Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

Implementation of State Child Support 

Certified Data Systems 

JUNE GIBBS BROWN 

Inspector General 

APRIL4 1997 

OEI-O4-%OOOlO 
OFFICE OF INSPECTOR GENERAL 

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

452, is to protect the integrity of the Department of Health and Human Services 

programs as well as the health and welfare of beneficiaries served by them. This 

statutory mission is carried out through a nationwide program of audits, investigations, 

inspections, sanctions, and fraud alerts. The Inspector General informs the Secretary 

of program and management problems and recommends legislative, regulatory, and 

operational approaches to correct them. 

Office of Evaluation and Inspections 

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

Office of Inspector General. It conducts short-term management and program 

evaluations (called inspections) that focus on issues of concern to the Department, the 

Congress, and the public. The inspection reports provide findings and 

recommendations on the efficiency, vulnerability, and effectiveness of departmental 

programs. 

OEI’s Atlanta Regional Office prepared this report under the direction of Jesse J. 

Flowers, Regional Inspector General, and Christopher Koehler, Deputy Regional 

Inspector General. Principal OEI staff included: 

REGION HEADQUARTERS 

Peggy Daniel, Project Leader 

Ron Kalil, Team Leader 

Jackie Watkins, Program Analyst 

Tammy Hipple, Program Analyst 

Alan Levine, Program Specialist 

Wm. Mark Krushat, Sc.D. 

Ann O’Connor, Program Specialist 

To obtain a copy of this report, call the Atlanta Regional Office at 404-331-5748. 
Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

Implementation of State Child Support 

Certified Data Systems 

JUNE GIBBS BROWN 

Inspector General 

APRIL 1997 

OEI-04-96-00010 
EXECUTIVE SUMMARY 

PURPOSE 

To describe State IV-D Child Support Enforcement Agencies’ experiences in 

implementing certified automated data systems. 

BACKGROUND 

The Child Support Enforcement program was established in 1975 as Title IV-D of the 

Social Security Act. Its purpose is to locate noncustodial parents, establish paternity, 

establish and enforce child support, and collect child support payments. State Title 

IV-D Child Support Agencies manage and operate child support programs. 

Because of escalating non-support for children by noncustodial parents, and a public 

need for responsive child support enforcement programs, the Administration and the 

Congress have long been interested in improving data systems for child support. As a 

result of this interest, the 1988 Family Support Act required each State to develop a 

Statewide automated data system that had the capability to control, account for, and 

monitor all processes for determining paternity and collecting child support. 

The 1988 Act also set October 1, 1995 as the deadline for States to implement the 

required certified automated child support data system. However, only one State met 

the October 1, 1995 deadline for implementing a certified automated data system for 

child support enforcement. As a result, on October 11, 1995, Congress passed 

legislation to authorize a 2-year extension of the deadline -- until October 1, 1997. 

Federal and State expenditures for developing automated child support systems 

totalled about $2 billion. 

FINDINGS 

Mmt States and territories are well positioned to have cert$ed automated child supprt 

data systkms by the rev&d October 1,1997 &adlim 

Only one State met the original October 1, 1995 deadline for having a certified data 

system. However, at the time of our review five more States had been certified. 

Forty-two States said they expect to have certified automated data systems by the 

revised October 1, 1997 deadline. Five States did not know whether or not they would 

be certified, and one State said it does not expect to develop a certified data system by 

the revised deadline. Of those anticipating to be certified by the revised deadline, 

thirty-two were in the implementation and operational phases. 
States, ACF, and conaactors general& attributed implementation delays huge& to three 

pqgmm ekkments: technology b-arqfer, short timefmmes; and Stai2/contractor 

iz?htionsw 

States, ACF, and contractors shared responsibility for the delays. Neither was solely 

responsible. States identified three program elements that contributed most to delays 

in developing and implementing certified automated data systems. The program 

elements were (1) a requirement to share technology, (2) short timeframe for 

developing and implementing the systems, and (3) ineffective State and contractor 

working relationships. ACF and contractors generally agreed with States that these 

program elements were the major causes of delays. 

Most States cosider the quality of Federal technical assistance and guidance to be good 

to excelknt 

About 70 percent of the States said the quality of ACF’s technical assistance and 

guidance was good or excellent. ACF provided various types of technical assistance 

and guidance to States at different stages during planning and development of certified 

data systems. States said on-site reviews, certification guide and questionnaire, 

interpretation of the certification guide, and user group meetings were most helpful. 

