Department of Health and Human Services 

CHILD SUPPORT AND THE MILITARY 

JUNE 1993 OEI-07-90-02250 
EXECUTIVE SUMMARY


PURPOSE 

To determine what barriers exist in the collection of child support payments from 

absent parents in the U.S. military service. 

BACKGROUND 

A 1989 Management Advisory Report, A-12-89-00154, issued by the Office of Audit 

Services (OAS) identified 42,000 military personnel in arrears on their child support 

payments. These payments totalled over $176 million. The OAS identified these 

military cases through a match of the 1989 Office of Child Support Enforcement 

(OCSE) tax intercept file and military personnel data. About 64 percent of the 

payments were related to support for Aid to Families with Dependent Children 

(AFDC). 

Persons serving in the U.S. military semices are expected to pay their financial 

obligations in a timely manner, including the support of dependent children. 

The U.S. Department of Army regulations, 32 CFR Part 584.2, requires soldiers to 

provide financial support to family members, obey court orders, and comply with all 

court imposed obligations. More specifically, Army Regulation 608-99, Chapter 2-la, 

“requires soldiers to provide financial support to family members and to obey court 

orders on child custody.” The Navy, Air Force and Marines have similar regulations 

which also require their members to pay their financial obligations, including 

dependent support. 

We selected eight States and 360 cases for inclusion in this inspection, using a twostage stratified cluster sample. States were then selected in the first stage using a 

stratified random sample. Forty-five cases were selected in each State with random 

sampling for a total of 360 cases. 

In addition, we interviewed Child Support Enforcement (cSE) caseworkers in two 

local CSE offices and at a military installation in each of the eight States. We also 

interviewed legal staff in each of the four Defense Finance and Accounting Service 

Centers. Our preliminary findings were discussed with the Department of Defense 

and their comments are incorporated in the report. 

FINDINGS 

States do not collect child support payrnen~ in more than half of the sample military 

cases. Projected national savings to the AFDC and Medicaid programs, if courts 

orders for child support were established and/or enforced in these cases, totals $54.1 

million. 

1 
Locating absent parents is the greatest barrier. The transient nature of military 

assignments and the fact that military personnel are often stationed at installations for 

short periods of time often complicates the location of absent parents. That, coupled 

with difficulties in obtaining Social Security numbers for absent parents, often makes 

locating absent parents in the military virtually impossible. 

The CSE stafl have not been properly trained to handle miiltary cases. The CSE staff 

are unfamiliar with military policies and procedures which can become “red tape”. A 

handbook issued by the Administration for Children and Families (ACF) entitled 

“Child Support Enforcement in the Military” was effective but not widely distributed to 

CSE caseworkers and staff. 

Mi.litaq Finance Centem identi~ reasons for delaying the processing of wage withholding 

oniem The Defense Finance and Accounting personnel interviewed indicated that the 

delay in processing wage withholding orders is often the result of handling many 

orders more than once, and that many orders are returned to CSE agencies because 

they lack the proper documents and/or information required for processing. The lack 

of standardized forms for submission of wage withholding orders also delays processing 

which is consistent with a finding in a previous Office of Inspector General (OIG) 

report. 

RECOMMENDATIONS 

1. The ACF, Office of Child Support Enforcement should: 

a.	 provide technical support to State CSE offices to improve Social Security 

number identification; 

b.	 evaluate the usefulness of information available through the Federal 

Parent Locator Service, and provide necessary assistance to local CSE 

offices searching for military absent parent Social Security numbers; 

c.	 continue to promote the “Child Support Enforcement in the Military” 

handbook; and 

d.	 establish and require the use of a standard form and a checklist for 

submission of wage withholding requests to the Defense Finance and 

Accounting Service Centers. 

2.	 The ACF and the Social Security Administration (SSA) should collaborate to 

develop a better mechanism to assist CSE staff in obtaining Social Security 

numbers for absent parents. In doing so, it is essential that safeguards remain 

in place to protect individual privacy and the integrity of the Social Security 

system. 

ii 
We received comments on the draft report from ACF, SS~ and the Assistant 

Secretary for Planning and Evaluation. They concurred with our recommendations. 

ACF identified several actions that they have taken. However, we feel continued 

actions on each of our recommendations are warranted. The full text of their 

comments are included in Appendix D. 

... 

111 
TABLE OF CONTENTS


Page 

EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . ..”. ”o”””o”oo Q””” ”o o”” i


INTRODUCTION . . . . . . . . . . . . . . . . . . . . ...””””””.” 0“”0””.c”o””””..” 1


FINDINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . o.-o””c””.-”””0”””””””” 3


Uncollected supportpayments. . . . . . . . . . . . . . . . . . . . ...”. . .”””””””””” 3


support inmilita~cases . . . . . . . . . . . . . . . . . . . . . 5


CSE staff training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7


Military finance centers . . . . . . . . . . . . . . . . . . . . . ...”.... . . . . . . . . . . . . . 7


RECOMMENDATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... 9


APPENDIXES 

A. Projected Case Characteristics . . . . . . . . . . . . . . . . . . . . . . . . ..”..A-l 

B. State Level Data . . . . . . . . . . . . . . . . . . . . . . . . . . . ..”..”... “...B-l 

c. Projected Program Savings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..”C-l 

D. Agency Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .*.-D-l 
INTRODUCTION


PURPOSE 

The purpose of this study is to determine what barriers exist in the collection of child 

support payments from absent parents in the U.S. military service. 

