Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

Janet Rehnquist 

Inspector General 

OCTOBER 2001 

OEI-05-00-00300 

Withholding Child Support 

Departmental Employees 

Obligations from 
OFFICE OF INSPECTOR GENERAL 

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

amended by Public Law 100-504, 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 Chicago Regional Office prepared this report under the direction of William C. Moran, 

Regional Inspector General and Natalie Coen, Deputy Regional Inspector General. Principal 

OEI staff included: 

REGION 

Victoria Dougherty, Program Analyst

Emily Melnick, Program Analyst

Kristen Masse, Program Analyst

Ray Balandron, Program Analyst

Elander Phillips, Program Inspections Assistant 

HEADQUARTERS 

Joan Richardson, Program Specialist

Brian Ritchie, Program Analyst

Barbara Tedesco, Mathematical Statistician

To obtain copies of this report, please call the Chicago Regional Office at 312-353-4124. 

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

http://www.hhs.gov/oig/oei 
EXECUTIVE SUMMARY 

PURPOSE 

To evaluate the wage withholding of child support from Department of Health and Human 

Services’ (HHS) employees. 

BACKGROUND 

On February 27, 1995, the President signed Executive Order 12953, which requires 

Federal agencies to: 

C conduct an annual cross-match of the Federal tax refund offset file with the payroll 

files of Federal agencies to identify Federal employees with child support 

delinquencies, 

C comply with all wage withholding requirements, and 

C act as model employers in facilitating the establishment and enforcement of child 

support orders. 

FINDINGS 

We Found Delinquent Obligors Without Wage Withholding Employed by the 

Department 

The 1995 Executive Order 12953 requires an annual match of the Federal tax refund 

offset file, indicating delinquent obligors, with the payroll files of Federal agencies. The 

intent of this match is to identify Federal employees with child support delinquencies to 

ensure enforcement of their support obligations. The Department last conducted an 

annual match in 1996. 

We conducted a match of the Federal tax refund offset file and the Department of Health 

and Human Services’ payroll file. This match resulted in a list of 215 delinquent 

employee-obligors, with an average delinquency of $7,295. As of May 30, 2000, wage 

withholding was in place for 139 and not in place for 76 of these delinquent employeeobligors. 

The Program Support Center, an operating division of HHS, conducts payroll services for 

the Department’s approximately 60,000 employees, including payroll deductions for child 

support payments. During the course of the inspection, the Office of Child Support 

Enforcement and the Program Support Center agreed to work together to periodically 

Withholding Child Support Obligations from Departmental Employees i OEI-05-00-00300 
conduct the cross-match to identify departmental employees who are delinquent child 

support obligors. 

In More Than Half the Sampled Cases, States Did Not Know That Delinquent 

Obligors Were Departmental Employees 

State systems typically match obligor information with State employment databases 

containing new hire and quarterly wage information from employers statewide. The 

National Directory of New Hires is the primary source for learning of Federal employment 

because Federal employees are not included in State employment systems. 

The Office of Child Support Enforcement assumes that States will learn from the National 

Directory of New Hires that an obligor is a Federal employee and act accordingly to 

pursue wage withholding. However, our examination of the case files for a sample of 45 

of the 76 employee-obligors, without withholding in place, revealed that in approximately 

22 cases the States did not learn that these obligors were departmental employees. The 

States either did not receive matches or did not determine from the matches that the 

obligor was, in fact, a Federal departmental employee. Upon learning of the obligors’ 

employment with the Department through our inspection, most of the States immediately 

issued wage withholding orders to HHS for these cases. 

More than Half of the Individuals Without Wage Withholding Were Indian Health 

Service Employees 

We found that 44 of the 76 delinquent employee-obligors without wage withholding were 

Indian Health Service employees. In 19 of 45 sampled cases, tribal jurisdiction issues 

contributed to the absence of income withholding. The Department has the authority to 

withhold wages for all Federal employees for the payment of child support, regardless of 

Native American tribal membership or residency, or employment on a reservation. 

Caseworkers often do not know that Native American obligors are Federal employees or 

that enforcement should be pursued for Indian Health Service cases. State enforcement 

policies involving Tribal jurisdiction are varied and complex. Many State caseworkers do 

not pursue these cases. 

The Department Enters All Income Withholding Orders Received; However, Some 

Data Entry Errors Occur 

The Program Support Center process for entering income withholding orders appears to 

be orderly and timely. Through a review of 51 cases with withholding in place, we found 

that the majority were entered into the system within 10 days of order receipt. State 

records indicated that income withholding orders were sent to the Department in 8 of the 

45 sampled cases that did not have withholding in place. However, the Program Support 

Center was not responsible for the lack of withholding in these eight cases. In four cases, 

Withholding Child Support Obligations from Departmental Employees ii OEI-05-00-00300 
the States sent wage withholding orders to the wrong HHS office. The other cases were 

inactive because current support had been paid in full. 

We found data entry errors in the amounts to be withheld and recipient addresses in some 

cases. In 8 out of 49 cases (16 percent) reviewed with withholding in place, the amounts 

to be withheld on the entry forms differed from the required amounts on the court orders. 

Entry forms with errors were rarely signed by a supervisor. 

RECOMMENDATIONS 

While conducting our inspection, OCSE worked closely with us to solve problems 

associated with the 76 departmental employees without wage withholding. In addition, 

OCSE is an active and cooperative partner with the Department in responding to our 

recommendation to institutionalize a process to ensure Departmental compliance with the 

Executive Order. Additional steps are also needed, however. We recommend: 

C The Department designate a senior departmental official the responsibility for 

ensuring compliance with the Executive Order, 

C The Office of Child Support Enforcement help States effectively use the National 

Directory of New Hires, 

C The Office of Child Support Enforcement provide guidance to States on issuing 

withholding orders for Indian Health Service employees, and 

C The Program Support Center increase withholding accuracy. 

AGENCY COMMENTS 

We received comments from the Office of Child Support Enforcement (OCSE), the 

Program Support Center (PSC) and the Indian Health Service (IHS). The OCSE is in 

agreement with our findings and recommendations. The PSC agrees this is an important 

initiative and provided technical comments and clarification. The IHS agrees with our 

recommendation pertaining to IHS employees. Where appropriate, we changed the report 

to reflect their comments. The full OCSE, PSC and IHS comments are contained in 

Appendix C. 