RECOMMENDATIONS 

Despite the favorable outlook, the Administration for Children and Families (ACF) 

should take steps to ensure that all States develop a certified automated child support 

data system by the revised October 1, 1997 deadline. We recommend that ACF: 

b Secure a detailed action plan from each State identifying specific steps they are 

undertaking to meet the revised deadline. 

w Establish an intensive system to continuously monitor the status of each State’s 

progress towards becoming certified by October 1, 1997. 

b Provide more indepth technical assistance and guidance to States having 

difficulty meeting the revised deadline. Such assistance could include (1) 

working with States to determine specific causes of problems, and (2) assisting 

States in designing and implementing corrective action measures. 

The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 

requires States to develop several additional child support data systems by October 1, 

2OMI. Some lessons learned from the systems development effort analyzed in this 

report may be applicable to these new systems. We suggest that ACF: 

k Allow States flexibility in determining whether or not transferring proven child 

support data systems from one political jurisdiction to another would shorten 

implementation time, reduce systems cost, and achieve standardized systems. 

ii 
b Develop strategies to identify areas where States can provide technical 

assistance to others. ACF should also coordinate this effort both regionally and 

nationally. 

Towards this effort, we will issue a report in the near future that identifies lessons 

learned by States in their efforts to develop and implement certified automated data 

systems. 

AGENCY COMMENTS 

The Principal Deputy Assistant Secretary for Children and Families commented on 

our draft report. She expressed general agreement with our recommendations. To 

help assure that States implement certified automated data systems by the revised 

October 1, 1997 deadline, ACF is re-emphasizing the importance of Advance Planning 

Document Updates by States. The ACF will also provide more in-depth technical 

assistance to States, including more frequent on-site visits by regional and central 

office staffs. ACF intends to obtain Quarterly Status Reports from States experiencing 

difficulties in developing certified data systems. 

Further, ACF modified original instructions requiring States to transfer another States’ 

child support data system. The revised instructions give States an option on whether 

or not to transfer another States’ data system. The ACF is also seeking opportunities 

to build supportive relationships between States to enhance development of the data 

systems. 

The Acting Assistant Secretary for Planning and Evaluation also concurred with our 

recommendations. 

Appendix A shows the full text of ACF comments. 

. . . 

111 
TABLE OF CONTENTS 

PAGE 

INTRODUCI-ION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 

FINDINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 

State Readiness ............................................ 5 

Causes of Implementation Delays .................. r ............ 6 

Technology Transfer Policy ............................... 8 

Short Timeframes ...................................... 9 

State and Contractor Working Relationships ................. 10 

. Quality of Federal Technical Assistance ......................... 11 

RECOMMENDATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 

AGENCYCOMMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 

APPENDIX A: ACF COMMENTS.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-l 
INTRODUCTION 

PURPOSE 

To describe State IV-D Child Support Enforcement Agencies’ experiences in 

implementing certified automated data systems. 

BACKGROUND 

Chiiii Support Enforcement 

The Child Support Enforcement program was established in 1975 as Title IV-D of the 

Social Security Act. Its purpose is to locate noncustodial parents, establish paternity, 

establish and enforce child support, and collect child support payments. State Title 

IV-D Child Support Agencies manage and operate child support programs. 

Within the Department of Health and Human Services (HHS), the Office of Child 

Support Enforcement (OCSE), Administration for Children and Families (ACF), has 

Federal oversight responsibility for State Title IV-D Child Support programs. 

Automating Child Support Data Systems 

Because of escalating non-support for children by noncustodial parents, and a public 

need for responsive child support enforcement programs, the Administration and the 

Congress have long been interested in improving data systems for child support. 

In 1984, Congress amended Title IV-D of the Social Security Act to fund 90 percent 

of State costs for computer hardware and software to operate automated child support 

data systems. 

The 1988 Family Support Act extended 90 percent funding for development of 

automated child support enforcement data systems. The Act required each State to 

develop a Statewide automated data system that had the capability to control, account 

for, and monitor all processes for determining paternity and collecting child support. 

Additionally, the system was required to electronically interface with systems of other 

agencies at the Federal, State, and local level. Such interface was deemed essential to 

assure collection of child support, where appropriate, and proper distribution of child 

support payments. 