BACKGROUND 

A 1989 Management Advisory Report, A-12-89-00154, issued by the Office of Audit 

Services (OAS) identified 42,000 military personnel in arrears on their child support 

payments. These payments totalled over $176 million. These military cases were 

identified through a match of the 1989 Office of Child Support Enforcement (OCSE) 

tax intercept file and military personnel data. About 64 percent of the payments were 

related to support for Aid to Families with Dependent Children (AFDC). 

Persons serving in the U.S. military services are expected to pay their financial 

obligations in a timely manner, including the support of dependent children. 

The U.S. Department of Army regulations, 32 CFR Part 584,2, requires soldiers to 

provide financial support to family members, obey court orders, and comply with all 

court imposed obligations. More specifically, Army Regulation 608-99, Chapter 2-la, 

“requires soldiers to provide financial support to family members and to obey court 

orders on child custody.” The Navy, Air Force and Marines have similar regulations 

which also require their members to pay their financial obligations, including 

dependent support. 

METHODOLOGY 

We selected eight States and 360 cases for inclusion in this inspection, using a twostage stratified cluster sample. States were then selected in the first stage using a 

stratified random sample. Forty-five cases were selected in each State with random 

sampling for a total of 360 cases. 

The sample frame for the first stage consisted of the 50 States. These States were 

rank ordered and categorized into quartiles based on the 1990 average annual AFDC 

caseload information listed on the OCSE-56 form. Three States were randomly 

selected from each of the four strata - two sample States plus one alternate. Three of 

the initially selected sample States were unable to provide us with a list of AFDC 

cases which included absent parent information. We replaced these three States with 

the selected alternate States for the respective quartile. The eight States selected for 

inclusion in this study were Arkansas, Georgia, Illinois, Massachusetts, New Jersey, 

Nevada, Oklahoma and South Dakota. 

Using the lists provided by the State Child Support Enforcement (CSE) agencies, we 

identified the AFDC child support cases in which a branch of military service was 

1 
listed as the absent parent’s place of employment. Then we randomly selected 45


cases from the military cases identified in each State, for a total of 360 cases. We


reviewed 275 of these cases, We did not review the other 85 cases based on our


determinations that the absent parents were not in the military, had been discharged


from military service, paternity blood tests were negative, or the AFDC portion of the


case had been closed.


Through our review of the sample AFDC case files, we obtained the information


necessary to determine if the absent parents had been located, if paternity had been


established, if court orders had been issued, and whether or not child support


payments were being collected. We were also able to determine the extent of contacts


between CSE staff and military personnel, and the success of the contacts.


In addition to our review of the sample cases, we interviewed CSE caseworkers and


military staff in each of the selected States, and each of the Defense Finance and


Accounting Service Centers. We interviewed CSE caseworkers in two local CSE


offices in each of the eight States. One CSE office in each State was located within 50


miles of a military installation, and the other located more than 50 miles from any


military installation.


We interviewed military personnel at one military installation in each of the sample


States. The selection of CSE offices and military installations to be included in our


sample was conducted with the assistance of both State CSE and Department of


Defense (DOD) personnel. In total, four Army, three Air Force, and one Naval


installation were included in the sample. The militaxy personnel interviewed varied


from installation to installation, and included staff from the Inspector General’s office,


the Family Support Center, Personnel, Payroll, Accounting and Finance, Legal


Assistance, and Chaplains. We also conducted interviews with legal staff in each of


the four Defense Finance and Accounting Service Centers.


Our preliminary findings were discussed with DOD and they provided comments,


advice, and input regarding sampling, design, and issues which were incorporated into


the report.


2

FINDINGS


I.	 States & not collect chiiif support payments in more than hay of the sample 

military cases. 

No child support payments are being collected in 143 of the 275 sample cases 

reviewed. Based on a weighted distribution, these cases account for 51 percent 

of the 360 included in our sample. Child support orders had been established 

but no current payments were being made in 45 of the cases (12.7 weighted 

percentage), causing arrearages to build. NO support orders had been 

established in 98 other cases (37.8 weighted percentage), and therefore no child 

support payments were being made. The chart below shows the weighted 

distribution of the 360 sample cases. (See Appendix A for more details.) 

No Child Support Collected 

(51 Percent - Weighted Distribution of 360 Cases) 

� u. Sqpxlcdleci 

� P13ym*ntscumnt 

Projected national savings to the AFDC and Medicaid programs, if court orders 

for child support were established and/or enforced in these cases, total $54.1 

million. (See Appendix C for more details.) 

No current child support pawn ents were being made in 45 of the sample cases 

where court orders for suPPort existed. 

