Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

JUNE GIBBS BROWN 

Inspector General 

MARCH 2000 

OEI-06-98-00040 

CLIENT COOPERATION WITH 

CHILD SUPPORT ENFORCEMENT 

Policies and Practices 
OFFICE OF INSPECTOR GENERAL 

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

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

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

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

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

legislative, regulatory, and operational approaches to correct them. 

Office of Evaluation and Inspections 

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

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

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

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

effectiveness of departmental programs. 

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

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

Principal OEI staff included: 

DALLAS 

Blaine Collins

Ruth Ann Dorrill

Marnette Robertson

Clark Thomas, Ph.D.

Nancy Watts

Lisa White

FIELD OFFICES 

Lucille Cop 

Vincent Greiber 

Ianna Kachoris 

Thomas Purvis 

Graham Rawsthorn 

HEADQUARTERS 

Alan Levine, Program Specialist 

Joan Richardson, Program Specialist 

Linda Hall 

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

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

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

PURPOSE 

To describe State policies and practices for gaining cooperation with child support enforcement 

from Temporary Assistance for Needy Families (TANF) clients. 

BACKGROUND 

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

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

State child support agencies are required to determine if clients are cooperating in “good faith” 

and notify the public assistance agency of each client’s cooperation status. If the child support 

agency determines a client has not cooperated, the public assistance agency must reduce the 

family’s cash assistance by at least 25 percent and, at State discretion, may deny the family all 

cash assistance. This report describes the client cooperation policies of six focus States which we 

chose in order to examine a variety of implementation strategies and experiences regarding TANF 

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

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

caseworkers. 

FINDINGS 

TANF Clients Appear to Have a Basic Understanding of Cooperation 

Requirements, But May Not Fully Understand All That is Expected of Them 

All six States in our study require clients to provide information about noncustodial parents and to 

keep appointments, such as for genetic testing or court hearings. While 95 percent of local public 

assistance respondents believe that most or all TANF clients understand their State’s cooperation 

requirements, only 60 percent of child support respondents agree with this assessment. The 

remaining 40 percent believe that half or fewer clients understand cooperation requirements. 

While public assistance workers mainly focus on clients providing initial information about 

noncustodial parents, child support staff are more aware that clients may also be expected to 

appear in court, submit to genetic testing, and attend additional meetings with agency staff. 

i 
Two of Our Study’s Focus States Require Applicants to Interview With Child 

Support Staff Prior to Approval for Benefits, While the Remaining Four Refer 

Cases Only After a New Client Has Been Approved for TANF Benefits 

Our focus States have two distinct practices regarding the earliest time at which a TANF 

applicant might interview with child support staff, either prior to or following approval of 

benefits. Staff report that pre-approval interviews allow child support workers to begin working 

cases sooner, and that clients may be more willing to provide information because they are still 

seeking approval of their application. 

After Typically Providing Many Opportunities to Cooperate, Front Line Child 

Support Staff Determine Each Client’s Cooperation Status 

Some clients fail to cooperate because they provide inadequate or false information, or fail to 

appear for appointments. Front line child support staff are typically responsible for determining 

the cooperation status of their clients and feel comfortable with the task because most cases are 

fairly obvious. Clients are typically notified in advance and given multiple opportunities to avoid 

being designated as noncompliant by providing additional information, attending re-scheduled 

appointments, or completing requested documents. 

States Impose Standardized Penalties on TANF Clients Who Do Not Cooperate in 

Meeting Child Support Requirements, Ranging From Reductions in Cash 

Assistance to Case Closure 

States report that TANF clients who do not cooperate face standardized penalties that reduce or 

eliminate their cash assistance. Penalties for noncooperation with child support enforcement in 

the six focus States range from the Federally mandated 25 percent cash assistance reduction to 

full case closure. We found that within each focus State, public assistance agencies appear to 

impose penalties uniformly. 

CONCLUSION 

Gaining cooperation from TANF clients is important to facilitating child support enforcement. 