The 1988 Act also required ACF to certify each State system to assure that State 

automated systems for child support meet Federal requirements. 

Finally, the 1988 Act set October 1, 1995 as the deadline for States to implement the 

required certified automated child support data system. At that time, funding was to 

be discontinued. 

1 
However, only one State met the October 1, 1995 deadline for implementing a 

certified automated data system for child support enforcement. As a result, on 

October 11, 1995, Congress passed legislation to authorize a 2-year extension of the 

deadline -- until October 1, 1997. 

Fe&ml and State Expedhrm 

While only one State system had been certified as of the October 1, 1995 deadline, 

Federal and State expenditures for developing State systems totalled almost $2 billion. 

Figure 1 shows that Federal and State funding for developing automated child support 

systems steadily increased from 1988 through 1995. 

FIGURE 1 

CHILD SUPPORT SYSTEMS EXPENDITURES 

FY 19884995 

TOTAL: FEDERAL/STATE SHARE ($ millions) 

700 - 

590.1 

600 - 

500 - 

400 - 

1988 1989 1990 1991 1992 1993 

FISCAL YEAR 

1994 1996 

m Federal EZi State 

2 
tincem about State lbgrm in Developing Autmnati Child Support Data Systems 

Congress and the Administration for Children and Families, Department of Health 

and Human SeM’ces expressed interest in learning about the status of implementation 

of automated child support data systems, delays in implementation, problems, 

successes, and lessons learned. Such information should be helpful to OCSE, the 

Department, and the Congress in continuing to develop an automated data system for 

child support, and in designing and implementing such systems in the future. 

Previously, the U.S. General Accounting Office (GAO) had issued two reports on 

Federal and State efforts to automate data systems. In 1989, the GAO reported on 

the automation status of State Child Support Enforcement programs.’ That report 

showed that between September 1985 and May 1988, States had made some progress 

toward developing automated child support systems. Thirty-nine States had 

progressed through at least one development stage, 13 States had remained in the 

same phase, and 2 States had regressed to a preplanning phase. 

In 1992, the GAO reported on OCSE’s oversight of States in developing the required 

automated child support systems. 2 GAO reported that OCSE did not require States 

to correct known problems. The GAO noted that OCSE’s approach resulted in a risk 

that serious problems would have to be corrected later when it is much more costly 

and time-consuming to do so. 

Pkimned Additional Child Supper Enfon;ement Data Systems 

The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 

required States to develop several additional child support data systems. For example, 

(1) State directory of new hires, (2) State case registry, (3) collection and use of Social 

Security numbers in child support enforcement, and (4) centralized collection and 

disbursement of support payments. The deadline set for implementation of the new 

systems is October 1, 2000. However, the deadline shall be extended by one day for 

each day (if any) that the Secretary fails to meet the set deadline for prescribing final 

regulations. In developing the additional new systems, States are expected to face 

similar challenges as they faced in developing the certified data systems. 

We believe this report on implementation of State child support certified data systems 

will provide important information for planning and implementing the additional child 

support data systems. Additionally, we will issue a follow-up report on this subject of 

lessons learned by States in implementing the certified data systems. 

‘Child Support: State Progress in Developing Automated Enforcement Systems 

(GAO/HRD-89-lOI%, February 10, 1989). 

2Child Support Enforcement: Timelv Action Needed to Correct System Development 

Problems (GAO/IMTEC-92-46, August 13, 1992). 

3 
METHODOLOGY 

We used a standardized questionnaire to survey all 50 States, the District of Columbia, 

Puerto Rico, Guam, and the Virgin Islands. Additionally, we conducted telephone 

interviews with staff at ACF headquarters and 10 regional offices. Finally, we 

conducted telephone interviews with eight judgmentally selected State contractors who 

were responsible for developing the required automated data systems. 

We used the following criteria in selecting the eight contractors. First, we stratified 

the States into the following two groups. States that were (1) certified, including those 

States that had obtained a Level 2 certification review by ACF, and (2) not certified. 

We selected four contractors from each of the two groups. 