The 45 sample cases had been open from 7 to 256 months, averaging 51.7 

months. The recorded number of months since the absent parent had made 

court ordered child support ranged from 1 to 43 months, averaging 12 months. 

The average recorded arrearage for these cases was $4,590. Recorded 

arrearages totalled $179,030. Projected nationally, the number of cases where 

no current child support payments were being made totals 5,114. Savings to 

3

the AFDC program, if existing court orders for child support were enforced in


these 45 cases, projects to $15.5 million annually.


0fthe45 sample cases inwhich absent parents were delinquent in their court


ordered child support, only 6 had orders containing immediate wage


withholding. The absence of immediate wage withholding makes the collection


of delinquent payments difficult. Because immediate wage withholding was not


included in these support orders, the CSE agency must encourage absent


parents to establish voluntary allotments, process garnishments or serve them


with delinquency notices to establish involuntary allotments. Voluntary


allotments must be established by the absent parent and can also be canceled


by the absent parent at any time. Involuntary allotments require delinquencies


of more than 2 months and are not honored by the military unless the order


specifies a monthly amount to be applied to the arrearage.


No court order for child support had been established in 98 of the sample


—.
 cases


Of the 98 sample cases in which no support orders had been established, CSE


staff had been unable to locate the absent parent in 47 cases. In the other 51


cases, the absent parents had been located but no court order established for a


variety of reasons, including the fact that the absent parents were out of the


country or on a ship, paternity blood tests were pending, or CSE staff made nO


militaly contacts. The chart below provides more detailed information


regarding these cases.


~d support (%XS in which 

No Support Order had been Established 

Absent Parent Absent Parent 

case status Not Located Located 

No absent parent SocialSecurityNumber


CSEstaffmade no militarycontacts


Absent parent abroad or on a ship


Paternhy blood tests were pending


No activityon case since absent parent located


MilitaryUncooperative(Due to War time


restrictions of Desert Storm) 

Custodial parent/client uncooperative 

CSE contacts current 

CSE made inappropriate contacts 

Insufficient information to determine status 

Absent parent was uncooperative 

CSE awaiting military response 

Absent parent discharged by time of contact 

Militaty had no record of absent parent 

Totals 

37 

12 

11 

7 

6 

4 

3 

2 3 

2 3 

3 

1 

1 

1 

— 

51 

4

Ontheaverage these cases had been open 27months, over 2years. The actual 

time they had been open ranged from 3t0145 months. Projected nationally, 

these cases total 15,222. The projected annual savings tothe AFDC program is 

$22,246,649 if court orders for child support were established and enforced in 

these cases. 

Medical insurance is available to cover demmdents currentlv receivirw medical 

assistance throu ti the Medicaid Dromun. 

Medical insurance is available to all military personnel and their dependents. 

In addition to AFDC program savings, the establishment and enforcement of 

medical support obligations for the projected number of cases in which no 

court orders had been established would save the Medicaid program 

$12,285,523 annually. We calculated this savings amount by applying the 

average of $807.09 in medical assistance provided to AFDC children by the 

Medicaid program to the projected number of these cases, and multiplying it by 

12 months. We used the Health Care Financing Administration Form 2080 to 

determine the average monthly amount. We then applied the $807 to the 

98 cases in which no court orders for child support had been established. 

The Medicaid program would save an additional $4,127,458 annually if court 

orders for medical support were enforced in the projected number of cases 

where court orders already exist. The combined Medicaid program savings for 

both types of cases totals $16,412,981 annually. 

We recognize the Federal government’s liability in the Civilian Health and 

Medical Program of the Uniformed Services (CHAMPUS) and Medicaid and 

that obtaining health care coverage for military personnel dependents through 

CHAMPUS would not necessarily lead to a reduction in overall Federal health 

care expenditures. 

2. Locating absent parenti is the greatest barrier. 

The CSE staff were unable to locate the absent parents in 47 of the sample 

cases reviewed, as shown in the chart on page 4. These 47 cases account for 

48 percent of the 98 cases in which no support order had been established. We 

estimate that out of the population studied 23.5 percent of the absent parents 

would be difficult to locate. 

The transient nature of military assignments and the fact that military personnel 

are often stationed at installations for short periods of time often complicates 

the location of absent parents. The CSE staff in 13 of the 16 CSE offices 

visited stated they had encountered problems in locating absent parents in the 

military. The staff in 6 of the 13 offices named location of the absent parents 

as “the greatest barrier” to child support enforcement and collection in military 

cases. 

5

As shown in the chart on page 4, cases in which the absent parents’ Social


Security numbers are unknown account for 38 percent (37 of 98) of the cases in


which no court orders have been established. Since the milita~ uses Social


Security numbers to identi& military personnel, they are imperative in the


identification and location of absent parents in the military, as well as in


processing wage withholdings for court ordered support. Without a Social


Security number, locating an absent parent in the military is virtually


impossible.


The CSE staff we interviewed indicated few resources are available for


obtaining unknown Social Security numbers. They have been directed to use


the Federal Parent Locator Service (FPLS) to search for unknown absent


parent Social Security numbers. Likewise, Social Securi~ Administration staff


have been directed to refer CSE staff searching for absent parent Social


Security numbers to the FPLS, except in emergency situations.