Congress has long maintained that recipients of public benefits are obligated to assist States in 

pursuing support for their children. Client responsiveness can ease and speed the support 

enforcement process, particularly when paternity has not yet been established. 

All focus States have implemented client cooperation policies in keeping with the Federal 

mandates, including establishing guidelines for staff, allowing for use of exceptions, and imposing 

uniform penalties. Staff in both the public assistance and child support agencies appear to value 

client cooperation, and attempt to implement State policy in a way that is largely flexible and 

client-focused. This includes relying primarily on front line staff closest to the individual cases to 

determine whether clients have adequately cooperated. 

ii 
Although most TANF clients cooperate readily, gaining cooperation from some clients can prove 

difficult. In response, staff typically provide multiple opportunities for clients to give information 

and to make appointment deadlines, and appear concerned about legitimate barriers to 

cooperation. Nevertheless, shortfalls and difficulties in current practice remain. However, based 

on our review, there are good opportunities to address them in a practical way. 

COMPANION REPORTS 

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

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

Enforcement: Challenges and Strategies to Improvement (OEI-06-98-00041), examines 

why some clients do not cooperate and how States attempt to gain their cooperation. 

Another report, Client Cooperation with Child Support Enforcement: The Role of Public 

Assistance Agencies (OEI-06-98-00042), discusses responsibilities of public assistance 

agencies and collaboration between agencies. The remaining report, Client Cooperation 

with Child Support Enforcement: Use of Good Cause Exceptions (OEI-06-98-00043), 

describes how clients may be exempted from cooperation requirements under certain 

circumstances, especially when enforcement may put the child at risk of violence. 

iii 
TABLE OF CONTENTS 

PAGE

EXECUTIVE SUMMARY i

INTRODUCTION 1

FINDINGS

Cooperation Requirements 4

Information Collection 6

Determination of Noncooperation 7

Penalties for Noncooperation 10

CONCLUSION 11

ENDNOTES 13
INTRODUCTION INTRODUCTION 

PURPOSE 

To describe State policies and practices for gaining cooperation with child support 

enforcement from Temporary Assistance for Needy Families (TANF) clients. 

BACKGROUND 

Federal law has long required public assistance clients to cooperate with State child 

support enforcement authorities in establishing paternity and creating and enforcing child 

support and medical support orders. As part of a broad effort to reform the nation’s 

welfare system, Congress made significant changes to Federal policy regarding client child 

support cooperation requirements in the Personal Responsibility and Work Opportunity 

Act of 1996. Currently, unless exempted from cooperation requirements through a good 

cause or other exception,1 TANF clients must name and provide information about the 

absent parent of their children, and otherwise cooperate as determined by the State.2 

Formerly, State public assistance agencies determined whether clients were cooperating 

with their State’s child support agency; however, welfare reform made State child support 

agencies responsible for determining if TANF clients are cooperating in “good faith” and 

notifying the public assistance agency of each client’s cooperation status. Before welfare 

reform, State public assistance agencies solely determined how to deal with clients who 

failed to cooperate. Now, if the child support agency determines a client has not 

cooperated, the TANF agency is required to reduce the family’s cash assistance by at least 

25 percent and, at State discretion, may deny the family all cash assistance. If a State 

public assistance agency does not enforce the penalties requested by the child support 

agency, Federal law allows for the State to be penalized up to 5 percent of their TANF 

funds.3 All these changes were made in an attempt to improve client cooperation with 

child support enforcement. While families who receive Medicaid coverage, food stamps, 

or foster care services are also required to cooperate with child support enforcement 

efforts, this report focuses on cooperation issues involving clients of the TANF program.4 

This report describes the policies of six States regarding TANF client cooperation with 

child support enforcement and how these policies are implemented. State child support 

agencies determine policies regarding what information and actions to require of clients, 

how to inform clients about cooperation requirements, which staff are authorized to 

determine whether clients are cooperating, what additional opportunities clients may 

receive to cooperate, and staff procedures for communication with public assistance 

agency workers and clients. State public assistance agencies also determine policies 

regarding how clients are informed about cooperation requirements, as well as what 

penalties may be imposed for noncooperation, whether clients receive additional 

opportunities to cooperate before being penalized, how benefits may be reinstated once a 

1
client complies, and staff procedures for communication with child support workers and 

clients. 