One matter unresolved at this time is the designation of a senior official to oversee 

Departmental compliance with the Executive Order. Considerable improvement can be 

made without taking this step, but an overall coordinator could facilitate a more cohesive 

and effective Department-wide response. 

Withholding Child Support Obligations from Departmental Employees iii OEI-05-00-00300 
TABLE OF CONTENTS 

PAGE 

EXECUTIVE SUMMARY

INTRODUCTION ..................................................... 1

FINDINGS ................................................................ 8

Delinquent Obligors Without Wage Withholding Employed by the Department .......... 8

States Did Not Know That Delinquent Obligors Were Departmental Employees ......... 9

More Than Half Without Wage Withholding Were IHS Employees .................. 10

The Department Enters All Orders Received; Some Data Entry Errors Occur .......... 12

RECOMMENDATIONS ............................................... 14

AGENCY COMMENTS .................................................... 18

APPENDICES

A. Profile of Employee Obligors ............................................ 19

B. Reasons for Non-Withholding ........................................... 21

C. Agency Comments .................................................... 24

Withholding Child Support Obligations from Departmental Employees iv OEI-05-00-00300 
INTRODUCTION 

PURPOSE 

To evaluate the wage withholding of child support from Department of Health and Human 

Services’ (HHS) employees. 

BACKGROUND 

The Child Support Enforcement program was created in 1975 with the addition of Part D 

to Title IV of the Social Security Act. State Child Support Enforcement Agencies, also 

known as IV-D agencies, are responsible for administering the program, including locating 

absent parents, establishing paternity, establishing orders for financial and medical support, 

enforcing the orders, and collecting and disbursing the support due. The Federal Office of 

Child Support Enforcement (OCSE) contributes matching funds, sets requirements for 

certain design features, and monitors and evaluates State child support program 

implementation. The OCSE also provides State child support agencies with technical and 

operational assistance to carry out program functions. 

In fiscal year (FY) 1998, State child support agencies had a total caseload of just over 

19.1 million cases. Approximately 11.5 million of these cases had child support orders 

established and in effect. The OCSE does not have data available on the number of 

Federal employees or departmental employees who are child support obligors. 

Executive Order for Federal Agencies to be Model Employers in the Collection of 

Support 

On February 27, 1995, the President signed Executive Order 12953 establishing the 

Federal Government as a model employer in facilitating the establishment and enforcement 

of child support orders. The Order states that, as the Nation’s largest single employer, the 

Federal Government should set an example of leadership in the collection of support from 

employees. The Executive Order requires Federal agencies to cooperate in efforts to 

establish paternity and child support orders, as well as enforce the collection of child and 

medical support. 

The Executive Order requires an annual cross-match of the Federal tax refund offset file 

with the payroll files of Federal agencies to identify Federal employees with child support 

delinquencies. The criteria for delinquency for the tax refund offset file are as follows: 

the obligor must owe arrears of $150 or more if the custodial parent is on Temporary 

Withholding Child Support Obligations From Departmental Employees 1 OEI-05-00-00300 
Assistance to Needy Families (TANF) or $500 or more if the custodial parent is not on 

TANF. 

The records generated from the tax offset-payroll file match are to be sent to the 

appropriate State child support agency to pursue wage withholding or other enforcement 

actions. In addition, under the Order, the Office of Personnel Management is required to 

annually publish in the Federal Register a list of contacts for each Federal Agency 

designated to receive income withholding orders for employees. Upon receipt of 

withholding orders, Federal agencies must comply with all wage withholding 

requirements. 

The Office of Child Support Enforcement last conducted a match of Federal payroll data 

with the tax refund offset file in October 1996. This match identified 225 employees of 

the Department of Health and Human Services as delinquent obligors. The match of these 

two files, required annually, has not been conducted by OCSE since 1996, due to their 

determination that pro-active matching of the National Directory of New Hires and the 

Federal Case Registry, enacted in 1996, supercedes the required payroll-tax offset file 

match. 

National Directory of New Hires and the Federal Case Registry 

The 1996 Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) 

mandated the creation of the National Directory of New Hires, a national database of 

employment data, herein referred to as the Directory, and the Federal Case Registry, a 

national database of child support case abstracts. 

The National Directory of New Hires contains three types of employment data compiled 

from State Employment Security Agencies and Federal Employers: State employment 

information on all new hires, quarterly wages for all employees and State unemployment 

insurance claim data. Federal employers, with the exception of certain security agencies, 

are required to submit new hire employment data and quarterly wage data on Federal 

employees to the Directory on a routine basis. 

The PRWORA requires routine matching between the National Directory of New Hires 

and the Federal Case Registry (FCR) to generate information on obligors for “locate” and 

enforcement purposes. Since October 1, 1998, matches have been continually run 

between the Directory and the FCR.1 When a match is identified, the employment 

information for the obligor is sent to the State. Through this system, States should receive 

recent employment information for all obligors employed by the Federal 

1 Pro-active matching of the NDNH and the expanded Federal Parent Locator Service began in October 1997, prior to full 

implementation of the FCR. 

Withholding Child Support Obligations From Departmental Employees 2 OEI-05-00-00300 
government. It is then the States’ responsibility to seek wage withholding through the 

Federal employer, if it is not already in place. 

Wage Withholding as Primary Enforcement Tool 

The most widely used and effective child support enforcement tool is wage withholding. 

Nearly 60 percent of all child support is collected through the withholding of wages by 

employers. 

Since the start of the child support program in 1975, State IV-D agencies have been 

authorized by the Federal Government to garnish wages and other payments for 

enforcement of child support obligations. The child support amendments of 1984 required 

IV-D agencies to include a provision for wage withholding in the establishment of all new 

orders and the modification of existing orders. States were required to implement wage 

withholding when an arrearage accrued that was equal to the amount of support payable 

for one month. The Family Support Act of 1988 greatly expanded wage withholding by 

requiring States to begin immediate wage withholding for all new or modified IV-D orders 

as of November 1990, regardless of whether arrears exist.2 

Upon receipt of a child support withholding notice, employers must provide a copy of the 

notice to the employee and begin withholding within 30 days. Employers are to continue 

withholding the required amount until official notification to stop is received. 

Additionally, the employer is required to notify the child support agency if the employment 

ends or is interrupted. The Treasury Department sends withheld payments from Federal 

employees to the States or the custodial parent. 