From each organization included in our survey, we obtained information on 

experiences and lessons learned in developing automated data systems for child 

support enforcement. Further, we obtained views of staffs on reasons for delays in 

developing certified automated data systems. Additionally, from ACF staffs, we 

obtained information on the status of development of certified data systems. We did 

not determine the extent that funding affected State delays in developing and 

implementing certified data systems. The U.S. General Accounting Office has a 

review underway which we understand will examine the effect of funding on system 

implementation. 

As of August 30, 1996, 54 States3 had completed and returned our questionnaire -- a 

response rate of 100 percent. 

We conducted our inspection between April 1996 and August 1996. 

This inspection was conducted in accordance with Quality Stundardr for Inspections 

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

3For convenience in summarizing survey results, we considered the District of 

Columbia, Puerto Rico, Guam, and the Virgin Islands as States. 
FINDINGS 

MOST STATES ANTICIPATE HAVING A CERTIFIED AUTOMATED CHILD 

SUPPORT DATA SYSTEM BY THE REVISED OCTOBER 1,1997 DEADLINE 

srirstateshadcertjciedDatasysterns 

As of October 1, 1995, only one State had a certified automated child support system 

as required by the 1988 Family Support Act. However, at the time of our review, five 

more States had developed certified automated data systems for child support -- for a 

total of six States. 

Forty-two of the Remaining 48 States Bpect to Meet the Rev&d Deadline of October 1, 

1497 

The majority of the remaining 48 States (88 percent), said they expect to have 

certified data systems by the revised deadline. Table 1 shows the status of all States in 

developing and implementing certified automated child support data systems at the 

time of our review. The table also shows that two-thirds of the remaining 48 States 

(32 of 48) are in the implementation and operational phases. 

TABLE 1 

STATE PROGRESS IN DEVELOPING AUTOMATED DATA SYSTEMS 

CURREWTPHASE NUMBER OF STATES IN PHASE 

Design 2 

Programming 3 

Testing 9 

Conversion 2 

Implementation 9 

Pilot in several counties, but enhancing 1 

Operational Statewide, but enhancing 12 

Operational Statewide, but transferring new 1 

system 

Level 1 Certification Review 2 

Level 2 Certification Review 7 

Certified 6 

TOTAL STATES 54 

I 

.Tlx.. 48 .States ,that. did. act have certified .data systems at, tire. time. of. our review were ,in one ,or more 

phases of development or implementation: For the States that selected more than one phase, we 

chose the last phase checked to be’ the State’s cnrrent phase. 

5 
Five of the Remaining 48 States Did Not K&w whether or Not lhcy Would Meet the 

Revived Deadline of October I, 1997 

Officials from the five States gave several reasons for uncertainty about meeting the 

revised October 1, 1997 deadline. Some of the more prevalent reasons were (1) the 

system has to be implemented in a number of counties, (2) ACF’s certification guide 

was published too late, (3) contractor’s plan was flawed, and, based on past 

performance, the State has no confidence in the contractor’s projections, and (4) State 

management is insisting that appropriate time be taken to develop a quality system. 

We observed that the six States who already have certified systems and the 42 who 

expect to have such systems by October 1, 1997 faced similar challenges. 

One State Doa Not Expect to Meet the Revived Dead&e of October I, 1997 

This one State does not expect to develop a certified automated data system by the 

revised deadline because of procurement and contractor problems. That State said 

they may have a certified system by October 1998. Again, 6 States have successfully 

overcome such barriers and 42 others expect to do so. 

STATES, ACF, AND cXXUTRACl-‘ORS GE NERALLYA’ITRIBUTED 

IMPLEMENTATION DELAYS LARGELY TO THREE PROGRAM ELEMENTS 

Our survey results show that neither the States, ACF, nor contractors were solely 

responsible for implementation delays, but each organization shared in the delays. 

States, ACF and contractors identified various program elements that contributed to 

the delays. Table 2 shows factors States said caused delays in developing and 

implementing certified data systems. 

However, States identified three program elements that contributed most to delays in 

developing and implementing certified automated data systems for child support. The 

program elements were (1) ACF’s transfer policy, (2) short timeframe for developing 

and implementing the systems, and (3) ineffective State and contractor working 

relationships. These are the top five factors identified in Table 2. 