SCOPE AND METHODOLOGY 

We used several sources of information to examine TANF client cooperation with child 

support enforcement. The primary source of information comes from self-administered 

written surveys which we mailed to local child support and public assistance offices. 

Managers and administrators from 99 local child support offices and 103 public assistance 

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

returned these mail surveys regarding cooperation policies, practices, and improvement 

strategies. The quantitative data (percentage of responses) presented in this report come 

from responses to the questions in these surveys. We also gathered and reviewed agency 

documents from these same local offices, including client cooperation policy statements, 

standardized forms, examples of correspondence with clients and other agencies, outreach 

materials, and other related documents. 

We also made site visits to a subset of local offices, visiting offices in one or two cities and 

their surrounding areas in each of the six focus States. During these visits, we conducted 

interviews with approximately 180 local public assistance and child support managers and 

caseworkers. At almost all offices, we interviewed one or more managers, then separately 

interviewed two or more caseworkers. Resource constraints prevented us from directly 

interviewing clients. Finally, we conducted telephone interviews of administrators from 

each State’s child support enforcement and public assistance agency to confirm 

information regarding State policies. 

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

strategies and experiences regarding client cooperation. To achieve this variety, we 

considered many criteria including type of penalties for noncooperation, number of good 

cause claims, number of good cause exceptions granted, outstanding program 

characteristics (innovations, privatization, etc.), status as State-administered or countyadministered, and geographic region. We also purposively selected local child support and 

public assistance offices within these States to provide a mix of urban, suburban, mid-size, 

and rural locations. The selection of focus States does not purport to be representative of 

the nation, nor do local offices represent all offices within individual focus States. The 

selections do, however, allow for examination of client cooperation processes under 

conditions found throughout the country. 

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

These respondents provided detailed information about how cooperation policies are 

implemented, as well as the effect of cooperation requirements on office operations, staff, 

and clients. We did not attempt to independently verify the information provided by staff. 

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

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

concern for the effectiveness of their programs. 

2
This study was conducted in accordance with the Quality Standards for Inspections issued 

by the President’s Council on Integrity and Efficiency. 

COMPANION REPORTS 

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

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

Enforcement: Challenges and Strategies to Improvement (OEI-06-98-00041), examines 

why some clients do not cooperate and how States attempt to gain their cooperation. 

Another report, Client Cooperation with Child Support Enforcement: The Role of Public 

Assistance Agencies (OEI-06-98-00042), discusses responsibilities of public assistance 

agencies and collaboration between agencies. The remaining report, Client Cooperation 

with Child Support Enforcement: Use of Good Cause Exceptions (OEI-06-98-00043), 

describes how clients may be exempted from cooperation requirements under certain 

circumstances, especially when enforcement may put the child at risk of violence. 

3
FINDINGS 

COOPERATION REQUIREMENTS 

While Federal law requires TANF recipients to cooperate with child support enforcement 

in a general sense, States have discretion to determine what specific actions constitute 

cooperation. Generally, in each of our six focus States, clients must cooperate by: 

naming and providing information about noncustodial parents, or putative fathers in cases 

that require paternity establishment; appearing for appointments at agency offices; 

appearing in court; and submitting to genetic testing. 

While Nearly All Public Assistance Staff We Surveyed Believe That Their Clients 

Understand Cooperation Requirements, Many Child Support Staff Report Clients 

May Not Fully Understand All That Is Expected of Them 

TANF clients typically learn of the requirements to cooperate with child support 

enforcement during an application or re-determination interview at the public assistance 

office. Public assistance workers usually conduct this interview, although some offices use 

child support staff co-located or out-stationed in the public assistance office.5 Most public 

assistance respondents (94 percent) report they provide clients with a verbal explanation 

of cooperation requirements, as well as written materials (91 percent). A few offices also 

post this information on bulletin boards in their waiting areas. Public assistance agencies 

in two focus States have developed videos which explain cooperation requirements, but 

only about half of local public assistance respondents we surveyed in those States report 

using these videos.6 In addition to explanations of cooperation requirements at public 

assistance offices, local child support respondents in all six States report they reiterate the 

cooperation requirements during any client interviews they conduct, and through written 

materials provided to clients. 