Wage Withholding Within the Department of Health and Human Services 

The Program Support Center (PSC), an operating division of HHS, conducts payroll 

services for all of the Department’s approximately 60,000 employees. As part of its 

payroll operations, the Center oversees the Debt Management and Collection System for 

the Department. Through this system, all payroll deductions for child support payments 

are processed. 

State child support agencies are required to send all withholding orders to the Office of 

General Counsel for HHS. The Office then sends the income withholding orders to the 

Special Activities Branch of the Program Support Center for processing. The Special 

Activities Branch is responsible for processing all mandatory withholding orders. If 

withholding orders are received by local Department employment sites or personnel 

2 The law allows for exceptions to immediate wage withholding if good cause not to withhold is determined in court or a 

written agreement is reached between both parties for an alternative arrangement. 

Withholding Child Support Obligations From Departmental Employees 3 OEI-05-00-00300 
offices, they are to be forwarded to the Office of General Counsel or the Special Activities 

Branch and processed centrally. 

Child Support Enforcement for Indian Tribes 

State child support agencies are responsible for establishing and enforcing child support 

orders for all IV-D cases opened in the State. However, the Office of Child Support 

Enforcement recognizes that Tribal sovereignty may prohibit State child support agencies 

from enforcing certain child support orders. Currently, each State agency determines 

whether to pursue the establishment and enforcement of orders in cases involving Tribal 

jurisdiction. 

Unlike other employers, the Federal Government has the authority to withhold wages for 

all Federal employees for the payment of child support, regardless of Native American 

tribal membership, residency, or employment on a reservation. 

State child support agencies and Tribes can contract for the Tribes to provide child 

support services. State agencies receive Federal financial participation for these costs, as 

long as the Tribal entity “demonstrates that it has an established Tribal court system with 

the authority to establish paternity, establish, modify or enforce support orders or to enter 

support orders in accordance with child support guidelines established or adopted by such 

Tribal entity.”3 Currently, 11 Tribes operate child support programs in whole or in part 

under cooperative or contractual agreements with eight State child support enforcement 

agencies. The Tribes, which operate under such cooperative arrangements with States, 

are not required to adhere to Federal income withholding requirements or to honor income 

withholding orders from State agencies. 

However, the PRWORA authorized direct Federal funding for Tribes operating child 

support enforcement programs. The PRWORA interim final rule requires Tribes to 

comply with all Federal child support provisions in order to receive direct Federal funding, 

including issuing wage withholding orders to the employers of all obligors. The interim 

final rule also requires Tribes to recognize child support orders issued by other Tribes, 

Tribal organizations, and States. Thus, funded Tribes will be required to honor income 

withholding orders issued by State child support enforcement agencies. 

Related Prior Office of Inspector General Work 

In August, 2000, the Inspector General released “Child Support Enforcement State 

Disbursement Units: Sharing the Implementation Experiences of Six States,” OEI-06-00-

00041. This study described States' experiences in developing and operating State 

Disbursement Units. The Inspector General found that State Disbursement Unit 

3 OCSE Action Transmittal, July 28, 1998 AT-98-21 

Withholding Child Support Obligations From Departmental Employees 4 OEI-05-00-00300 
managers cited particular difficulties processing checks issued by Federal agencies. 

According to the managers, Federal checks often contain inadequate or confusing 

information, are sometimes sent to the wrong location, and may be submitted too early to 

allow proper disbursement to custodial families. The OIG recommended that OCSE 

encourage improved performance by Federal government payers by collaborating with 

States so that States can communicate their problems and potential solutions. 

The Office of Inspector General conducted an inspection on Child Support and the 

Military, OEI-07-90-02250, released in June 1993. This report found low collections in 

military cases due to challenges child support staff experienced locating absent parents; 

lack of training of child support staff to handle military cases; and inconsistent wage 

withholding requests submitted to Military Finance Centers. A recommendation to 

establish a standard wage withholding request form was implemented. 

In August 1997, the Inspector General released Grantees and Providers Delinquent In 

Child Support, OEI-07-96-00390, examining Departmental compliance with a September 

1996 executive order requiring Federal agencies to offset Federal payments and deny 

Federal loans to delinquent obligors. The report examined child support payment 

compliance by a sample of physicians receiving Medicare payments and a sample of 

individuals receiving grants or payments through the National Health Services Corp and 

the National Institutes of Health. The Inspection found that three out of every 1,000 

providers or grantees in the study universe were in arrears, totaling $21.5 million. 

SCOPE AND METHODOLOGY 

In this inspection, we examined whether wage withholding was occurring for all 

Department of Health and Human Service employees who are delinquent child support 

obligors. Where wage withholding was in place, we determined whether the withholding 

was accurate and timely. Where withholding was not in place, we examined sampled case 

records to determine why it was not in place. We also analyzed the payment records on 

the sampled cases to determine the amount of support uncollected due to the absence of 

withholding. In addition, we collected descriptive information on the processes used to 

locate obligors and establish wage withholding. 

To identify the universe of departmental employees who are indicated as delinquent 

obligors on the tax refund offset file, we conducted a match of the Department’s payroll 

file with the Federal tax refund offset file. We matched 61,325 individuals who had been 

employees of the Department of Health and Human Services for at least three months as 

of May 30, 2000, with the 4,501,494 individuals who were obligors in arrears on the 

Federal tax offset file as of July 31, 2000. This resulted in a list of 239 individuals 

matched by Social Security Number (SSN). 

Withholding Child Support Obligations From Departmental Employees 5 OEI-05-00-00300 
We then compared each individual’s name on the tax refund offset file with the name on 

the payroll file to verify that these 239 matches were correct. We found 20 cases in which 

the same SSN had been used to identify 2 different people. We sent these SSNs to the 

Social Security Administration and requested the correct name for each case. We found 

that 18 of the SSNs were incorrect on the tax offset file and 2 others were incorrect on the 

payroll file. All 20 individuals were dropped from our universe. An additional 4 

individuals were eliminated due to death, resignation or closed cases, resulting in a 

universe of 215 employee-obligors. Three of the employees had died or resigned prior to 

the date of our payroll file extract. The child support case of one employee-obligor was 

closed prior to the date of the tax offset file extract. 

We matched the 215 employee-obligors against the payroll office’s Debt Management 

Collection System to determine whether wage withholding was in place as of May 30, 

2000. We found that withholding was not in place for 76 of these 215 employee-obligors. 

To check the accuracy of the payroll office’s withholding process, we pulled a random 

sample of 51 of the 139 employee-obligors who had wage withholding in place. For each 

sampled employee, we compared the court order received to the data entered into the debt 

management system and then to the payroll data transmitted to the Treasury Department. 