However, the CSE staff interviewed indicated that since little absent parent


information is available to them in many of these cases, they often consider the


FPLS an unproductive source for obtaining a Social Security number. To


obtain a Social Security number through the FPLS, the CSE agency must


accurately complete at least three of a number of specified data fields. These


fields include the absent parent’s city of birth, State or country of birth, first


name, middle initial, last name, date of birth, sex, mother’s first name, mother’s


middle initial, or mother’s maiden name. The information included in the


completed fields must be letter perfect to match with Social Security


Administration information available through the FPLS. Staff in one CSE


office said they had “never gotten a Social Security number through the FPLS.”


Others indicated that obtaining a Social Security number through the FPLS is


very unlikely.


Additionally, CSE staff are often unfamiliar with other locate sources available


to them if the Social Security number is known. One such source is the


Worldwide Military Locator Services (wMLS). Each branch of military service


has established a WMLS to provide military addresses for military personnel.


The WMLS information is provided to State CSE agencies at no charge.


However, CSE staff in four of the eight offices visited said they seldom


contacted a WMLS, and one said they had never contacted a WMLS. In the


45 cases where CSE staff had contacted a WMLS for locator information, the


absent parents’ military addresses were provided in all but four instances. In


three of these four cases, the military refused to provide the information


requested based on the privacy required by Operation Desert Storm. In the


other case, the military refused to provide the information requested by the


CSE agency, stating that the “records requested are protected from disclosure


under the privacy act.”


6

hothermilita~ locator source available to CSEstaff is base locators. Most 

military installations have a base locator, who can provide the ranks and 

military addresses of military personnel assigned to that installation. A base 

locator can also provide CSE staff with the next duty station, in the event that 

the person in question has been transferred. Even though CSE staff in 11 of 

the 16 offices visited said they sometimes or almost always used base locators, 

staff in 3 offices said they seldom or never contacted base locators. 

Even though base locators often serve as an excellent source of locating absent 

parents, CSE staff should be cautioned in their contacts with them. Military 

personnel at seven of the eight installations visited indicated they do not 

forward requests for the location of absent parents to the WMLS in instances 

where he/she is not, or has not recently been, stationed at their facility. 

Therefore, CSE staff should proceed with contacts to the WMLS if contacts 

with a base locator are unsuccessful. As with the use of the WMLS, base 

locators also require the absent parent’s Social Security number. 

3. The CSE stafi have not been properly trained to handle milita~ cases. 

The CSE staff have not been properly trained to handle military cases. They


are unfamiliar with military policies and procedures which can become “red


tape” when not understood. The staff interviewed expressed concern with the


“layers” they have to go through in obtaining information about absent parents


in the military. One person interviewed said they “may write off military cases


because it is so hard to get the absent parents served.” Others said they “have


limited information regarding the military and need training,” and that they


“need training sessions with military personnel who have direct knowledge of


how the system works.”


The handbook issued by the ACF, Office of Child Support Enforcement,


entitled “Child Support Enforcement in the Military” was effective, but not


widely available. The Office of Child Support Enforcement issued the


handbook in June of 1991 to states and local child support enforcement offices,


but only 8 of the 16 local CSE offices we visited had a copy of the handbook at


the time of our interviews, over 6 months later. In two of these eight offices


the handbook was available in the office, but it had not been distributed to the


staff. In these two instances, only one person on the CSE staff had seen a copy


of the handbook. The CSE staff that had copies of the handbook spoke highly


of it and said they found it helpful.


4.	 Militay Finance Centen identi~ reasom for a!daying the proc&g of wage 

withholding ordem 

The CSE staff inteniewed indicated that processing wage withholding in 

military cases takes longer than non-military cases. They said military wage 

7

withholdings take from 2 to 4 weeks longer than civilian cases, and that it is 

2 to 3 months before they see any payments. 

The Defense Finance and Accounting personnel interviewed indicated the delay 

in processing CSE wage withholdings is often the result of the office handling 

many wage withholding orders more than once. They said that many wage 

withholding orders are returned to CSE agencies because they lack the proper 

documents and/or information required for processing. Among the reasons 

listed for returning wage withholding orders to CSE agencies were the lack ofi 

- a certified copy of the support order;


- a certified copy of the arrearage support order;


- the absent parent’s full name and Social Security number;


- the full name and address to whom payment should be made; or


- legible copies of documents.


The Defense Finance and Accounting personnel also indicated that the lack of 

standard forms for the submission of withholding orders delays the processing 

of wage withholding orders, which in turn delays payment. The wage 

withholding forms they receive vary by State, and many times from one 

jurisdiction to another within a State. They indicated that standardization of 

wage withholding documents would speed their document review time, leave 

less room for errors, and could serve as a checklist for CSE staff to use in 

preparing wage withholding packages. This finding is consistent with a previous 

Office of Inspector General (OIG) report which found that formats and 

language in court order forms are not standardized among State CSE agencies. 

