United States General Accounting Office
GAO Report to the Committees on Finance,
U.S. Senate, and Ways and Means, House
of Representatives
January 1999
SUPPLEMENTAL
SECURITY INCOME
Increase Receipt and
Reporting of Child
Support Could Reduce
Payments
GAO/HEHS-99-11
United States
GAO General Accounting Office
Washington, D.C. 20548
Health, Education, and
Human Services Division
B-279807
January 12, 1999
The Honorable William V. Roth, Jr.
Chairman
The Honorable Daniel Patrick Moynihan
Ranking Minority Member
Committee on Finance
United States Senate
The Honorable Bill Archer
Chairman
The Honorable Charles B. Rangel
Ranking Minority Member
Committee on Ways and Means
House of Representatives
In 1996, over a quarter of the nation’s children lived in a household where
only one parent was present, usually the mother. About 42 percent of
female-headed families with children had incomes at or below the poverty
level, and a majority of these families received government aid to help
meet their basic needs. For four of the largest federal programs that
provide such aid—Temporary Assistance for Needy Families (TANF),
Medicaid, the Food Stamp Program, and Supplemental Security Income
(SSI)—child support received by a custodial parent is required to be
considered as income in determining eligibility and benefit amounts.
To reinforce the idea that parents have the primary responsibility for
supporting their children and to minimize government costs of providing
aid, single parents with children applying for or receiving TANF (since
1975) or Medicaid (since 1984) are required as a condition of eligibility to
cooperate with state Child Support Enforcement (CSE) agencies in seeking
child support income. Cooperation involves identifying and helping to
locate the noncustodial parent of a child and, if needed, taking steps to
help establish paternity. In addition, as of 1996, states have the option of
requiring food stamp applicants and recipients to cooperate with CSE.
In contrast, single parents receiving SSI on behalf of their children are not
required to cooperate with CSE agencies. These parents are, however,
required to report any child support income received to the Social Security
Administration (SSA), which administers the SSI program. In June 1998,
about 60 percent of the 904,554 children under age 18 receiving SSI lived in
single-parent families. In about 9 percent of these cases, the parents
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reported child support income to SSA. These statistics suggest that there is
potential for increasing child support income in the other families. They
also suggest that some families receiving child support may not report it to
SSA.
Because of congressional interest in enhancing parental responsibility and
self-sufficiency among families receiving public assistance and concern
about the need for improved management of the SSI program, we explored
opportunities for increasing the number of SSI single-parent families
receiving child support and for improving the reporting of such support to
SSA. More specifically, we identified the potential for reducing SSI payments
by increasing the extent to which (1) SSI children in single-parent families
are served by the CSE program and have support collected for them and
(2) support collected by CSE programs is reported by custodial parents to
SSA. We focused our work on the CSE programs of Florida, New York, and
Texas, three of the four states with the largest numbers of children
receiving SSI.1 We did our work between May 1997 and December 1998 in
accordance with generally accepted government auditing standards. (See
app. I for information on our scope and methodology.)
SSIbenefits could be reduced and single-parent families’ incomes
Results in Brief increased if more children on SSI received CSE services. The Florida, New
York, and Texas CSE programs provided services to almost 45,000 SSI
children in single-parent families in those states and collected child
support for more than one-quarter of those served. However, more than
52,000 other SSI children in single-parent families in those states did not
receive CSE services. We estimate that if their parents had been required to
cooperate with CSE services, annual SSI benefits to these children would
have been reduced by about $4.2 million, while the net annual income
(considering the child support and the resulting adjustments to the SSI
benefits) of the SSI single-parent families would have been increased by
$2.2 million. These potential benefit reductions would be offset by the
costs for SSA to administer a child support cooperation requirement and by
the costs, which could be considerable, for CSE programs to provide
services. Even though savings to the government are not guaranteed,
increasing the number of SSI children receiving CSE services would help
promote parental responsibility and increase the incomes of single
1
The four states with the largest number of children receiving SSI, in descending order, are New York,
California, Florida, and Texas. We did not include California in our review because it does not have a
statewide automated CSE data system. The three states included in our review represented about
20 percent of SSI children nationwide in June 1998.
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parents, helping them to achieve and maintain economic independence
and reducing their dependence on public assistance.
Among the SSI children in single-parent families for whom the three states’
CSE programs collected support, we found strong evidence that many
parents had not reported the income to SSA as they were required to do.
The Florida, New York, and Texas CSE programs collected support for
15,427 SSI children—12,841 living in those states and an additional 2,586 SSI
children living in other states. For 68 percent of these children, SSI records
did not contain a report of child support income, indicating that their
parents did not report the income to SSA. We estimate that, in these three
states, SSA overpaid $7.7 million in annual SSI benefits because this
unreported support was not considered in calculating children’s’ SSI
benefits. These overpayments could be minimized in the future if SSA and
CSE established a routine method of exchanging information on SSI
recipients and child support collections.