Responding staff from the two agencies differ in their views of the effectiveness of their 

combined efforts to inform clients about cooperation requirements. While 95 percent of 

local public assistance respondents feel that most or all clients understand their State’s 

cooperation requirements, only 60 percent of child support respondents agree with this 

assessment. Forty percent of child support respondents believe that half or fewer TANF 

clients understand their State’s cooperation requirements. 

One reason child support workers may perceive that fewer clients fully understand 

cooperation requirements is that these workers appear to have a better understanding of 

exactly what cooperation entails. While public assistance workers mainly focus on clients 

providing initial information about noncustodial parents or putative fathers, we found that 

most child support workers are more aware that clients may also be expected to provide 

additional information, visit agency offices for additional interviews, appear and testify in 

court, and submit to genetic testing. 

4
Some States Require TANF Clients to Provide All Available Information About 

Noncustodial Parents, While Others Require Clients to Provide Only Minimal 

Information 

Typically, the first opportunity clients have to cooperate with child support enforcement 

involves providing information about noncustodial parents or putative fathers. Child 

support agencies seek this information from clients in order to allow staff to locate the 

noncustodial parent, establish paternity, create a child support order, and/or enforce a 

prior obligation. Staff indicate that the most useful information is a full name, Social 

Security number, driver’s license number, date of birth, and current employment data. 

Other helpful information includes last-known address, make and model of automobiles 

owned, relatives’ addresses, schools attended, and previous employers. 

Among focus States, policy regarding the provision of this information falls into two 

categories. Three focus States require clients to provide all the pertinent information they 

have about noncustodial parents. Two of these States go further to require clients to 

make efforts to gain more information than may be readily available upon first request. 

Under this ‘all information’ approach, it is necessary for child support workers to 

determine whether clients are in fact providing all the information they have or are making 

efforts to obtain additional information. Three States use a second approach involving 

minimum standards for providing information. One of these States requires that clients 

name the noncustodial parent or putative father and provide two additional pieces of 

information, while the other two States require the name plus three pieces of additional 

information. 

Staff report that while collecting minimal information may sometimes not generate enough 

leads to allow the child support agency to pursue support, it does standardize expectations 

for clients and gives initial interviewers clear guidelines as they attempt to elicit 

information. Many public assistance caseworkers like the policy of gathering minimal 

information because they believe their role in discussing noncustodial parents should be 

limited. These workers explain they are often uncomfortable talking about their clients’ 

relationship with the noncustodial parent, or attempting to uncover the identity of the 

father when paternity has not been established. They note that, unless handled carefully, a 

contentious child support portion of the interview may hinder their efforts to develop the 

close relationship needed in the future to help the client move toward self-sufficiency. 

Therefore, workers suggest that, in some cases, it may be better for public assistance staff 

to accept minimal information, then let child support staff re-interview clients if additional 

information is needed in the future. 

TANF Clients May Be Exempted from State Cooperation Requirements By 

Qualifying for a “Good Cause” Exception and Other Exceptions 

Federal law allows States to exempt clients from cooperating when child support 

enforcement is not in the best interest of the child. This normally involves situations in 

which it is feared that a noncustodial parent might retaliate against a child or client 

5
because the client cooperates with authorities. All six focus States have adopted 

definitions of a “good cause” exception which includes cases of domestic violence, when 

conception was the result of forcible rape or incest, when adoption is pending, or when the 

client is consulting with a social service agency regarding the possibility of adoption. 