Through this comparison, we assessed whether the withheld wages were transmitted in a 

timely manner, to the appropriate party and for the correct amount. 

To determine why withholding was not in place for the other 76 employee-obligors, we 

pulled a stratified-cluster sample of 45 employee-obligors, stratified by State in which the 

order is based. We divided the 27 States containing the cases in our universe into three 

strata, based on the number of employee-obligors in the State. We selected all five States 

in our first strata, consisting of States with five or more employee-obligors. We randomly 

selected two of the four States in our second strata, consisting of States with three or four 

employee-obligors. We randomly selected two of the 18 States in our third strata 

consisting of States with one or two employee-obligors. 

The resulting sample is depicted in the following chart: 

Stratum 1 Stratum 2 Stratum 3 

State AZ ND CA MD NM GA MT IA MO 9 States 

No. of NCPs* 9 8 7 6 5 3 3 2 2 45 NCPs 

*NCPs = Non-custodial parents (employee-obligors) 

The data was not weighted to project our findings. Rather, our intention was to illustrate 

the scope and nature of the problems associated with the absence of wage withholding. 

Withholding Child Support Obligations From Departmental Employees 6 OEI-05-00-00300 
We reviewed the case files for each of the employee-obligors in our sample on-site in the 

State child support offices.4 We analyzed steps used to locate the obligor, attempts to 

establish wage withholding and payments missed in the absence of withholding. 

To obtain information on the processes used by caseworkers to locate obligors and 

establish wage withholding, we interviewed local office caseworkers in two offices in each 

State in our sample. We also interviewed State policy staff responsible for oversight and 

guidance pertaining to “locate” and withholding. In addition, we reviewed copies of the 

income withholding forms and accompanying instructions sent to employers in the 

sampled States. 

We also interviewed staff of the Department’s Special Activities Branch who are 

responsible for processing wage withholding orders for departmental employees. 

All data collection occurred between June and November 2000. 

Our review of the withholding process for departmental employees was limited to 

employees who were indicated as delinquent child support obligors on the Federal tax 

refund offset file. We did not determine the total universe of employees who owe child 

support, because there is no complete data set available to make this determination. 

We also did not review the enforcement of health insurance support from Federal 

employees. We did not examine compliance with elements of the Executive Order 

pertaining to Federal employer cooperation in “locate” and the service of legal process. 

Our review was conducted in accordance with the Quality Standards for Inspections 

issued by the President’s Council on Integrity and Efficiency. 

4 We did not review cases on-site in Montana. The State IV-D Director informed us that they knew the 3 employee-obligors 

were HHS employees and that support was not in place for them because they were employed on an Indian reservation. The 

State office sent us the other requested data. 

Withholding Child Support Obligations From Departmental Employees 7 OEI-05-00-00300 
FINDINGS 

N

We Found Delinquent Obligors Without Wage Withholding 

Employed by the Department 

The 1995 Executive Order 12953 requires an annual match of the Federal tax refund 

offset file, indicating delinquent obligors, with the payroll files of Federal agencies. The 

intent of this match is to identify Federal employees with child support delinquencies to 

ensure enforcement of their support obligations. The Department last conducted an 

annual match in 1996. With the implementation of the Federal Case Registry and National 

Directory of New Hires in 1996, the Department assumed that this new match would both 

identify all delinquent obligors and trigger the wage withholding process for departmental 

employees. 

We conducted a cross-match and found 215 delinquent departmental employeeobligors, 139 of whom have income withholding in place and 76 of whom do not 

We conducted a match of the Federal tax refund offset file, indicating delinquent support 

obligors, and the Department of Health and Human Services’ payroll file. This match 

resulted in a list of 215 delinquent employee-obligors, with an average delinquency of 

$7,295. Therefore, although we cannot determine the universe of employee-obligors in 

the Department, we know that there are at least 215 employees delinquent in paying 

support. A profile of the 215 employee-obligors can be found in Appendix A. As of May 

30, 2000, wage withholding was in place for 139 (65 percent) of these delinquent 

employee-obligors and not in place for 76 (35 percent). 

We reviewed payments missed in the months in which a sample of 45 of the 76 employeeobligors without withholding in place were employed by the Department and were 

obligated to pay support between December 1998 and May 2000. Through this review, 

we determined that if withholding had been in place, $128,893 in additional support would 

have been collected from these 45 employees. 

The Program Support Center has agreed to conduct the cross-match 

As of June 2000, HHS was withholding wages for child support and/or alimony on a 

mandatory basis for 569 employees and on a voluntary basis for 8 employees. The 

Program Support Center (PSC), an operating division of HHS, conducts payroll services 

for all of the Department’s approximately 60,000 employees. As part of its payroll 

operations, the Center oversees the Debt Management and Collection System for 

the Department. Through this system, all payroll deductions for child support payments 

are processed. 

The Special Activities Branch is responsible for processing all mandatory withholding 

orders. The Program Support Center agreed that the Special Activities Branch will work 

Withholding Child Support Obligations From Departmental Employees 8 OEI-05-00-00300 
with the Office of Child Support Enforcement to periodically conduct a cross-match to 

identify delinquent Department child support obligors. 

In More Than Half the Sampled Cases, States Did Not Know 

That Delinquent Obligors Were Departmental Employees 

State systems typically match obligor information with State employment databases 

containing new hire and quarterly wage information from employers statewide. 

Additionally, the majority of State systems receive matches, indicating employment 

information, from the National Directory of New Hires. The NDNH is the primary source 

for learning of Federal employment because Federal employees are not included in State 

employment systems. 

The Office of Child Support Enforcement sends matches generated by the Federal Case 

Registry and the National Directory of New Hires directly to the States’ child support 

enforcement agencies’ computer systems on a routine basis. In most of the States we 

visited, States report that the National Directory employer information automatically 

populates the employment information screen of the obligor with a matched SSN. The 

State system then uses this employer address to issue a wage withholding order to the 

employer. 

