successful because their leaders were committed to the 

project and encouraged staff to discuss voluntary paternity acknowledgment with clients. 

Most State child support agencies who have conducted outreach report that some entities are 

reluctant to provide voluntary acknowledgment services. Although only three States report 

reluctance by “most” or “all” alternative sites contacted, another twenty States report reluctance 

by half or fewer contacted sites.9 

Lack of Resources is Cited as the Most Significant Barrier to Participation of Alternative 

Sites. 

State child support agencies identified barriers that hamper participation by alternative sites. In 

general, other entities often see the voluntary paternity acknowledgment program as a potential 

drain on limited staff time. Twenty-eight States report sites they approached were “too busy with 

their primary function” and 25 States responded that entities “lacked the manpower to offer such 

services.” Fourteen States report the absence of any financial incentive is a barrier to 

participation. Despite having the authority to use Federal matching funds to pay other entities for 

completed paternity acknowledgments, only four State child support agencies report paying 

alternative sites for any services. By comparison, 20 State child support agencies paid hospitals 

for completed voluntary acknowledgments in 1996.10 

Most Participating Alternative Sites Provide Forms and Written Materials, But May Not 

Actually Assist Parents in Completing Paternity Acknowledgments. 

Table 2 shows the number of States in which alternative sites are providing different types of 

acknowledgment services. The most common service is provision of outreach materials to the 

general public. Typical outreach materials are wall posters, brochures or pamphlets that explain 

the mechanics and benefits of voluntary paternity acknowledgment. In several States, alternative 

sites currently participate in outreach, but offer no further services such as making 

4
acknowledgment forms available to the public. While 21 States report that their public assistance 

agencies distribute acknowledgment forms, only a handful of States currently make 

acknowledgment forms available through high schools, WIC Centers, or Head Start facilities. 

Some alternative sites also provide personal assistance to individuals and accept completed 

acknowledgment forms. Personal assistance may include notification of rights and 

responsibilities,11 or guidance on how to present the idea of acknowledging to the other parent. 

Fewer alternative sites accept acknowledgment forms from the public and forward them to the 

appropriate agency (typically the child support agency or the vital records agency.) As shown in 

the last column of Table 2, only 15 States report that even their public assistance agencies 

currently provide this higher level service. 

TABLE 2: Number of States in Which Alternative Sites Provide Services 

Alternative Site Outreach 

Materials 

Acknowledgment 

Forms 

Personal 

Assistance 

Accept & 

Forward Forms 

Public Assistance Offices 26 21 17 15 

Public Health Clinics 15 13 8 4 

High Schools 11 4 3 3 

Food Stamp Offices 10 7 6 4 

Private Doctors’ Offices 9 5 1 1 

Head Start Facilities 9 5 5 4 

WIC Centers 8 5 4 2 

Most State Child Support Agencies Provide Training or Materials to Alternative Sites, and 

Some Have Begun to Monitor Their Performance. 

Thirty-five State child support agencies report providing materials or training to other entities. 

Additionally, vital records agencies perform some of these tasks in 15 States.12 In nine States, 

however, neither the child support agency nor the vital records agency report providing any 

training or materials to other entities. Eighteen State child support agencies report monitoring the 

performance of most or all alternative sites, and an additional three States said their vital records 

agency performs this monitoring function. The most common form of monitoring involves 

tracking the number of acknowledgments generated through individual sites. Fourteen State child 

support agencies and three vital records agencies monitor alternative sites by this method. 

However, fewer than ten States report tracking alternative sites through more in-depth methods 

such as personal conversations, telephone calls or on-site visits. Even less monitoring of 

acknowledgment services may occur with entities that are not officially considered alternative 

sites, such as fatherhood organizations. One approach to monitoring alternative sites was 

developed for Cook County, Illinois where a single unit (3-4 staff members) acts as a liaison with 

5
all alternative sites. This unit maintains contact with participating entity staff and insures periodic 

training. 