The report recommended requiring all jurisdictions to use standardized forms 

when issuing legal processes for child support to employers.1 

1

“An Employer Perspective Fragmentation of State Practices Impair Ability of Employers to 

Effectively Implement Wage Withholding Process,” A-12-91-00016. 

8 
RECOMMENDATIONS


1. The ACF, Office of Child Support Enforcement should: 

a.	 provide technical support to State CSE offices to improve Social Security 

number identification; 

b.	 evaluate the usefulness of information available through the Federal 

Parent Locator Service, and provide necessary assistance to local CSE 

offices searching for military absent parent Social Security numbers; 

c.	 continue to promote the “Child Support Enforcement in the Military” 

handbook; and 

d.	 establish and require the use of a standard form and a checklist for 

submission of wage withholding requests to the Defense Finance and 

Accounting Service Centers. 

2.	 The ACF and the Social Security Administration should collaborate to develop 

a better mechanism to assist CSE staff in obtaining Social Security numbers for 

absent parents. In doing so, it is essential that safeguards remain in place to 

protect individual privacy and the integrity of the Social Security system. 

AGENCY COMMENTS AND OIG RESPONSE 

We received comments on our draft report from ACF, the Assistant Secretary for 

Planning and Evaluation (ASPE), and SSA. The full text of their comments are 

included in Appendix D. 

The ACF concurred with our recommendations, agreeing that processes for collecting 

child support payments from absent parents in the military need to be improved, 

particularly in locating the absent parents. They noted several past and future 

initiatives to enhance efforts to locate and establish support requirements for absent 

parents in the milita~. However, we believe continued actions on each of our 

recommendations are warranted. 

The ACF suggested that we incorporate data collection instruments into the report. 

For reasons of efficiency and clarity, we generally do not do this. However, we are 

more than happy to provide a copy of the instruments to ACF. 

The ASPE agrees that OCSE and child support enforcement agencies could undertake 

additional administrative actions to improve establishing and enforcing child support in 

cases where the absent parent is in the military. 

9 
However, ASPE raised several points.


The ASPE agrees that military-provided insurance could potentially reduce Medicaid


costs but pointed out that would not reduce Federal health care expenditures. The


medical bills would be paid by CHAMPUS, the Federal program which pays for health


care of military personnel and their dependents. We agree and have made this point


on page 5 of our report.


The ASPE mentions that AFDC (and Medicaid) program savings are computed as if


all of the absent parents could be located, so the potential program savings should


reflect a more realistic, less than 100 percent, locate rate. We agree that our


estimates are premised on the 100 percent locate rate and that this is not likely to be


achieved, However, we believe that this should be the goal and that a locate rate


approaching 100 percent is feasible. Furthermore, we have no way to accurately


predict any other rate.


The ASPE feels that some of the problems related to wage-withholding stem from


inconsistencies between the Federal law permitting garnishment in the military (passed


in 1982) and the general child support wage withholding statutes (passed in 1984 and


1988) and that it may be impossible to eliminate confusion between military personnel


and CSE until the 1982 law is amended and/or military regulations are brought into


conformance with subsequent legislation. However, we did not encounter this


problem in our study.


Regarding developing a better mechanism for obtaining Social Security numbers,


ASPE indicated that safeguards have to remain in place to protect individual privacy


and the integrity of the Social Security system. We agree and have included such


references in the report.


The SSA agreed that it should collaborate with ACF/OCSE to develop a better


mechanism to obtain Social Security numbers for absent parents.


The SSA also raised several questions regarding our statistical calculations. We


selected our sample using stratified two-stage cluster design. The data from the eight


States were assigned weights appropriate for the design.


The SSA is correct that States having a large number of child support cases in which a


military branch was listed as the absent parent’s place of employment had a higher


percentage of cases where no child support is being collected than the small


enrollment States. We include State level data in Appendix B. SSA also pointed out


a discrepancy in the precision level of one item on our table of projected case


characteristics. We made the corrections.


10

APPENDIX A


Projected Case Characteristics 

Distribution with resmect to whether child support . -1-. 

Delinquent Cases 

Estimate 12.7% 

9070 Confidence Interval 9.770-15.7% 

Relative Precision 23.6% 

payments were 

Non-Delinquent 

Cases 

59% 

54%-64% 

8.3% 

delinquent. . 

Dropped out of 

the Sample 

28.3% 

23.3V0-33.3% 

17.770 

Distribution with respect to whether or not a support order was established. . .-

No Support Support Order Dropped Out of 

Order Established Established the Sample 

Estimate 37.8% 33.970 28.3Y0 

90% Confidence Interval 239?0-52.6T0 16.5% -51.39Z0 23.3% -33.3?Z0 

Relative Precision I 39% I 51.3% I 17.7% 

Distribution with respect to whether or not the absent parent could be located. 