Some focus States have added other exceptions, including circumstances of mental 

incapacity of the client, cases with non-parent caretakers, cases in which conception 

occurred from artificial insemination, cases in which clients lack knowledge about 

noncustodial parents, and cases in which domestic violence is anticipated. Front line 

public assistance caseworkers are normally responsible for informing clients about good 

cause exceptions and for evaluating requests for exceptions. Respondents report few 

requests for good cause exceptions and virtually no fraudulent claims. In a companion 

report, we discuss the process for requesting good cause exceptions, the reasons and 

disincentives that help explain the low number of requests, and local office efforts to 

preserve client safety.7 

INFORMATION COLLECTION 

Initial Information About Noncustodial Parents is Usually Collected By Public 

Assistance Staff, But Child Support Workers Can Often Obtain More Useful 

Information 

Public assistance staff ask clients questions about noncustodial parents during new 

application and re-determination interviews, but the information received is often 

minimal.8 If the information collected is considered insufficient for establishing paternity 

and pursuing support, child support staff may conduct follow-up interviews. Interviews 

conducted by child support workers are likely to differ from those conducted by public 

assistance staff in two significant ways. First, because child support workers have been 

specifically trained to gather information that will lead to location of the noncustodial 

parent, they are better equipped to ask important follow-up questions and gain potentially 

vital information. One worker explains the differences, “It is incumbent on the client to 

give us as much information as she has, and we emphasize this. Our interviewing 

techniques are much different from a TANF worker - we are trained to probe deeper and 

observe body language ... observe who comes with them to the appointment.” 

Second, child support interviewers tend to have the electronic means to immediately verify 

information given them by clients. If a client provides a Social Security number, for 

instance, workers can immediately determine if that number exists, who has been assigned 

that number, and whether that person has had earnings in a location that would validate 

the client’s information. Similarly, child support interviewers often verify information 

through motor vehicle records, State employment databases, and other systems. Workers 

report that access to these resources substantially improves the information child support 

staff gather relative to public assistance interviewers. 

6
Two of Our Study’s Focus States Require Applicants to Interview With Child 

Support Staff Prior to Approval for Benefits, While the Remaining Four Refer 

Cases Only After a New Client Has Been Approved 

Our focus States have two distinct practices regarding the earliest time at which an 

applicant for public assistance might interview with child support staff. As a matter of 

State policy, clients in one focus State are required to personally interview with child 

support staff, who are co-located in each county’s public assistance office, before 

continuing with their application for benefits. In another focus State, child support staff 

must be available in person or by telephone for such a pre-approval interview. Staff 

identify two primary benefits of requiring pre-approval child support interviews. First, 

workers may gather and verify information sooner than if they had to wait until a client is 

approved, and can immediately begin working the case. Second, at the time of 

application, clients often have the best information they will ever have about noncustodial 

parents or putative fathers, and staff report clients are more willing to provide information 

because they are still seeking approval of their application. 

In the other four focus States, new cases are typically not referred to the child support 

enforcement agency until the clients are approved for benefits, which may take up to 45 

days. In three of these States, child support staff examine the information that clients 

provide at the public assistance office to determine whether a follow-up interview is 

needed. If the initial information is sufficient to work the case, they begin procedures to 

collect support. When more information is needed, workers may conduct telephone 

interviews, or mail clients questionnaires, rather than request a personal interview. 

Personal interviews are scheduled when necessary, but staff indicate they avoid requesting 

clients to come in to the child support office because this further delays enforcement, and 

because the appointment may have to be re-scheduled if the client faces barriers to 

attending. The child support agency in the remaining focus State routinely schedules all 

newly approved TANF clients for personal interviews with child support staff, regardless 

of what information has already been provided. 

DETERMINATION OF NONCOOPERATION 

TANF Clients May Fail to Cooperate by Providing Inadequate or False Information 

and by Failing to Appear for Appointments 

Child support and public assistance agency staff report that most TANF clients cooperate 

by providing at least minimal information about noncustodial parents or putative fathers at 

initial interviews. However, workers describe several other possible client reactions to 

their requests for information during interviews. Some new applicants and clients seeking 

re-determination of eligibility for benefits simply refuse to provide information. As one 

worker describes, “Some choose to withdraw their application when they find out that 

they have to name the father. They don't want him involved at all.” In these cases, new 

application processes cease and existing clients face penalties for noncooperation. 