RECOMMENDATIONS 

While State programs to offer voluntary paternity acknowledgment services through alternative 

sites are still in early stages of development, many preliminary efforts appear promising. 

Therefore, we recommend that the Office of Child Support Enforcement (OCSE) capitalize on 

these early efforts by promoting refinement of potentially effective approaches. As we offer these 

suggestions, we recognize that OCSE has already taken action to promote innovation in 

acknowledgment services. For example, OCSE’s 8th National Training Conference highlighted 

effective practices in a session on expanding voluntary acknowledgment services through 

alternatives sites. 

Focus technical assistance on the most promising sites. 

States are using the flexibility afforded by welfare reform legislation and OCSE regulations to 

expand voluntary paternity acknowledgment services offered through alternative sites, especially 

public assistance agency offices. Although OCSE regulations list a large number of potential 

sites, our research suggests that a few (public health and pre-natal clinics, WIC centers, food 

stamp offices, Head Start agencies, doctors’ offices and high schools) clearly have the greatest 

potential. To maximize the impact of technical assistance, OCSE should primarily focus on 

helping States expand services through these sites. 

Minimize complexity for participating entities. 

Lack of staff is viewed as a significant barrier to participation by alternative sites. To address this 

barrier, OCSE should assist States in simplifying the role of alternative site staff in the voluntary 

paternity acknowledgment process. For instance, several states have established toll-free phone 

lines through which parents may hear a recorded explanation of the rights and responsibilities of 

acknowledging paternity or talk directly with a child support specialist. Many States have also 

simplified processes through which sites may order needed materials or arrange for training of 

new staff. These efforts reduce the burden on alternative site staff, while insuring that parents 

may obtain accurate, consistent information. 

Encourage full-service participation. 

While most participating alternative sites provide public outreach materials about voluntary 

acknowledgment of paternity, many do not offer full services that would enable parents to 

complete and submit acknowledgments through the site. By encouraging alternative sites to assist 

parents in completing voluntary acknowledgments, State child support agencies could increase the 

use of acknowledgments and better utilize resources devoted to alternative sites. To accomplish 

this goal, at least one State makes the percentage of cases with paternity established a 

performance measure for its local public assistance office managers. Thus, these managers have a 

6
direct incentive to give their staff the training and resources to assist parents in completing 

voluntary paternity acknowledgments. 

Consider developing incentives for alternative site participation. 

Lack of financial incentives is seen as a significant barrier to participation by other entities. 

Payment for completed voluntary acknowledgments, which currently occurs in only a few States, 

may be one way to encourage alternative site participation. States might focus financial incentives 

on sites - such as public assistance offices and public health clinics - which are full service sites, 

appear to be promising, and are regarded as important by State child support officials. However, 

some State child support administrators surveyed considered payment for acknowledgments akin 

to offering a “bounty” for completed acknowledgments. On the other hand, others view a small 

($10 - $20) payment as minimal compensation for assisting the State in the important task of 

paternity establishment. 

Encourage State agencies to more closely monitor sites. 

While virtually all States provide training or materials to participating alternative sites, relatively 

few appear to monitor the performance of these sites. Monitoring not only allows State child 

support agencies to review the performance of sites, it also helps insure consistent service to 

parents. To encourage monitoring, OCSE may wish to highlight the activities of States that do 

actively monitor alternative sites. At a minimum, effective monitoring involves tracking the 

amount of outreach materials distributed through other entities and the number of 

acknowledgments completed at sites. More extensive methods may include periodic visits to sites 

to conduct training and assess progress. 

AGENCY COMMENTS 

The Administration for Children and Families (ACF) notes that OCSE has made a commitment to 

State development of alternative sites by allowing States to provide up to $20 to hospitals, State 

birth record agencies, and other entities designated by the State and participating in the State’s 

voluntary paternity establishment program for each voluntary acknowledgment obtained pursuant 

to an agreement with the child support agency.13 ACF also anticipates that, in an effort to 

increase paternity establishment ratios to the levels PRWORA requires, States will work closely 

with, and monitor, the progress of paternity acknowledgment in alternative sites. 