Unable to Locate Located 

Estimate 23.5% 48.2% 

90% Confidence Interval 20.5%-26.5% 38.7%-57.7% 

Relative Precision 12.8% 19.7% 

Distribution with respect to whether or not the case was a paternity 

Paternity Case	 Non-Paternity 

Case 

Estimate 55.2% 16.59Z0 

9090 Confidence Interval 45%-65.4% 7%-26$Z0 

Relative Precision 18.4% 57.6% 

Dropped Out of 

the Sample 

28.39Z0 

23.3%-33.3% 

17,7% 

case. 

Dropped out of 

the Sample 

28.3% 

23.3%-33.3% 

17.7% 

A -1


II 
APPENDIX B


State Level Case Data 

Cases 

cases in in Cases 

Universe Sample Reviewed 

Strata 1 

GA 4,068 45 32 

IL 664 45 29 

Strata 2 

MA 90 45 31 

NJ 708 45 33 

Strata 3 

414 45 35 

OK 127 45 40 

Strata 4 

NV 178 45 33 

66 45 42 

* 6,315 360 275 

B-1 

98 Cases 

No Order 

Established 

21 

1 

2 

9 

20 

26 

18 

1 

98 

45 Cases 

No Payment 

6 

5 

6 

6 

4 

3 

6 

9 

45 

I 
APPENDIX C


Projected Program Savings 

(dollar amounts in millions) 

Order Established/ 

Payments 

Delinquent 

45 

5,114 

$15.5 

$4.1 

$19.6 

No Order 

Established/ 

No Payments 

98 

15,222 

$22.2 

$12.3 

$34.5 

and Precision 

in millions) 

Total Number of 

Cases Receiving 

No Payment 

143 

20,336 

$37.7 

$16.4 

$54.1 

Number of Cases in 

Sample 

Number of Case 

Projected Annually 

AFDC Program 

Savings 

Medicaid Program 

Savings 

— 

Total 

Confidence Intervals 

(dollar amounts 

Order Established/ No Order Established/ 

Payments Delinquent (45 cases) No Payments (98 Cases) I 

AFDC I Medicaid 

Estimate $22.2 I $12.3 

9070 Confidence $13.2-$31.2 $7.5 -$17.1 

Interval * ‘;l 

Precision 29% I 23.6% 39% 39?40 

c-1 
APPENDIX D


Agency Comments 

We received comments on our draft report from the Administration for Children and 

Families (ACF), the Assistant Secretary for Planning and Evaluation (ASPE), and the 

Social Security Administration (SSA). Their responses follow. 

D-1

L*. ---

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ADMINISTRATION FOR CHILDREN AND FAMILIE 

370 L’Enfant Promenade, S.W. 

Washington, D.C. 20447 

Date: April 1, 1993 

To: B ell 

P ty Inspector General 

From: L 

A nt Secretary for 

Children and Families 

Subject: Comments on OIG Draft Report ‘tChild Support and the 

Military” OEI-07-90-02250 

We agree that there is a need to improve the processes, 

particularly location, to remove barriers that exist in the 

collection of child support payments from absent parents in the 

military. 

The report finds that: 1) States did not collect child support 

payments in more than half of the sample of military cases; 2) 

locating absent parents is the greatest barrier to the collection 

of support payments; 3) Child Support Enforcement (CSE) staff 

have not been properly trained in handling military cases; and 4) 

military finance centers identified reasons for delaying the 

processing of wage withholding. 

The report indicates that OIG staff interviewed CSE staff and 

military personnel in each of the eight States. However, the 

report does not mention the process for identifying and selecting 

the persons to be interviewed nor does it include the questions 

posed. We suggest that the data collection instruments be 

incorporated as exhibits to the report. 

Comments on the specific OIG recommendations follow: 

OIG Recommendation: 

I.a.�The ACF, Office of Child Support Enforcement should provide 

technical support to State CSE offices to improve social 

security number identification: 

ACF Comment: 

We concur. 

In September 1991, at the First Annual National Child


Support Training Workshop, the Office of Child Support


Enforcement. (OCSE) conducted a track on location training


for 72 participants (mainly State child support trainers)


from 28 States. Improvement of social security number (SSN)


identification was included. Each of the participants

Page 2 - Bryan B. Mitchell 

and the non-attending states were provided with a sample 

curriculum for location training. Our follow-up to the 

conference indicates that several States have conducted 

location training using this curriculum. 

OCSE staff have conducted on-site location training (with 

SSN identification as an integral part of the training) i.n 

Arizona, Indiana, Michigan, Prince George~s County, and 

Philadelphia. OCSE staff also presented sessions on 

location at State child support conferences i.n Alabama, 

California, and Florida. Training workshops on the location 

function were also conducted at the two largest national 

training conferences: the National Child Support 

Enforcement Association’s and the Eastern Regional Child 

Support Association’s Annual Training Conferences. 

In 1992, OCSE developed a program review protocol which was 

issued in December to all Regional Offices for use in 

conducting program reviews of the location function (and SSN 

i.dentifi.cation) with follow-up technical assistance where 

appropriate. 