6 
[r 

1. ACF’s prior mandate that States ‘transfer’ a CSE 

system 

TABLE 2 

FAcXXlS CAUSING DELAYS IN DEVELOPING AND IMP-G 

STATE CHILD SUPPORT CERTIFIED DATA SYSTEMS 

FACIXNIS CAUSING DELAYS PERCENT 

1 

II 

70% (38 of 54) 

I 

I 

*55% (27 of 49) 

2. Not enough time allowed by the October 1, 1995 

deadline for developing and implementing your State’s 

certified data system 

3. Contractor meeting “deliverables” schedule stipulated in 

contract 

4. Qualitv of contractor’s work 

5. Problems with State contractor 

6. State administrative problems 

7. Resources assigned to other competing child support 

priorities 

5. State staff technical expertise to develop and implement 

data system 

------A 

*49% (24 of 49) 

I 

*43% (21 of 49) 

I 

9. Guidance provided bv ACF to State 

10. Guidance/direction provided by State to contractor 

11. Technical assistance provided by ACF to State 

12. State monitoring of contractor’s progress 

13. State leadership and commitment 

14. State planning process 

15. State-established contract requirements 

16. State legislation 

17. Organizational location of child support data system in 

relation to State IV-D program office 

*17% (8 of 49) 

I 

*13% (6 of 49) 

I 

12% (6 of 54) 

8% (4 of 54) 

I 

18. Monitoring by ACF 

y 5 of.54 States did ntit use contractors, thereby reducing the 

to ‘49. 

7 
Attempts to lhzn.$wAutomated Data Systems from One State to Another Did Not Wok 

In 1986, OCSE established a transfer policy generally requiring States seeking 

enhanced funding to use existing automated data systems of other States as models 

rather than develop new systems. The OCSE expected such transfers to (1) save 

system development time and costs, and (2) increase the likelihood of success, 

especially in States lacking technical staff. 

However, about 71 percent of the States said the attempt to transfer an automated 

data system delayed, rather than enhanced, development and implementation of 

automated systems. For example, several State officials said attempts to use a transfer 

system delayed implementation by several years. 

According to the States, the transfer requirement delayed development and 

implementation of certified data systems for two major reasons. 

b No Complete Systems to Transfer: When States began developing data 

systems, there were no certified systems to transfer as models. None of the 

States had complete, mature automated IV-D child support systems that could 

be certified according to the requirements of the 1988 Family Support Act. 

b Transfer Systems Not Unique To State Needs: The systems States finally chose 

as a transfer model had to be redesigned, rewritten, modified and enhanced to 

meet individual State needs. One State official said the transfer concept was 

fundamentally flawed. It called for the transfer of poorly designed systems and 

old technology that had to be significantly enhanced to function for individual 

States. State officials said that redesigning, rewriting, and enhancing the flawed 

transfer systems resulted in much lost time. 

According to many States, the existing State systems they tried to transfer did 

not meet the diverse needs of individual States and counties. The States said 

the transfer concept seemed to be based on a premise that one child support 

program is like another. They said, however, that in reality each child support 

program is unique, and trying to adopt another system wasted time and 

resources. For example, officials in one State said they wasted about a year 

trying to adopt a transfer system. The final result was a documentation of 

deficiencies in the transfer system that were eventually used to justify not using 

the system. 

A few States said the transfer systems did not permit the degree of 

customization desired by individual States. For example, officials in one State 

noted that the transfer system could not satisfy over 182 elected officials 

involved in child support at the State and county level. The requirements of 

county-administered child support systems create additional difficulties for some 

States. Some States said the transfer system requirement forced them to 

choose a system they otherwise would not have chosen. 

8 
ACF and contractor staffs generally corroborated State opinions that the transfer 

policy was a major contributor of the delays. Both ACF and contractor staffs said the 

transferred system needed significant modifications. 

October I, I995 Deadkhe did not Allow Adequate lhe for Developing and 

Implementing State Certified Data *stems 

Seventy percent of the States said the October 1, 1995 deadline, set by the Congress, 

was unrealistic for developing and implementing certified data systems. According to 

State officials, the time was unrealistic because (1) final system requirements from 

ACF were late, (2) political issues could not be resolved in time allowed, and (3) 

complex State systems could not be developed in time allowed. 

b System Requirements Issued Late: State child support officials said ACF 

issued final certification requirements and guidelines in June 1993. This was 

too late, they said, to analyze, design, redesign, develop, and implement systems 

to meet the October 1, 1995 deadline. Several State officials explained that 

they started developing systems based on 1992 regulations which detailed 

specifications for computer systems. However, the June 1993 regulations 

required significant and extensive changes to the automated systems that States 

had underway. Other States said they did not know what was required until 

they received the 1993 certification requirements. 

b Political Issues Could Not Be Resolved In Time: State officials said the 

October 1, 1995 deadline did not consider a need for obtaining political 

consensus among all child support agencies in a State. They explained that 

development of a central child support system must consider the needs and 

desires of many State and local officials, including local agencies, county 

officials, clerks of courts, and court administrators. 