The caseworkers we interviewed primarily rely on automated “locate” searches to find the 

employment of an obligor. Most of the nine sampled States we visited report that their 

child support systems use this information to automatically generate a withholding order 

to the listed employer. The Office of Child Support Enforcement, however, only 

recognizes two of our nine sample States as having fully automated wage withholding at 

the time of our study. According to OCSE, it is possible that NDNH information may 

sometimes be altered by caseworkers or overwritten by in-State locate sources. The 

OCSE has found that many States have difficulty maintaining the integrity of their master 

employer table. 

States’ lack of knowledge of departmental employment contributes to the 

absence of wage withholding 

The Office of Child Support Enforcement assumes that States will learn from the NDNHmatches that an obligor is a Federal employee and act accordingly to pursue wage 

withholding. However, we found that in many cases, the States either did not receive 

matches or did not determine from the matches that the obligor was, in fact, a Federal 

departmental employee. 

Our examination of the case files for a sample of 45 of the 76 employee-obligors without 

withholding in place revealed that in approximately 22 cases the States did not learn that 

these obligors were departmental employees. Seventeen of the 22 departmental 

employees were employed by the Indian Health Service. 

Withholding Child Support Obligations From Departmental Employees 9 OEI-05-00-00300 
Upon learning of the obligors’ employment with the Department through our inspection, 

most of the States immediately issued wage withholding orders to HHS for these cases. 

The sampled States’ quick response demonstrates that the information generated by the 

National Directory of New Hires-Federal Case Registry match may not be used by the 

States to ensure enforcement of departmental employees, as intended in the Executive 

Order. Had the States been able to ascertain departmental employment more readily, the 

intention of the Executive Order to ensure enforcement of the child support obligations of 

federal employees could have been better fulfilled. 

State systems may not be able to effectively use National Directory of New Hires’ 

addresses 

State child support staff indicated State system difficulties with the NDNH addresses. In 

some States, the NDNH matches are read through a centralized employer address 

database to verify address information. In these cases, if the match lists “HHS” as the 

employer, while the existing database reference for the matching employer identification 

number is the “U.S. Department of Health and Human Services,” the system may reject 

the match or register it to an exception report. The NDNH also does not indicate 

employment status. One respondent suggested that this creates problems if the obligor is 

only employed intermittently or part-time with the Department, while holding a full-time 

job elsewhere. 

The Office of Child Support Enforcement’s “NDNH Guide for Data Submission” requires 

Federal employers to use the address of “the entity that employs the individual” as the 

employer address in the NDNH. For departmental employees, the Program Support 

Center address is hard coded as the primary address. The Guide also gives employers the 

option of submitting a second address which should be “where an employer receives child 

support wage withholding orders.” 

During our data collection, we found that the Department was not submitting the second 

optional address for wage withholding. As a result of our inspection, the Department 

took corrective action to ensure that beginning in January 2001, the Office of the General 

Counsel was hard coded in the optional employer address category. States’ access to two 

addresses for departmental employees will help to ensure that departmental employees are 

correctly identified by States and subsequently, that wage withholding orders are sent to 

the Department. 

More Than Half of the Individuals Without Wage Withholding 

Were Indian Health Service Employees 

In some cases, State records indicate the physical employment sites, such as an Indian 

Health Service hospital, rather than the Program Support Center. This address 

information causes caseworkers to perceive departmental employees as Tribal employees. 

In sampled States, when work sites are located on Indian reservations, income withholding 

orders are usually not pursued. If departmental employment had been readily 

Withholding Child Support Obligations From Departmental Employees 10 OEI-05-00-00300 
apparent, the Tribal jurisdiction issues likely would not have been a barrier to withholding 

in most States. A more detailed chart, indicating reasons for non-withholding on each 

case, is in Appendix B. 

In 20 of the 45 cases, tribal jurisdiction issues contributed to the absence of income 

withholding. As is the case for our universe, these obligors are paid Federal wages by the 

Program Support Center. The Department has the authority to withhold wages for all 

Federal employees for the payment of child support, regardless of Native American tribal 

membership or residency or employment on a reservation.5 Some child support staff are 

not aware of this authority. 

The following chart depicts the impact of Tribal issues on income withholding for IHS 

employees: 

No. of Cases Tribal Jurisdiction Issues Contributing to Absence of Withholding 

5 Locate not pursued because obligor is Native American 

8 IWO not sent because obligor is Native American 

4 IWO sent to local IHS site and not forwarded to PSC 

3 Tribes responsible for the cases did not issue IWOs 

State enforcement policies involving Tribal jurisdiction are varied and complex. 

Many caseworkers do not pursue these cases. 

State and local staff reported difficulty enforcing child support cases when the obligor is a 

Tribal member, resides or works on a reservation. In general, child support agencies have 

no authority to enforce State orders on Tribal land. Factors States consider to determine 

jurisdiction include the residency of the obligor, the location of his or her work-place, 

tribal membership, and the child’s tribal membership or residency. Respondents indicated 

that they rely on an assortment of rules to determine jurisdiction and usually decide on a 

case-by-case basis. 

Caseworkers in our 9 States, with average caseloads of 800, must prioritize their 

workloads. Several caseworkers indicated that they do not pursue cases involving Native 

Americans because the State is unable to enforce collections from non-Federal Tribal 

employees. Some States’ computer systems have codes indicating lack of jurisdiction for 

Tribal reasons, which further discourages caseworkers from pursuing these cases. 

5 Social Security Act, Title IV, Section 459 [42 U.S.C. 659] (A) 

Withholding Child Support Obligations From Departmental Employees 11 OEI-05-00-00300 
Caseworkers often do not know that Native American obligors are Federal 

employees or that enforcement should be pursued for Indian Health Service 

cases 

In several cases, the caseworker appeared to know that the obligor was working at an 

Indian Health Service (IHS) site. However, the caseworker did not know that the obligor 

was a Federal employee and, therefore, did not pursue income withholding. In some 

cases, respondents knew Native American obligors were Federal employees, but did not 

pursue enforcement because of the erroneous belief that these cases cannot be enforced. 

In fact, a couple of State policy staff respondents indicated that if the wages are earned on 

a reservation, wage withholding cannot be pursued regardless of the payer source. 

In some cases, income withholding orders were not in place because the Tribe 

responsible for enforcing the cases did not issue withholding orders 

Two of our sampled States, New Mexico and Arizona, contract with the Navajo Nation 

for the Nation to provide Tribal child support enforcement services. Local Navajo 

caseworkers in New Mexico reported including income withholding orders on all cases 

established administratively. However, caseworkers report that most cases established in 

Navajo court do not include income withholding provisions. Modifying an order to 

include income withholding is a multi-step process that can take a long period of time. In 

three of the cases we reviewed, employment with the Department was known, but an 

income withholding order had not been sent due to Tribal court procedures. 