OCSE has recently notified State CSE offices of their 

ability to submit through the Federal CSE office to the 

Social Security Administration (SSA) SSN8S for verification 

in SSA’S Enumeration Verification System (EVS) . There are 

two systems offered by the SSA that the States may use. The 

first is “System 2121’ which will provide a State with 

multiple SSN’S for an individual who has been legally issued 

more than one SSN. To date, System 212 has identified 

14,000 multiple SSN’S. The second is l~System220f’which 

will provide a corrected SSN in cases where the State has 

made a transposition or slight error in the SSN that they 

currently have for that individual. To date, System 220 has 

provided 30,000 corrected SSN8S. 

OIG Recommendation: 

lb.� The ACF, Office of Child Support Enforcement should evaluate 

the usefulness of information available through the Federal 

Parent Locator Senice (FP123), and provide necessary 

assistance to local CSE offices searching for military 

absent parent social security numbers. 

ACF Comment: 

We concur in that we are constantly evaluating the 

usefulness of the information available through the FPLS. 

However, the usefulness of the Lcapation information is 
. . 

Page 3 - Bryan B. Mitchell 

dependent on several factors including the currency of the 

data received from other Federal agencies and how successful 

states are in following up on the information. Most Federal 

agency data bases that the FPLS accesses are updated at 

least annually. 

The FPLS receives SSN information from the Social Security 

Administration and address and employer information from the 

Internal Revenue,Senice, the National Personnel Records 

Center, the Department of Defense, the Department of 

Veterans Affairs, the Selective Senice System and the State 

Employment Security Agencies. If SSA records indicate the 

person is in the military, the FPIS will automatically send 

the case to DOD. 

On an ongoing basis, OCSE provides technical assistance to 

local child support enforcement offices in the 

identification of SSN’S, from automated matches with IRS and 

SSA, for all absent parents including those in the military. 

OIG Recommendation: 

l.c. The ACF, Office of Child Support Enforcement should continue 

to promote the “Child Support Enforcement in the Military” 

handbook. 

ACF Comment: 

We concur. 

With two inhouse printings, OCSE has distributed the ‘lChild 

Support Enforcement in the Militaryi’handbook to all State 

and local child support offices and has made copies 

available to military family senice centers, and to 

worldwide offices of the American Red Cross. This 

publication is included in OCSE’S list of available 

publications. In an effort to further promote the handbook, 

OCSE arranged in 1992 for the handbook to be marketed and 

sold by the U.S. Government Printing Office. 

OIG Recommendation: 

l.d.�The ACF, Office of Child Support Enforcement should 

establish and require the use of a standard form and a 

checklist for submission of wage withholding requests to the 

Defense Finance and Accounting Senice Centers. 

ACF Comment: 

We concur. 
. 

Page 4 - Bryan B. Mitchell 

OCSE has identified a work group to develop a standardized 

form for wage withholding. The work group consists of CSE 

staff at the Federal, Regional, State, and local level, as 

well as appropriate associations. The OCSE plans to submit 

the form to OMB for approval this fiscal year. 

OIG Recommendation: 

2.� The ACF and the.Social Security Administration should 

collaborate to develop a better mechanism to assist CSE 

staff in obtaining social security numbers for absent 

parents. 

ACF Comment: 

we concur.


Through SSA, the FPLS can identify SSN~s, addresses, and


employer information. Additionally, as previously


indicated, SSN’S can be verified through the SSA~s


Enumeration Veri.ficati.on System.


.-
FEB12!933€

TO:� Bryan B. Mitchell 

Principal Deputy Inspector General 

FROM :� Acting Assistant Secretary 

for Planning and Evaluation . ., 

SUBJECT :� OIG Draft Report: “Child Support and the Military, 

0EI-07-90-02250 

We have reviewed the above mentioned draft report and agree that 

there are additional administrative actions that OCSE and state 

child support enforcement agencies can undertake to improve the 

establishment and enforcement of child support in cases where the 

non-custodial parent is in the military. 

However, we have several concerns about the specific findings in 

the report and would like to raise an additional concern about 

your recommendation that ACF/OCSE and SSA develop a better 

mechanism for obtaining Social Security numbers of non–custodial 

parents. 

First, while we agree that whenever possible, the ~litary noncustodial parent should provide for the health care needs of 

their children and that such military-provided insurance could 

potentially reduce Hedicaid costs, the report should clearly 

state that obtaining such health care coverage Wo uld not lead to 

9 reducti~n ~ federal health care ex~end itures . CHAMPUS, the 

program designed to provide health care for military personnel 

and their families, is 100 percent federally-financed and has a 

broader package of coverage than some state Medicaid programs. 

This would mean that the Federal Government would likely pick up 

more of the cost for health care under CHAKPUS than under 

Medicaid. In the long run, health care coverage through CHAMPUS 

might help some families with high health care costs, leave ATDC, 

because Medicaid coverage is no longer needed. However, in the 

short-term, there is likely to be a reduction in the federal 

share of Medicaid costs but an overall increase in Federal 

Government costs as a result of increased provision of health 

insurance and care through the military. 

Second, while the report correctly indicates that several factors 

beyond the’control of the CSE program make the location of some 

non-custodial parents in the military virtually impossible, the 

AFDC (and Medicaid) program savings are computed as if ~ of 

these absent parents could be located. The potential program 

savings should reflect the less than 100 percent locate rate that 

the report elsewhere indicates is realistic. 
, . 