Workers also report receiving sketchy or even false information during interviews. For 

7
example, a woman who wants to avoid paternity establishment may delay the process 

several months by intentionally naming the wrong man as putative father. By using this 

ploy, applicants may gain approval for benefits while avoiding real cooperation. Similarly, 

clients may provide false names, invalid Social Security numbers, non-existence addresses, 

and the like. Two workers explain this problem, “Some make up everything. Anything to 

get us off their back. When we prove it false, they make up more.” And, “It bothers you 

when they do that. It is hard to prove that they are lying. How can you prove it?” 

Clients who seem to initially provide accurate information about noncustodial parents may 

subsequently fail to cooperate. For instance, if the man named as putative father is 

excluded by genetic testing, the client is required to name another man. If the client 

refuses to name another man, she may be designated noncooperative. To discourage 

clients from intentionally naming wrong men as putative fathers, one focus State instituted 

a policy that the client would be designated noncooperative if the first two men named 

were excluded by genetic testing, even if the client names a third man as putative father. 

However, this policy was challenged in court and the offices we visited in that State 

indicated they were not currently enforcing the policy.9 Clients may also fail to cooperate 

by not completing and returning agency documents. In one State, for example, the child 

support enforcement agency typically mails new clients an extensive form which must be 

completed and returned within 15 days. Workers report that because the form is quite 

detailed and, when paternity is in question, requests intimate information about the client’s 

personal relations, many clients fail to return the form. Clients who need paternity 

established for a child may also be required to complete and sign a voluntary paternity 

acknowledgment form to be considered cooperative.10 

Finally, clients can fail to cooperate by not appearing for appointments. A child support 

caseworker describes, “At first interviews, we have problems getting clients to show up. 

No contact is the greatest problem. [An] appointment is set and they do not show up. We 

have about 60 percent no-shows. If we get to the stage of genetic testing or court order, 

we generally have cooperation.” Our companion report on State efforts to improve client 

cooperation explores the causes of noncooperation by examining barriers that prevent 

some clients from cooperating, program characteristics that discourage cooperation, and 

strategies States use to improve client cooperation.11 

Front Line Child Support Staff Determine Each Client’s Cooperation Status, and 

Are Largely Comfortable With This Task Because Most Cases Are Fairly Obvious 

Local caseworkers are largely responsible for determining whether TANF clients are 

cooperating. If a client refuses to provide information during initial interviews, the 

interviewer - either a child support or public assistance worker - designates the applicant 

or client as noncooperative. Otherwise, the child support worker assigned a case is 

usually individually responsible for making a determination of cooperation or 

noncooperation. Only 22 percent of child support respondents report that supervisors are 

8
also routinely involved in cooperation determinations, although staff indicate that they 

often consult their supervisors when unique situations arise. 

Front line child support staff express comfort with their role as decision-maker, despite the 

great impact a noncooperation determination might have on a client. Workers explain that 

most cases of noncooperation are obvious because, by the time the case gets to them, the 

main reason for noncooperation is because of failure to appear for scheduled appointments 

or other events. Caseworkers point out that while it is often difficult to tell whether 

clients are completely and accurately providing all the information they have about 

noncustodial parents, they have no difficulty telling whether a client attends a scheduled 

appointment. Staff explain that when clients fail to appear for appointments, the main 

question is whether the client has a valid reason for not appearing. 

TANF Clients Typically Have Multiple Opportunities to Avoid Being Designated as 

Noncooperative by Making a Good Faith Effort to Cooperate 

To insure that clients are not unjustly penalized for noncooperation, both policy and 

practice in all six States give clients the benefit of the doubt regarding available 

information about noncustodial parents, permit rescheduling of missed appointments, and 

allow clients additional chances to complete required documents. Staff in 85 percent of 

local child support offices report that clients who make “good faith” efforts to provide 

information will not be penalized, even if they provide little information about 

noncustodial parents. One worker explains how staff generally view clients providing only 

sketchy information, “Usually good faith is determined by the client’s attitude. If the 

client gives consistent information, appears to be cooperative but lacks the knowledge, is 

unable to recall pertinent information despite careful prompting, we accept the client’s 

efforts.” 