To illustrate, one State official said completion of the implementation phase 

was dependent on total county cooperation. That official said the road from a 

separate, individual county system to an integrated, statewide system took a 

long time, and the deadline did not allow enough time for this task. 

b Not Enough Time To Develop Broad Scoped and Complex Systems: Many 

States said the scope and complexity of the required certified data systems 

made the deadline unrealistic. To illustrate, one State official said the deadline 

allowed inadequate time to do the extensive testing, and numerous interfaces 

with other databases that were required. Another said the time was inadequate 

for the extensive procurement process. One official said the scope and 

complexity of the systems were underestimated at the Federal, State and local 

levels. 

9 
Several State officials said only a few private sector contractors had child 

support and public welfare expertise. They said the child support deadline did 

not include consideration of this limited resource pool. Since only a few 

experienced contractors were available, States said the deadline was unrealistic. 

Again, ACF and contractors agreed that October 1, 1995 deadline was a major 

contributing factor to the delays. ACF and contractor staff said the deadline was 

unrealistic because of the (1) late issuance of Federal regulations and certification 

requirements, (2) political issues in States involving a number of different agencies, 

and (3) systems were complex and expensive to develop. 

I.eche Stnte and Gmbwtor Wohing Reibionstip 

b Contractors Could Not Deliver Acceptable Products on Time: Officials from 

55 percent (27 of 49)4 of the States said contractors failed to deliver as 

stipulated in their contract. To illustrate why contractors failed to deliver, 

several officials furnished the following comments. 

-- The contractors lacked experienced staff, and in some instances, the 

contractors lost experienced staff after obtaining a contract. 

-- The contractors had insufficient staff to accomplish what was agreed to in the 

contract. 

-- The contractor changed management after the contract was obtained. 

-- The contractor overpromised, underestimated the scope and complexity of 

work, poorly planned, and ultimately failed to deliver as scheduled. 

b Contractors Experienced Quality Problems: Officials from 49 percent (24 of 

49) of the States attributed contractor delays to poor quality work. To illustrate 

contractors’ poor quality work, several officials said 

-- every deliverable was always late and subsequently rejected when received. 

Ultimately, deliverables in one State were accepted only conditionally, 

-- contractor has never delivered an acceptable product on schedule, 

-- many of the programs they accepted from the contractors did not work once 

implemented, and 

-- contractor programs could not pass quality test without extensive 

modifications. 

45 of 54 States did not use contractors, thereby, reducing the number of States to 49. 

10 
b Contractors Experienced Various Other Petiormance Problems: Officials from 

43 percent (21 of 49) of the States attributed contractor delays to problems 

other than those mentioned above. For example, several officials said 

-- contractor never fully understood the business of child support enforcement, 

-- contractor failed to undertake needed analysis of State policies, procedures, 

and current systems before starting the project, 

-- contractor was not receptive to input from the State on the system design 

(e.g., system users), and 

-- State spent many months deciding what they wanted from their system, 

but the contractor pushed his own ideas instead of listening to the State. 

Likewise, ACF staff said ineffective State and contractor working relationships 

contributed to delays. To illustrate, ACF said contractors were not adequately 

prepared to deal with certification requirements on the level that States needed. Also, 

only a limited number of contractors had expertise in developjng certified data 

systems. Contractor staff also said there was not enough available resources to 

develop systems, since every State’s system had to be developed by the same deadline. 

Contractor staff also said that both State and contractors lost experienced staff which 

contributed to delays. 

Other Potential Causes of Delays 

To identify potential causes of delays in implementing certified data systems, we 

considered several factors in addition to those named by States, ACF, and contractors. 

For example, we considered (1) county vs State administration, (2) centralized vs 

distributed data processing systems, and (3) whether or not States used predominantly 

contract staff vs predominantly in-house staff to develop certified data systems. We 

found that these factors did not appear to contribute to delays in States meeting the 

deadline. 

