Child Support Report XXVI, No. 1, 20040101

Our Road to the Future was the theme of the 2003 National Child Support Systems Conference, hosted in Washington, D.C., December 9-11, 2003. Program, policy, and systems staff met to discuss the role of state, tribal and Federal systems in the future of the child support enforcement program.

Commissioner Sherri Z. Heller, Ed.D. kicked off the journey, giving conference participants a view of the road to come, including some of the sights, potholes and detours they may encounter along the way. Dr. Heller spoke of the accomplishments of the child support program and some of the issues that have impeded program progress. Performance over the past few years has been nothing less than extraordinary; however, there is more work to be done if child support is to become a truly reliable source of family income.

Dr. Heller envisions a program in which states, tribes, and OCSE harness technology to enable proactive case management and activity. The focus must not be solely on distinct Federal and state enterprises, but on an integrated Child Support Enterprise. This may involve changes in the relative roles of state and Federal systems, with Federal systems facilitating state efforts to be more proactive in case management, as we move towards a child support superhighway.

A plenary session on the Child Support Enterprise provided conference participants with one possible map to that superhighway. Enterprise architecture (EA) is defined as business enabled by technology. Use of EA ensures information technology (IT) decisions are made by people who understand the business, and constantly aligns IT investments to the business.

OCSE proposed an approach to creating a "child support enterprise," consisting of modernized, integrated information systems that connect people and processes nationally to serve children and families. All program partners and stakeholders would have a role within the child support enterprise. It is critical for OCSE and the states to communicate effectively so their architectures can operate to the greatest extent possible.

The audience received a preview of some new expressways that may lie ahead for the program. Pending legislative initiatives will further increase the efficiency and effectiveness of the child support program. These initiatives will also have a significant impact on the respective roles of Federal and state partners as well as the integration of state and Federal enterprise architectures.

There was a day-long plenary on the proposed legislation authorizing OCSE to seize assets identified through Multi-State Financial Institution Data Match (MSFIDM). Conference participants received an update on the MSFIDM Workgroup findings and recommendations, and presented states with an overview of the proposed process for the levy. States were strongly encouraged to offer feedback and establish consensus on issues such as fees, due process, data elements, and the overall impact to states.

OCSE anticipates a phased-in approach to implementation of the proposals, beginning with Federal seizure of multistate financial institution accounts, then moving to the insurance match, and then gaming intercept. These initiatives make apparent that there must be a paradigm shift programmatically that incorporates our information technology systems. The Federal government is moving from a largely supportive role into a larger enforcement role on the "back-end." Conference participants discussed some of the implications of this, including the many challenges associated with these initiatives, and the need for systems, both Federal and state, to be more integrated.

Electronic payments for child support are on the rise in state disbursement units (SDUs) all over the country. SDUs are required, as part of state certification, to be able to receive electronic payments from employers in two file formats: CCD+ and the CTX 820 Remittance format. As states worked to establish their SDUs and to develop the infrastructure for receiving electronic payments, a "simplified" version of the CTX 820, which came to be known as "CTX Lite" came into existence. This rogue format was never approved by either the National Automated Clearinghouse Association (NACHA) or the American Standards Committee (ASC) X12. Many employers began using it, and many states accepted it, either because they did not know they were receiving it or to accommodate employers who were sending it. The Employer Services team at the Federal Office of Child Support Enforcement worked with SDUs, with NACHA, and with the banking community to discourage employers from using this unapproved electronic format, but some employers continued to use it.

In an effort to deal with the problem, the Michigan SDU (MiSDU), in partnership with OCSE and NACHA, designed a letter to be used to notify employers who were using the incorrect CTX Lite file format. The letter was designed to go to all employers remitting a CTX Lite electronic file, along with a copy of Michigan's Employer Automated Clearinghouse (ACH) Software CD, which enables employers to remit their payments electronically. Thus MiSDU was offering employers a solution, not merely notifying them of a problem.

MiSDU began by manually reviewing raw data files remitted by electronic employers within a 45-day time frame. After identifying 37 employers who were remitting in the CTX Lite form, it began sending letters to the identified employers in September 2003 along with the ACH software. The letter also stated that the employer would be required to re-test its CTX 820 file format with the MiSDU. Of the original 37 employers remitting incorrectly, 16 have successfully retested and converted to either CCD+ or CTX 820 (as of December 2003). MiSDU continues to track the remaining employers to monitor their compliance in converting to an approved file format.

Although the actual number of affected employers was not necessarily large, the size of the employers themselves and their respective withholdings were very large. MiSDU anticipated some frustrations from the affected employers but has actually received positive compliance. It hopes to have all 37 employers converted to proper file formats by March 2004.

For more information contact Monica Bowman of MISDU at monica.bowman@acs-inc.com. To review employer's letter contact Nancy Benner at nbenner@acf.hhs.gov.

In an effort to provide more timely responses to customer inquiries as well as save the agency time and money, the Butler County, Ohio, Child Support Enforcement Agency (CSEA) developed a Digital Document Management System which was designed to convert nearly 26,000 active support cases to a paperless system.