Page 2 - Bryan B. Xitchell 

Third, the report indicates that military personnel allege that 

the problems in processing wage-withholding orders are mainly the 

result of improper handling of the CSE agency. What the report

fails to mention is that some of the problems related to wagewithholding stem from inconsistencies between the federal law 

permitting garnishment in the military, which was passed in 1982, 

and the general child support wage withholding statutes passed in 

1984 and 1988. The,1982 statute only permd.tsgarnishment 

(involuntary wage-withholding) after 2 months arrears and places 

other limitations on enforcement action. Under the 1988 statute, 

immediate withholding, without any accumulation of arrears, was 

mandatory in IV-D cases beginning in 1991. An example of the 

confusion which might result from these separate statutes is that 

military personnel cite as a frequently “missing” item, a 

certified copy of the arrearage support order. According to the 

1984 law, it is not necessary to go back to court for such an 

order, and according to the 1988 law, it i.s not necessav for 

there to be an explf.cit request for wage-withholding in the 

initial support order. It may be impossible to clear up the 

confusion between military personnel and CSE staff until the 1982 

law is amended and/or military regulations are brought into 

conformance with subsequent legislation. 

Lastly, the report recommends that ACF and SSA develop a better 

mechanism for”obtaining Social Security numbers for absent 

parents. While we support any collaboration which could make the 

system work better, we would like to point out that safeguards 

have to remain in place in order to protect individual privacy 

and the integrity of the Social Security system. Unknown SSNS 

can be provided only when the CSE agency, based on information 

from the, custodial parent, can furnish several other pieces of 

information which are kept as part of the Social Security 

records. These include some combination of: the non-custodial 

father’s legal name, his date of birth, his place-of birth, and 

the names of his mther and father. If the custodial parent does 

not know any of these items, release of a SSN or a number of 

possible SSNS, based solely on a name match, would be irresponsible. Attempts to locate absent parents need to be balanced 

against the reasonable protection of the privacy of individuals 

within the Social Security system. “ 

If you have any questions, please feel free to call Ann Segal, 

Acting Deputy Assistant Secretary for Human Services Policy 

(690-7148). 

..-... 
‘r{ 

_> L 

‘+> + +X.,,,, a 

Date: 

From: 

Subject: 

To: 

Refer to Memorandum 

‘ .:=fzi!P/. Acting Commissioner of ~ocial Security 

Office of Inspector General Draft Report, ‘tChild Support and 

the Military” (OEI-07-90-02250)--INFO~TION 

Bryan B. Mitchell�

Principal Deputy Inspector General�

Attached is our response to the subject report. If we can be�

of further assistance, please let us know.�

Attachment:�

SSA Response�

. 
COMMENTS OF THE SOCIAL SECURITY ADMINISTRA TION ON THE OFFICE OF�

INSPECTOR GENERAL DRAFT REPORT, “CHILD SUPPORT AND THE MILITARY”�

(OEI-07-90-02250)�

Office of Inspector General (OIG) Recommendation�

The Administration for Children and Families (ACF) and the Social�

Security Administration (SSA) should collaborate to develop a�

better mechanism to assist the Office of Child Support�

Enforcement (OCSE) staff in obtaining Social Security�

numbers (SSN) for absent parents.�

SSA Response�

We agree and are currently working with OCSE to develop a better�

mechanism to obtain SSNS for absent parents. The Federal Parent�

Locator Service (FPLS) within OCSE is conducting a study to see�

if a different SSA system could provide SSNS to them. The Alpha�

Search routines of the Enumeration Verification System may be a�

better mechanism for locating SSNS for these cases, since they�

would not require as many data elements as the FPLS system.�

On January 6, 1993, representatives from SSA met with OCSE to�

explore ways to better serve OCSE in obtaining SSNS for absent�

parents. A number of options for enhancing this process through�

data exchange and other methods will be shared with OCSE in the�

near future.�

Other Matters�

There appears to be a problem on page 3 of the report with OIG’S�

estimate that 51 percent of the 360 cases reviewed showed no�

child support payments being made. Either an error was made in�

the calculation or States that have a large number of child�

support cases in which a branch of military senice was listed as�

the absent parent’s place of employment have a higher percentage�

of cases where no child support is being collected than do the�

small enrollment States. The pie chart on page 3 shows that�

143 of 275 sample cases represented a weighted percentage of�

51 percent and 132 of 275 represented a weiqhted ~ercentaae of 

21 percent. If this is so, It would be ben;ficia~ to she; State 

level data for the eight States or, alternatively, quartile data, 

so that the reader of the report would be aware of this disparity

in results for large enrollment States as compared to small 

enrollment States. 

Additionally, on page A-1 of the appendix, the relative precision 

number under the Unable to Locate column for absent parent should 

be 12.8 percent rather than 45.5 percent. Also, the confidence 

intervals for whether or not a support order was established seem 

to be wider than one would expect.