MOST STATES CONSIDERED THE QUALITY OF FEDERAL TECHNICAL 

ASSISTANCE AND GUIDANCE TO BE GOOD TO EXCELLENT 

While States expressed concern about some guidance such as the transfer policy and 

timeliness of final certification requirements, 70 percent of the States said that overall 

the quality of ACF’s technical assistance and guidance was good or excellent. ACF 

provided various types of technical assistance and guidance to States at different stages 

during planning and development of the certified systems. For example, ACF 

furnished various publications to States for guidance; held various group meetings, 

conferences, and workshops; made on-site reviews, and provided individual 

11 
consultation. Table 3 summarizes the major types of technical assistance and guidance 

provided and the number of States receiving the help. 

TABLE 3 

TECHNICAL ASSISTANCE AND GUIDANCE PROVIDED BY ACF Xl STATES 

TYPESOFTIXHNICALASSISTANCEAND 

GUIDANCE ACF PROVIDED To STATES 

NUMBER OF STATES 

RECEIVINGTECHNICAL 

A!!SISTANCEANDGUlDANCE 

Interpretation of Certification Guide (Q&A) 49 

Certification Guide and Questionnaire 47 

Financial Test Deck I 45 

Visits with Federal Staff I 43 

User Group Meetings 

CSENet Technical Assistance 

41 

40 

Conferences 31 

ACF Bulletin Board 30 

Teleconferences with Staff 28 

On-Site Assistance 27 

Workshops 21 

Facilitate Collaborative Efforts and 

Communications between States 

21 

Review of Draft Responses to Questionnaire 21 

NQJJZ States cuuld check more than one type of technical assistance or guidance. 

States said the on-site reviews, certification guide and questionnaire, interpretation of 

the certification guide, and user group meetings were the most helpful. 

12 
RECOMMENDATIONS 

Despite the favorable outlook, the Administration for Children and Families (ACF) 

should take steps to ensure that all States develop a certified automated child support 

data system by the revised October 1, 1997 deadline. We recommend that ACF: 

b Secure a detailed action plan from each State identifying specific steps they are 

undertaking to meet the revised deadline. 

b Establish an intensive system to continuously monitor the status of each State’s 

progress towards becoming certified by October 1, 1997. 

b Provide more indepth technical assistance and guidance to States having 

difficulty to ensure that appropriate adjustments are made to meet the revised 

deadline. Such assistance could include (1) working with States to determine 

specific causes of problems, and (2) assisting States in designing and 

implementing corrective action measures. 

The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 

requires States to develop several additional child support data systems by October 1, 

2000. Some lessons learned from the systems development effort analyzed in this 

report may be applicable to the new systems. We suggest that ACF: 

b Allow States flexibility in determining whether or not transferring proven child 

support data systems from one political jurisdiction to another would shorten 

implementation time, reduce systems cost, and achieve standardized systems. 

b Develop strategies to identify areas where States can provide technical 

assistance to others. ACF should also coordinate this effort both regionally and 

nationally. 

Towards this effort, we will issue a report in the near future that identifies lessons 

learned by States in their efforts to develop and implement certified automated data 

systems. 

13 
AGENCY COMMENTS 

The Principal Deputy Assistant Secretary for Children and Families commented on 

our draft report. She expressed general agreement with our recommendations. To 

help assure that States implement certified automated data systems by the revised 

October 1, 1997 deadline, ACF is re-emphasizing the importance of Advance Planning 

Document Updates by States. The ACF will also provide more in-depth technical 

assistance to States, including more frequent on-site visits by regional and central 

office staffs. ACF intends to obtain Quarterly Status Reports from States experiencing 

difficulties in developing certified data systems. 

Further, ACF modified original instructions requiring States to transfer another States’ 

child support data system. The revised instructions give States an option on whether 

or not to transfer another States’ data system. The ACF is also seeking opportunities 

to build supportive relationships between States to enhance development of the data 

systems. 

The Acting Assistant Secretary for Planning and Evaluation also concurred with our 

recommendations. 

Appendix A shows the full text of ACF comments. 

14 
APPENDIX A 

A-l 
DEPART-MENT OF HEALTH & HUMAN SERVICES 

March 14, 1997 

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w 41LcIc ADMINISTRATION FOR CHILDREN AND FAMILIES~ 

Et!* - 

rf)ffice uf the Assistant Secretary, Suite 600 

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370 L’Enfant Promenade, S.W. 