Imaging technology is not new to the management of client files, but getting this technology at little to no cost most assuredly is. In a world of ever-evolving technology, customers have grown to expect their needs be addressed in a timely fashion. In the age of paper filing systems, this was often difficult and frequently impossible. Paper files are usually bulky, disorganized, and sometimes misplaced, making it problematic for an agency to meet the specification of their customers' needs.

Imaging case files is often the best way of solving issues relating to file tracking, access and, when appropriate, final disposition. With the costs of purchasing items required for the creation and storage of physical files eliminated, the agency will save hundreds of thousands of dollars per year along with the time it previously took staff to manage the file system. The system will also reduce time in regards to routing and searching for files. With the application viewable on each employee's personal computer, more than one person may review a file at the same time and staff are able to answer customer inquiries in a more timely and efficient manner.

Imaging, while a wonderful idea, can end up costing an agency thousands of dollars. In 2002, through the partnership of the CSEA, Butler County Information Services and Butler County Records Center, an in-house imaging system was developed specific to the needs of the CSEA. A workgroup of approximately 10 individuals was created to discuss the agency's needs in the development stage of the project and they continued to meet once the system was put into place to discuss and correct any problems that occurred.

While other counties in Ohio and across the United States have contracted with outside vendors and are spending an average of $500,000 for their imaging systems, Butler County only expended approximately $50,000. Since the system was created in-house it was designed specifically with the needs of the child support program in mind. Furthermore, all programming and design costs were absorbed through the use of current county personnel. The agency was only required to purchase hardware such as server storage space, CD burners, laptop computers and scanners. Thus, the agency saved about $450,000 as compared to other counties.

Since its implementation, staff in all areas of the agency have noticed an increase in the amount of time they have to work on cases rather than deal with requesting, routing, searching for and creating files. The agency's legal staff alone save an average of ten minutes per case by having access to the imaged documents via their laptops in court. Overall, the system will not only save the agency thousands of dollars over the course of the next year, but has already enabled CSEA staff to better serve agency consumers in a more timely and efficient manner.

The CSEA currently employs 91 employees who previously spent an average of two hours per day on the previous file system. However, now just seven clerks work four hours per day on scanning documents into the application. All other staff have cut down approximately two hours per day because they are now able to access cases on their personal computers. Once all active cases have been scanned into the system, we anticipate additional time savings.

Once the system was put into place, a goal was set to prepare 95 files per day (average of one case per employee) and image 475 files per week. Since the agency began using the imaging system in May 2002, more cases have been imaged. At this rate of completion, the agency is looking to complete the project by Spring 2004.

Dusty Dunaway is Communications Coordinator in Butler County, Ohio, Child Support Enforcement Agency

It has been brought to OCSE's attention that the FPLS is not often used for locating a parent or child in cases of parental kidnapping or for custody or visitation purposes. Commissioner Heller signed Action Transmittal 03-06 on December 22, 2003, which addresses Federal policy for use of the FPLS for enforcing a Federal or state law with respect to the unlawful taking or restraint of a child or making or enforcing a child custody or visitation determination. It is intended to increase awareness about the authority to use the FPLS for these purposes and the procedures for obtaining FPLS location information to assist in these cases.

OCSE believes that state IV-D agencies and the State Parent Locator Service (SPLS), as the entry point for FPLS location requests, should be of assistance in advising authorized persons about the proper steps for submitting location requests for parental kidnapping or custody and visitation purposes.

When an authorized person contacts the IV-D agency to request information from the FPLS in a parental kidnapping case or for purposes of making or enforcing a child custody or visitation determination, the IV-D agency should assist that individual by informing him or her of the requirements and procedures outlined above and any applicable state requirements or procedures.

AT-03-06 is available on the OCSE website at http://www.acf.dhhs.gov/programs/cse/pol/AT/at-03-06.htm.

OCSE has proposed revisions to the Notice of Lien and Administrative Subpoena forms. The notices were printed in the Federal Register on February 13. There is a 60 day comment period. The notices are available at: http://www.acf.dhhs.gov/programs/cse/newann.htm

OCSE's Website -- http://www.acf.dhhs.gov/programs/cse/newann.htm now has all the information needed to apply for SIP announcements, the Federal Register and ACF versions of the announcement and the application kit for printable copies of the required forms.

With increased use of electronic communications, some problems in interstate case processing have become more obvious. Case number mismatches and jurisdictional issues cause extra work for caseworkers. Format and definitional variations across states contribute to difficulties in electronically processing interstate cases. At the recommendation of states, OCSE determined that a nationwide perspective in reconciling interstate cases would identify the extent of the problem, and alleviate many of these issues.

In Dear Colleague Letter 03-21, Dr. Sherri Heller, OCSE Commissioner, stated that the goals of the Interstate Case Reconciliation(ICR) project are to "improve service to families with interstate cases, improve electronic communication among states, establish accurate state and national interstate case baselines, and establish clear accountability for interstate case processing."