Three States have specific forms which TANF clients may use to attest to a lack of 

additional knowledge. In two States, these forms also require clients to explain why they 

don’t know more about the noncustodial parent or putative father and what efforts they 

have made to gain additional information. Even after an attestation of lack of knowledge, 

child support staff in 85 percent of sample offices report they continue to contact clients to 

determine if more information has become available. Staff in two focus States report 

contacting clients in person, by telephone, or by mail at least annually to request any new 

information. One worker reports, “We still contact the client every three months to 

determine if she has new information.” Caseworkers also continue to pursue support by 

using the limited information they have to locate the noncustodial party. Staff report that 

automated systems regularly compare whatever information is available against relevant 

databases and alert caseworkers when data matches occur. 

Typically, if a client does not show up for an appointment, but calls to explain why they 

are not appearing, another appointment is arranged with no adverse consequences. One 

worker describes, “We always allow a second opportunity for the client to meet with us 

or contact us by phone.” If, however, clients do not make a phone call, or cannot 

9
demonstrate a valid reason for missing an appointment, they are likely to be designated 

noncooperative and face penalties. Also, some States are more stringent about keeping 

certain appointments - namely, appearing in court or for genetic testing - because other 

parties are often involved. In these cases, “no-show” clients are more likely to be 

designated noncooperative and may have to make extra efforts to demonstrate their 

cooperation. 

PENALTIES FOR NONCOOPERATION 

Even After Being Notified of Their Noncooperation Status, TANF Clients May 

Avoid Penalties or Have Benefits Reinstated by Cooperating, Yet Some Clients 

Do Not Take Advantage of These Opportunities 

All local public assistance respondents report that clients are mailed at least one notice 

informing them that they may be penalized for noncooperation, and many clients are 

mailed notices by both agencies. Clients are mailed a written notification of 

noncooperation in 88 percent of public assistance and 65 percent of child support offices 

we surveyed. Clients may also be notified of noncooperation by telephone from staff of 

one or both agencies. Even after a client is designated noncooperative, 90 percent of local 

child support respondents report they will allow TANF clients to change their status by 

cooperating prior to imposition of penalties. If clients call or come in to child support 

offices, staff indicate they will attempt to gather needed information or re-schedule an 

appointment, and alert the public assistance office that the client might be cooperating. 

However, child support respondents report that, once notified they have been designated 

as noncooperative, clients only sometimes (45 percent of respondents), rarely (26 

percent), or never (5 percent) act to avoid penalties. Staff explain two reasons why more 

clients may not take advantage of opportunities to avoid penalties. First, many clients may 

simply not act quickly enough because once they are notified, their grant may be reduced 

in only a few days. Forty-eight percent of child support respondents report clients have 20 

days or less to comply to avoid penalties, and another 30 percent say clients have 30 

days.12 Another reason clients may fail to avoid penalties involves the effectiveness of the 

threat of penalties. Staff from both agencies explain that the actual imposition, not the 

threat, of penalties is often needed to catch the attention of some TANF clients. 

After Clients Have Been Provided with Notice and Multiple Opportunities to 

Cooperate, States Impose Standardized Penalties for Noncooperation 

TANF clients who still fail to cooperate with child support enforcement after receiving 

multiple opportunities and sufficient notice face a variety of penalties in our six focus 

States. One State reduces the family’s cash assistance by 25 percent until the client 

cooperates. One State reduces the family’s cash assistance by a specific dollar amount 

($78), regardless of the total grant the family receives.13 One State has three tiers of 

penalties, effectively reducing the cash grant by 50 percent for a period of three months, 

10
followed by elimination of all cash assistance. One State removes the needs of the client 

when calculating the families cash grant for a period of six months, followed by 

elimination of all cash assistance. The remaining two focus States immediately eliminate 

all cash assistance. (Among the States, elimination of all cash assistance is often referred 

to as ‘full family sanction’ because children, as well as adult clients, are deemed ineligible 

for cash assistance, or ‘case closure’ because the families cease to be clients of the TANF 

program.) 