The Department Enters All Income Withholding Orders 

Received; Some Data Entry Errors Occur 

The payroll office’s process for entering income withholding orders appears to 

be orderly and timely 

When the PSC receives an income withholding order, either through the Office of General 

Counsel, or directly from a State child support agency, an accounting technician records 

all of the elements required for the Debt Management Collection System on a one-page 

form. Upon a supervisor’s approval, the technician enters the data into the system. 

Through a review of 51 cases with withholding in place, we found that the majority were 

entered into the system within 10 days of the income withholding orders’ receipt. 

The data in the debt management collection system is transmitted electronically to the 

Treasury Department at the end of each pay period. The Treasury Department generates 

and distributes paychecks and withheld payments based on this transmission. Our 

comparison of the data entered into the Debt Management Collection System to a printout of the data transmitted to the Treasury verified that the fields in the system are 

correctly transmitted within one day of the end of the pay period. 

Withholding Child Support Obligations From Departmental Employees 12 OEI-05-00-00300 
State records indicated that income withholding orders were sent to HHS in 8 of the 45 

sampled cases that did not have withholding in place at the time of data collection. The 

Program Support Center was not at fault for the lack of withholding for any of these 

cases. Four of these cases were sent to the wrong HHS address, three were inactive 

because the current support debt had been paid in full, and one was implemented after our 

review period. A chart depicting the reasons for non-withholding on all cases is included 

in Appendix B. 

We found data entry errors in the amounts to be withheld and recipient addresses 

Although the Payroll Office’s process for entering income withholding orders into the debt 

management collection system appears to be orderly, errors occur. In 8 of 49 cases6

 (16 

percent) reviewed, the amounts to be withheld on the entry forms differed from the 

required amounts on the court orders. In six of the eight cases, the difference was due to 

omission of the arrears or the current support payment. In the other two cases, 

withholding was more than it should have been based on the court order. The address to 

which the withheld payments should be sent differed from the addresses on the court 

orders in 6 of the 51 cases (12 percent). 

The absence of supervisor approval appears to be a factor in the cases in which the 

withheld amounts were incorrect. Seven of the eight entry forms with errors in the 

withheld amounts were not signed by a supervisor. Overall, entry forms were not signed 

by a supervisor in 46 percent of the reviewed cases. While the lack of supervisor approval 

appears to be significant in the cases with errors related to the amount withheld, it does 

not appear to be a significant factor in address errors. 

The payroll office has no formal process to ensure local HHS offices forward 

income withholding orders 

Income withholding orders sometimes come to the Program Support Center via local 

Department office sites. According to the Center, all payroll liaisons in local offices have 

been verbally informed to forward orders to the Program Support Center. There is no 

written procedure instructing local sites of this requirement, nor any PSC oversight to 

ensure compliance. 

The lack of a formalized forwarding process appears to be a problem in cases in which 

obligors work for the Indian Health Service (IHS). In 4 of our 45 cases, the State child 

support staff sent income withholding orders to HHS local offices and the orders were not 

forwarded to the Program Support Center. The IHS was the employer for three of these 

four cases. 

6 The universe of cases for which the withheld amounts were reviewed was 49 rather than 51 because in 2 of the cases, the 

required withheld amount was greater than 50% of the obligor’s disposable income. The Federal Consumer Protection Act 

limits garnishment to 50% of disposable earnings for an obligor who supports a second family and 60% to an obligor not 

supporting a second family. 

Withholding Child Support Obligations From Departmental Employees 13 OEI-05-00-00300 
RECOMMENDATIONS 

The Department Should Designate a Senior Departmental 

Official the Responsibility for Ensuring Compliance with the 

Executive Order 

While conducting our inspection, OCSE and PSC worked closely with us to solve 

problems associated with the 76 departmental employees without wage withholding. In 

addition, they have been active partners with the Department in responding to our 

recommendation to institutionalize a process to ensure that the Department is in 

compliance with the Executive Order. 

We recognize the Office of Child Support’s efforts to ensure that Federal agencies submit 

timely and accurate employment information to the National Directory of New Hires and 

that States are able to use this data effectively. Since PRWORA, OCSE has focused on 

the development of the National Directory of New Hires and the Federal Case Registry, 

which are systems to provide States with much needed employment data. Continuing to 

ensure these systems function effectively is vital to departmental and State efforts to 

withhold wages for delinquent child support obligors. 

We recommend that the Department now focus on the outcomes of these systems. In 

particular, to ensure compliance with the Executive Order, the Department must focus on 

State and departmental actions that are necessary to withhold wages for all departmental 

obligors. During the course of assisting with this inspection, OCSE and PSC agreed to 

work together to periodically conduct the cross-match. Through this match, the 

Department will determine which departmental employees are delinquent child support 

obligors and do not have withholding in place. The OCSE and PSC should work together 

to release the employment information to the States responsible for enforcing the 

delinquent employee-obligors’ wage withholding orders and to ensure implementation of 

orders received. The OCSE and PSC agreed to do so. 

In addition, the Department must meet the other requirements of the Executive Order, 

which include informing and sensitizing employee obligors about their child support 

obligation and the Department’s obligation to withhold wages. We suggest that the Office 

of Human Resources (OHR) of the Assistant Secretary for Management and Budget 

should assume responsibility to meet the Executive Order requirements of routinely 

informing departmental employees about: 

C the Department’s obligation to cooperate in efforts to establish paternity and child 

support orders, 

C the Department’s obligation to enforce the collection of child and medical support, 

C the Department’s obligation to withhold wages for all child support obligors for whom 

a State issues a wage withholding order to the Department, 

Withholding Child Support Obligations From Departmental Employees 14 OEI-05-00-00300 
C departmental employees’ responsibility to be in compliance with their child support 

obligations, and 

C actions departmental employees should take and services that are available to them to 

ensure that their children are provided the support to which they are legally entitled. 

The Department should assign a senior departmental official the responsibility to organize 

and oversee the overall effort to meet the requirements of the Executive Order and report 

progress and compliance to the Secretary on a routine basis. 