While ACF’s comments reaffirm that financial incentives are available for alternative sites, our 

study shows that few States as yet pay alternative sites. On this issue and others addressed in our 

recommendations, we continue to believe that States could benefit from further Federal leadership 

and focused technical assistance as they seek to expand voluntary paternity acknowledgment 

services through alternative sites. 

ACF’s comments are provided in their entirety in Appendix A. 

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ENDNOTES

1. The State agency responsible for maintaining birth records is also known as the vital records 

agency or the public health statistics agency. We use the term ‘vital records agency’ in this 

report. 

2. The terms ‘alternative sites’ and ‘other entities’ are used interchangeably here. 

3. OCSE Action Transmittal 99-02 (March 10, 1999). 

4. Our office previously evaluated in-hospital voluntary paternity acknowledgment programs 

and presented the results in August of 1997 in a series of four reports entitled In-Hospital 

Voluntary Paternity Acknowledgment Program: State Agency and Birthing Hospital 

Implementation (OEI-06-95-00160); Hospital Experiences in Sample States (OEI-06-95-

001610; Effective Practices in Hospital Staff Training (OEI-06-95-00162); and Effective 

Practices in Parent Outreach (OEI-06-95-00163). Also, see our companion reports Paternity 

Establishment: Use of Voluntary Paternity Acknowledgments (OEI 06-98-00053) and Paternity 

Establishment: States Use of Genetic Testing (OEI 06-98-00054). 

5. While every State returned the survey, three States did not fill out a series of questions on 

other entities. Other questions on alternative sites were answered by varying numbers of 

respondents. The effect, if any, of non-response to individual questions is that our findings 

may understate actual alternative site activity. 

6. This table does not include sites that fewer than twelve State child support agencies believed 

would be important to their voluntary paternity program. 

7. Our data collection concentrated on the other entities suggested in OCSE Action Transmittal 

98-01 (January 8, 1998) and, therefore, did not ask about fatherhood organizations or other 

community based organizations (CBOs). One State did report contacting CBOs to offer 

acknowledgment services and fatherhood organizations have publicized offering services to 

assist fathers in acknowledging paternity. Any unofficial involvement of CBOs may create 

problems for State child support agencies, however, because they may lack mechanisms 

through which to monitor or evaluate the efforts of these organizations. 

8. Some of these fifteen States may not yet use voluntary paternity acknowledgments outside 

hospitals and birthing centers. For more details, see our companion report, Paternity 

Establishment: Use of Voluntary Paternity Acknowledgments (OEI 06-98-00053). 

9. By contrast, 14 States report no reluctance at all by the alternative sites approached to 

provide acknowledgment services. 

10. As indicated in our report, In-hospital Voluntary Paternity Acknowledgment Program: 

State Agency and Birthing Hospital Implementation (OEI-06-95-00160), August, 1997. 

8
11. If an alternative site distributes acknowledgment forms, it is required to provide parents 

with written and oral notification of their rights and responsibilities regarding voluntary 

paternity acknowledgment. For more details, see our companion report, Paternity 

Establishment: Notification of Rights and Responsibilities for Voluntary Paternity 

Acknowledgment(OEI 06-98-00051). 

12. Nine State vital records offices conduct on-site training of alternative site staff. For more 

details see our companion report, Paternity Establishment: The Role of Vital Records Agencies 

(OEI 06-98-00055). 

13. While the original ACF Response in Appendix A suggests that other entities must provide 

prenatal or birthing services to be eligible for the $20 payment, OCSE clarified that States 

could provide payment to any alternative site participating in the State’s voluntary paternity 

establishment program pursuant to an agreement with the child support agency, as indicated in 

OCSE Action Transmittal 99-02. 

9