States participating in the ICR project "signed on" during fall 2003. With technical assistance provided by OCSE, each participating state will develop an extract. The file will "extract" information from the state's database about those cases that the state considers interstate. OCSE will then use the extract file to match one state's interstate cases against interstate cases from other states. This match will occur in mid-March 2004. From that match OCSE will send response files to each state for automatic system updating and for manual reconciliation. These response files will be sent to the states in early spring 2004. The ICR schedule is subject to revision, based on the resolution of case identifier inconsistencies.

OCSE will break down mismatches into "reason codes", which will allow for automated processing of discrepancies and reduce the number of cases requiring manual correction.

"02 - The other state has a matching case, but your Other State Case Number is incorrect."

Additional "reason codes" will identify Other State FIPS Code discrepancies and Case Status discrepancies. The ICR will also establish accurate interstate caseloads, allowing caseworkers to focus on those interstate cases that truly require a two-state action.

A recent study estimated that $17.1 million would be saved through a more efficient use of state caseworker time by implementing the ICR program nationwide.

Helen Smith is Deputy Associate Commissioner, Office of Automation & Program Operations, OCSE. For more information contact David Noble, ICR Project Manager, at david.noble@ngc.com.

Researching and gathering multiple orders on interstate cases has been a laborious task. Creating multiple de novo child support orders in different states ended with the enactment of the Uniform Interstate Family Support Act (UIFSA) and the Federal Full Faith and Credit for Child Support Orders Act (FFCCSOA). States were mandated to implement UIFSA by January 1998. UIFSA places an emphasis on determining the controlling order for prospective enforcement. Tribunals are also required to reconcile arrears at this point.

OCSE is pleased to provide two products developed to enhance your efforts in selecting valid support orders and reconciling accrued arrears for prospective enforcement. The two products were developed under the OCSE interstate initiative and are available now on our website. They are the Determination of Controlling Order/Reconciliation of Arrears (DCO/ROA) Guide and the Arrears Reconciliation Calculator. The DCO/ROA Guide provides the framework for child support practitioners to solve multiple order and arrears consolidation issues that come up in everyday case work. It is divided in two sections: determining the controlling order and reconciliation of arrears. It offers step-by-step narratives, easy-to-use flow charts, and detailed questions and answers to assist you from start to finish.

The Arrears Reconciliation Calculator is a user-friendly automated calculator that helps child support practitioners with multiple- order interstate arrearage reconciliation processes. The Calculator uses a Microsoft Excel spreadsheet and is supported by instructions that explain how it works and what policy choices are incorporated. It also contains both summary pages and year-by-year documentation.

Both products were pilot tested in support mediation/negotiation and litigation in administrative and judicial tribunals. Typical reaction of staffers who tested them were, "the Guide helps overcome the reluctance of doing determinations of controlling orders and reconciliation of arrears," and, "the Guide and Calculator provide resolutions to long-standing interstate case processing issues that have plague child support for years."

Use the Guide and Calculator "as is" or incorporate them and develop more specific procedures for case processing. Or, use both products as training companions.

Take a minute, visit OCSE's website at http://www.acf.hhs.gov/programs/cse/pubs/2003/calculator and experience both of these newly created tools. We hope you will find the DCO/ROA Guide and the Arrears Reconciliation Calculator helpful and provide resolutions to those difficult, time consuming interstate cases.

For over five years, a California builder of specialty homes evaded traditional child sup- port enforcement remedies while building his own personal wealth of real estate investments. He abandoned the financial needs of his four children in Washington State, including one child who suffers from a chronic seizure disorder and who requires 24 hour medical care. The non-custodial parent just didn't pay. For a while, the family relied on public assistance to make ends meet.

Through the collaborative efforts of Support Enforcement Officer Sherry Feely of the Washington State Division of Child Support, the Encino office of California's Family Support Division, the HHS Division of Special Staffs' Project Save Our Children (PSOC) Task Force, Special Agents with the Office of Inspector General, and Federal prosecutors with the United States Attorneys Office in Washington and California, the non-custodial parent was indicted on Federal criminal charges and arrested in September 2003.

After spending some time in jail, and realizing that a felony conviction is possible under Title 18, Section 228 of the United States Code, the non-custodial parent paid $11,000 of his nearly $116,000 debt. Two payments of $5,000 each reached the family within a week of Christmas.

The custodial parent has expressed excitement and genuine appreciation for the multi-agency efforts, which followed a lengthy and intensive investigation.

While the Federal case is still pending, a full payoff of the remaining debt is anticipated through the sale of one of the non-custodial parent's properties.

Steve Tivel is an Investigative Analyst, PSOC,OCSE

Connecticut, District of Columbia, Florida, Illinois, Kentucky, Louisiana, Maine, Michigan, Minnesota, Mississippi, Montana, Nebraska, New Hampshire, Ohio, South Dakota and Tennessee were recently certified as meeting the automation requirements of the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA), bringing the total to 39.

Barbara Harrison, the most recent editor of Child Support Report, retired on January 2, 2004. Barbara served over 32 years in the Federal government; 29 in OCSE!

OCSE is interested in your suggestions for stories, articles, and items. Please submit your suggestions to the new editor, Gail A. Griffin, at 202-401-4594 or ggriffin1@acf.hhs.gov.