The Office of Child Support Enforcement Should Help States 

Effectively Use the National Directory of New Hires 

As our findings demonstrate, State child support staff did not appear to know that many 

sampled employee-obligors were Federal employees. State child support staff’s inability 

to learn of departmental employment from the NDNH for employee-obligors indicates that 

States remain in need of assistance in order to efficiently and effectively use the NDNH to 

issue wage withholding orders for departmental employees. 

Specifically, OCSE should continue to work with States to improve or enhance their 

automated processing of NDNH data and automated wage withholding. This should 

include encouraging States to establish processes to verify NDNH information, even if 

alternative employer information exists. In addition, States should be encouraged to 

enhance their automated systems to be able to capture the second wage withholding 

address provided by the Department. 

The Office of Child Support Enforcement Should Provide 

Guidance to States on Issuing Withholding Orders for Indian 

Health Service Employees 

In 19 of the 45 sampled cases, tribal jurisdiction issues contributed to the lack of income 

withholding. Additionally, 44 of the total 76 delinquent employee-obligors without 

withholding in place are employed by the Indian Health Service (IHS). As all of the 

obligors are Federal employees, tribal jurisdiction should not have prevented wage 

withholding in any of these cases. 

Of the 139 delinquent employee-obligors with withholding in place, 61 are employed by 

IHS, many on reservations. Clearly, income withholding orders are regularly implemented 

for IHS employees without legal challenges. Withholding orders should be in place for all 

delinquent IHS employee-obligors. 

Withholding Child Support Obligations From Departmental Employees 15 OEI-05-00-00300 
To ensure withholding for all IHS employee-obligors, OCSE should: 

C Provide guidance to State child support agencies clarifying their authority to enforce 

wage withholding for all Federal employees, regardless of where the wages are earned. 

C Encourage State agencies to examine whether obligors employed by reservation 

medical centers are departmental employees. States could provide local staff with lists 

of IHS sites to cross-reference with employer addresses on reservations. 

C Instruct States to send all income withholding orders for Indian Health Service 

employees to the OGC, the designated withholding agent for the Department. 

The Program Support Center Should Increase Withholding 

Accuracy By: 

Ensuring review of all withholding entries 

C Review all entry forms carefully, ensuring that all of the data from the court orders has 

been correctly entered and that the form has been signed by a supervisor. 

We found errors in the entry of withholding amounts in the withholding system operated 

by the Program Support Center (PSC). Entry forms with errors in the withhold amounts 

were rarely signed by a supervisor. 

Expanding entry form 

C Include space for technicians to calculate percentages of disposable income. 

Federal law prohibits employers from withholding more than 50 to 65 percent of an 

obligor’s disposable income.7 In some cases, therefore, the Program Support Center staff 

need to calculate income percentages to determine allowable withholding amounts. We 

found calculations were often scribbled on the margins of forms, rendering an accurate 

supervisory review difficult. 

Formalizing the forwarding process of income withholding orders from local 

offices 

C Provide local payroll liaisons with written guidance on the need to forward all income 

withholding orders to the PSC. 

C Require that local liaisons record the date of receipt of all income withholding orders 

and the date forwarded in a log, subject to review. 

C Mandate that forwarding occur within 3 days of income withholding orders receipt. 

7 The Federal Consumer Protection Act limits garnishment to 50% of disposable earnings for an obligor who supports a second 

family and 60% to an obligor not supporting a second family. If arrears are more than 12 weeks overdue, the percentage of 

earnings which can be garnished increases to 55% and 65% respectively. 

Withholding Child Support Obligations From Departmental Employees 16 OEI-05-00-00300 
In 4 out of 45 sampled cases, States sent withholding orders to local HHS offices. These 

orders were not forwarded to the Program Support Center. Child support agencies should 

send income withholding orders directly to the PSC or Office of General Counsel. 

However, when they are sent erroneously to local offices, they should not be neglected. 

Tracking receipt of employee verification letters and income withholding orders 

not acted upon 

C Keep copies of all employer verification letters and income withholding orders 

received. 

In a few cases, States indicated that they sent verification letters to the Program Support 

Center, but the PSC did not have a record of them. The PSC indicated that they do not 

store verification letters or withholding orders that are not acted upon. Storage of these 

letters and orders would allow periodic review to ensure appropriate response to all child 

support agency requests. 

Withholding Child Support Obligations From Departmental Employees 17 OEI-05-00-00300 
AGENCY COMMENTS 

We received comments from the Office of Child Support Enforcement (OCSE), the 

Program Support Center (PSC) and the Indian Health Service (IHS). The OCSE is in 

agreement with our findings and recommendations. The PSC agrees this is an important 

initiative and provided technical comments and clarification. The IHS agrees with our 

recommendation pertaining to IHS employees. Where appropriate, we changed the report 

to reflect their comments. The full OCSE, PSC and IHS comments are contained in 

Appendix C. 

We would like to thank OCSE for their assistance in conducting this study and for 

providing us with substantive and insightful comments. The OCSE has provided extensive 

guidance and technical assistance to States. The OCSE will further these efforts with a 

specialized guidance document that will address the issues detailed within this report. 

The OCSE will address the recommendation made directly to them as well as assist the 

Program Support Center in responding to the recommendation pertaining to the PSC’s 

role in employee wage withholding. The OSCE’s and PSC’s efforts will help to assure 

departmental compliance with Child Support Enforcement requirements and with the 

intent of the Executive Order. 

The Indian Health Service concurs with our recommendation that OCSE provide guidance 

to State Child Support agencies clarifying their authority as to federal employees residing 

and/or working on Indian reservations. 

Finally, we recognize that additional discussions are needed within the Department to 

resolve outstanding substantive and technical matters highlighted in the report. First, the 

substantive matter concerns the designation of a senior official to oversee Departmental 

compliance with the Executive Order. Considerable improvement can be made without 

taking this step, but an overall coordinator could facilitate a more cohesive and effective 

Department-wide response. Second, to resolve the technical issue, OCSE has provided us 

with a separate technical memorandum, addressing issues related to OCSE providing their 

files to other federal Departments in order to test compliance with the intent of the 

Executive Order. 