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-- 

Washington, D.C. 20447 

DWI-MPTO: 

FROM: 

SUBJECT: 

-3 !Ez Dsmsul!~ 

June Gibbs 'Brown 

Inspector General 

Olivia A. Golden 

Principal Deputy As 

for Children and Families 

OIG Draft Report Wnplementation of State Child Support 

Certified Data Systems" (OEI-04-96-00010) 

Thank you for the opportunity to respond to your draft report of 

findings concerning State Child Support Data Systems. Our 

comments follow the order of recommendations in the report. If 

you have questions regarding this response, please contact David 

Ross of my staff at (202) 401-9370. 

Comments: 

OIG Recommendation I: Secure a detailed'action plan from each 

State identifying specific steijs they are undertaking to meet the 

revised deadline. 

ACF Response: We generally agree with the OIC's 

recommendation, and will place a renewed emphasis on the 

States' informational and submission requirements of Annual 

and As-Needed Advance Planning Document Updates. 

OIG Recommendation 2: Establish an intensive system to 

continuously monitor the status of each State's progress towards 

becoming certified by October 1, 1997. 

ACF Response: We generally agree with the OIG's 

recommendation in this area,, and will be offering and 

.conducting additional technical assistance reviews to those 

States in need of these services, as well as to any State 

asking for such services. Further, we intend to employ as 

practicable, the use of Quarterly System Status Reports by 

those States experiencing difficulties with their Child 

Support system development project. 
OIG Recommendation 3: Provide more in-depth technical assistance 

and guidance to States having difficulty meeting the revised 

deadline. Such assistance could include (1) working with States 

to determine specific causes of problems, and (2) assisting 

States in designing and implementing corrective action measures. 

ACF Response: We generally agree with the OIG's 

recommendation in this area, and will offer and conduct 

additional technical assistance reviews to those States in 

need of these, services, 

such services. 

as well as to any State asking far 

In order to support this need for enhanced 

levels of technical assistance to States, we have offered 

States the opportunity to have more frequent visits by our 

regional and central office staff. A primary purpose of 

these technical assistance visits will be to provide 

guidance to States‘ project staffs in designing and 

implementing corrective action measures, should corrective 

actions ba deemed necessary. 

Here are our responses to the OIG recommendations made regarding 

States' efforts to implement systems to meet the Personal 

Responsibility and Work Opportunity Reconciliation Act of 1996: 

GIG Recommendation 1.: Allow States flexibility in determining 

whether or not transferring proven child support data systems 

from one political jurisdiction to another would shorten 

implementation time, reduce systems Cost, and achieve 

standardized systems, 

ACF Response: We agree with this recommendation and have 

modified our original instructions so that States are no 

longer required to transfer systems from another 

jurisdiction. This policy change was issued on July 22, 

1994, under Action Transmittal ACF-AT-94-5 in which our 

practice of mandating the transfer of systems was 

require its *... consideration as an option in.the 

changed to 

alternatives analysis...,* We will: continue to review our 

policy towards systems transfer, as with all policies 

regarding systems development, to ensure that we provide the 

clearest guidance and most cost-effective and efficient 

solutions to States in the area of data systems development, 

implementation and operation. 

OfG Recommendation 2: Develop strategies to identify areas where 

States can provide technical assistance tb others. AC!? should 

also coordinate this efforC both regionally and.nationally. 

ACF Response: 

this area, 

We agree with the OIG's recommendation in 

and have begun seeking opportunities to build the 

types of supportive relationships between States systems 
Paw 3 

development and operations staffs that are envisioned by 

this recommendation. We are seeking opportunities through 

scme of the many conferences we sponsor each year to allow 

for enhanced technical. assistance between States. The ACF 

Users Group Conference, held twice a year, is another 

example of how we are striving to bring States' staffs 

together on issues of mutual interest. over the last two 

years, we have held many regionally-based CSENet Technical 

Aseistance Workshops under the direct sponsorship of a 

particular State. These workshops., in many ways, directly 

address the OIG's suggestions of having States become 

valuable resources ta one another. ACF will cont=inue to 

seek more opportunities to bring the States together, 

regionally and nationally, as technical assistance resources 

and partners.