Each State’s penalties are standardized and appear to allow no variation among clients. 

That is, while local staff have great flexibility to work with individual clients to avoid 

penalties, staff do not have discretion to impose different penalties on different clients. 

Additionally, once penalties are imposed, workers indicate they cannot be removed until 

the noncooperation designation is lifted. All but two local public assistance respondents 

report they remove penalties, or reinstate benefits, only when the child support agency 

determines that a client has begun to cooperate. 

CONCLUSION 

Gaining cooperation from TANF clients is important to facilitating child support 

enforcement. Congress has long maintained that recipients of public benefits are obligated 

to assist States in pursuing support for their children. Client responsiveness can ease and 

speed the support enforcement process, particularly when paternity has not yet been 

established. 

All six of our focus States have implemented client cooperation policies compatible with 

the Federal mandates, including establishing guidelines for staff, allowing for use of 

exceptions, and imposing uniform penalties. Staff in both the public assistance and child 

support agencies appear to value client cooperation, and attempt to implement State 

policy in a way that is largely flexible and client-focused. This includes relying primarily 

on front line staff closest to the individual cases to determine whether clients have 

adequately cooperated. Although most TANF clients cooperate readily, gaining 

cooperation from some can prove difficult. In response, staff typically provide multiple 

opportunities for clients to give information and to make appointment deadlines, and 

appear concerned about legitimate barriers to cooperation. 

Nevertheless, shortfalls and difficulties in current practice remain. However, based on our 

review, there are good opportunities to address them in a practical way. Our companion 

reports discuss particular issues and potential problems in greater detail. These include 

breakdowns in communication between the public assistance and child support 

enforcement agencies, the relatively modest use of good cause exceptions, possible 

barriers and disincentives to cooperation, and potential solutions employed by our focus 

States. 

The Administration for Children and Families (ACF) did not provide comments in 

response to our draft report. 

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ENDNOTES 

1. See our companion report, Client Cooperation With Child Support Enforcement: Use of 

Good Cause Exceptions, OEI-06-98-00043, 2000. 

2. Social Security Act, Title IV, Part A., Sec. 408 (2). 

3. Social Security Act, Title IV, Part A., Sec. 409 (5). 

4. For information regarding gaining client cooperation with child support enforcement from 

individuals receiving Medicaid, but not TANF, see our report, Client Cooperation with 

Child Support Enforcement: Medicaid-Only Clients, OEI-06-98-00045, 2000. 

5. Public assistance and child support staff use the term “co-location” to describe two 

arrangements: when the two agencies share offices; and when child support staff is 

assigned to work at a local public assistance office either daily, or on a periodic schedule. 

For clarity, we call the former arrangement ‘co-location’ and the latter ‘out-stationing’. 

Forty-six percent of local child support offices we surveyed in focus States report using 

some form of co-location or out-stationing. 

6. Even fewer local child support respondents we surveyed report using these videos. 

7. Ibid, OEI-06-98-00043, 2000. 

8. For more information about interviews conducted by public assistance staff, see our 

companion report on the role of the public assistance agency, Client Cooperation with 

Child Support Enforcement: The Role of Public Assistance Agencies, OEI-06-98-00042, 

2000. 

9. See our report, Paternity Establishment: State Use of Genetic Testing, OEI 06-98-00054, 

1999. 

10. See our report, Paternity Establishment: Use of Voluntary Paternity Acknowledgments, 

OEI 06-98-00053, 2000. 

11. See our report, Client Cooperation with Child Support Enforcement: Challenges and 

Strategies to Improvement, OEI-06-98-00041, 2000. 

12. The date within the month may affect the amount of time an individual client has to 

comply because public assistance agencies typically reduce the next month’s grant check. 

13. Prior to welfare reform, this State received a waiver to test different penalties at select 

offices. Therefore, in some areas, the State immediately eliminates all cash assistance as 

penalties for noncooperation. 

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