Withholding Child Support Obligations From Departmental Employees 18 OEI-05-00-00300 
APPENDIX A 

Profile of Employee-Obligors 

A P P E N D I X A 

Totals:

C 215 departmental employees were obligors on the tax offset file as of 5/30/00

C 139 employee-obligors with income withholding in place as of 5/30/00

C 76 employee-obligors without income withholding in place as of 5/30/00

GRADE LEVEL All EmployeeObligors (215) Without 

Withholding 

(76) 

With 

Withholding 

(139) 

% that are GS-7 or less 60% (128) 65% (49) 57% (79) 

% that are GS-11 or less 85% (182) 87% (66) 84% (116) 

SALARY All EmployeeObligors (215) Without 

withholding 

(76) 

With 

withholding 

(139) 

75% earn less than this 

amount (Quartile 3) 

$42,275 $40,114 $43,094 

50% earn less than this 

amount (Median) 

$32,974 $29,361 $33,768 

25% earn less than this 

amount (Quartile 1) 

$25,459 $24,091 $26,455 

Minimum Salary $13,870 $13,870 $15,261 

Maximum Salary $115,811 $98,310 $115,811 

Withholding Child Support Obligations From Departmental Employees 19 OEI-05-00-00300 
A P P E N D I X A 

Profile of Employee-Obligors

AGENCY EMPLOYMENT All EmployeeObligors (215) Without 

Withholding 

(76) 

With 

Withholding 

(139) 

IHS 49% (105) 58% (44) 44% (61) 

NIH 17% (37) 4% (3) 24% (34) 

FDA 10% (21) 9% (7) 10% (14) 

CDC 8% (18) 8% (6) 9% (12) 

OS 6% (13) 10% (8) 4% (5) 

HCFA 4% (8) 5% (4) 3% (4) 

PSC 4% (8) 4% (3) 4% (5) 

HRSA 1% (3) 0% (0) 2% (3) 

ACF 1% (2) 1% (1) 1% (1) 

EMPLOYMENT STATUS All EmployeeObligors (215) Without 

Withholding 

(76) 

With 

Withholding 

(139) 

Full time 94% (203) 87% (66) 99% (137) 

Part time 1% (2) 1% (1) <1% (1) 

Zero hours 5% (10) 12% (9) <1% (1) 

EMPLOYMENT HISTORY All EmployeeObligors (215) Without 

Withholding 

(76) 

With 

Withholding 

(139) 

Less than 1 year 19% (41) 30% (23) 13% (18) 

One to 3 years 20% (42) 26% (20) 16% (22) 

More than 3 years 61% (132) 43% (33) 71% (99) 

Withholding Child Support Obligations From Departmental Employees 20 OEI-05-00-00300 
A P P E N D I X B 

Reasons for Non-Withholding

IWO Sent to HHS. Not in Place on 5/30/00. 

IWO Sent to HHS on 4/21/00 and Implemented 6/20/00. 

IWO Sent to Local HHS Site, Not PSC. 

IWO in Place w/ HHS, But Inactive on 5/30/00 Because Child Support Paid in Full. 

X 

Income Withholding Order Not Sent to HHS 

Other* 

State Knew NCP Was w/ HHS. No Discernible Reason for No IWO. 

X 

State Did Not Learn of NCP Employment. 

IWO Deemed Not Necessary Because NCP Perceived as Not in Arrears. 

X 

IWO in Place w/ Other Employer. 

X 

Tribes Responsible for Case Did Not Issue IWO. 

X X X 

IWO Not Sent Due to Tribal Jurisdiction Questions. 

X X X X X 

Locate Not Pursued Due to Tribal Jurisdiction Questions. 

X X X 

Sample Number 

1 2 3 4 5 6 7 8 9 

10 11 12 13 14 15 

Withholding Child Support Obligations From Departmental Employees 21 OEI-05-00-00300 
A P P E N D I X B 

Reasons for Non-Withholding

IWO Sent to HHS. Not in Place on 5/30/00. 

IWO Sent to HHS on 4/21/00 and Implemented 6/20/00. 

X 

IWO Sent to Local HHS Site, Not PSC. 

X X X 

IWO in Place w/ HHS, But Inactive on 5/30/00 Because Child Support Paid in Full. 

Income Withholding Order Not Sent to HHS 

Other* 

X 

State Knew NCP Was w/ HHS. No Discernible Reason for No IWO. 

X X X X 

State Did Not Learn of NCP Employment. 

X X 

IWO Deemed Not Necessary Because NCP Perceived as Not in Arrears. 

X 

IWO in Place w/ Other Employer. 

Tribes Responsible for Case Did Not Issue IWO. 

IWO Not Sent Due to Tribal Jurisdiction Questions. 

X 

Locate Not Pursued Due to Tribal Jurisdiction Questions. 

X 

Sample Number 

16 17 

18 

19 20 21 22 23 24 25 26 27 28 29 

30 

Withholding Child Support Obligations From Departmental Employees 22 OEI-05-00-00300 
A P P E N D I X B 

Reasons for Non-Withholding

IWO Sent to HHS. Not in Place on 5/30/00. 

IWO Sent to HHS on 4/21/00 and Implemented 6/20/00. 

1 

IWO Sent to Local HHS Site, Not PSC. 

X 

4 

IWO in Place w/ HHS, But Inactive on 5/30/00 Because Child Support Paid in Full. 

X X 

3 

Income Withholding Order Not Sent to HHS 

Other* 

X 

3 

State Knew NCP Was w/ HHS. No Discernible Reason for No IWO. 

X 

6 

State Did Not Learn of NCP Employment. 

X X X 

5 

IWO Deemed Not Necessary Because NCP Perceived as Not in Arrears. 

X 

3 

IWO in Place w/ Other Employer. 

X X X 

4 

Tribes Responsible for Case Did Not Issue IWO. 

3 

IWO Not Sent Due to Tribal Jurisdiction Questions. 

X X 

8 

Locate Not Pursued Due to Tribal Jurisdiction Questions. 

X 

5 

Sample Number 

31 32 

33 

34 35 36 37 38 39 40 41 42 43 

44 

45 

TOTAL 

*Other reasons for IWOs not sent to HHS are: 1) Case was unenforceable since child is now 27, exceeding the AZ Statute of Limitations; and 2) Employer 

verification with HHS was attempted for two cases. There was no response, and the State did not pursue. 

Withholding Child Support Obligations From Departmental Employees 23 OEI-05-00-00300 
A P P E N D I X C 

Agency Comments

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A P P E N D I X C 

Agency Comments

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A P P E N D I X C 

Agency Comments
A P P E N D I X C 

Agency Comments

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Agency Comments

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A P P E N D I X C 

Agency Comments

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A P P E N D I X C 

Agency Comments

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