The Congress established SSI in 1972 to ensure a minimum cash income to
Background needy aged, blind, and disabled persons, including needy children under
age 18 if they have severe disabilities. SSI, now the nation’s largest cash
assistance program for the poor, in 1997 paid about $26 billion in federal
funds to about 6.5 million low-income aged, blind, and disabled recipients.
Although SSI primarily serves adults, the number of children receiving SSI
has increased from 127,000 in December 1975 to 928,000 in
December 1997. SSA administers the program, which is authorized by title
XVI of the Social Security Act.
In 1975, in response to growing numbers of families receiving Aid to
Families With Dependent Children, the Congress created the CSE program
to reduce welfare spending and help single-parent families achieve or
maintain economic self-sufficiency.2 The program provides assistance in
obtaining financial and medical support for children through locating
noncustodial parents, establishing paternity and support obligations, and
enforcing those obligations. The Congress expanded the CSE program over
the years, and today state CSE agencies are required to provide services
automatically to families receiving TANF, foster care payments or services,
or Medicaid and to any other family that requests them.3 State CSE agencies
have responsibility for administering the program through state and local
offices. At the federal level, the Office of Child Support Enforcement
2
CSE refers to the program authorized by title IV, part D, of the Social Security Act.
3
Persons required to cooperate with state CSE agencies may not be charged fees for CSE services.
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within the Department of Health and Human Services (HHS) has oversight
responsibility for the program. The federal government pays 66 percent of
the states’ administrative costs for the CSE program, with the states paying
the remainder. The federal government also pays states incentive
payments for performance in establishing paternity and support orders,
collecting current support, collecting past due support, and operating
cost-effectively.4
In 1997, the CSE program collected about $13.4 billion in child support for
families receiving TANF and other families. About $10.8 billion of this was
distributed to families and $2.2 billion retained by the government as
recoupment of TANF payments. The Social Security Act requires that TANF
recipients assign their rights to child support to the state government and
that cash child support payments collected for TANF families be retained by
the government as recoupment for benefits.5 In the same year, CSE
collected child support for about 13 percent of the TANF child support
cases.
The requirement that persons cooperate with CSE as a condition of
receiving TANF or Medicaid benefits on behalf of children emphasizes that
parents, not the government, have primary responsibility for supporting
their children.6 However, TANF, Medicaid, and Food Stamp Program
applicants and recipients may not be required to cooperate with CSE if they
claim to have good cause for refusing to do so and the state agencies
administering these programs determine that the circumstances claimed
make cooperation not in the best interests of the child. Good causes for
refusing to cooperate may include, for example, fear of physical or
emotional harm to the child and/or custodial parent. For TANF recipients
who are required to cooperate but fail to do so, states are required to
reduce these recipients’ TANF grants by at least 25 percent and may opt to
eliminate TANF aid for the entire family.7
4
In the calculation of performance incentives, collections on TANF cases and former TANF cases
receive twice the weight as collections on cases of persons who have never received TANF.
5
Medicaid recipients assign to the government only their rights to medical child support payments and
payments for medical care from any third party. Thus, only cash child support designated for medical
expenses is retained by the government.
6
Many Medicaid and food stamp recipients are also TANF recipients and are therefore required to
cooperate with CSE. Non-TANF recipients of Medicaid are required to cooperate with CSE only in
establishing paternity and seeking medical support. In those states that have opted to require it,
non-TANF food stamp recipients are required to cooperate with all CSE services. As of
December 1997, seven states had chosen to require food stamp recipient cooperation with state CSE
agencies.
7
A survey conducted by the American Public Human Services Association in the summer of 1997 found
that 16 states eliminate the entire family’s assistance for failure to cooperate with CSE.
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The SSI program, on the other hand, does not require cooperation with CSE
as a condition of eligibility for receipt of SSI benefits.8 However, under the
Social Security Act, two-thirds of any child support received by, or on
behalf of, an SSI recipient is to be counted as income in calculating SSI
benefits. The amount of child support counted as income results in a
dollar-for-dollar decrease in the amount of SSI benefits to which a child is
entitled. These adjustments can reduce the benefit level, depending on the
size of the benefit, to zero, making the child ineligible for benefits.
When SSI parents receive child support for their children, they are required
to report this income to SSA for benefit determinations. SSA relies on
applicants and recipients to accurately report their income and assets, and
SSA policy requires that its staff obtain documentation to verify the amount
of income and resources that applicants report. To ensure recipients’
continuing financial eligibility and possibly detect some types of income
and resources that clients may not have reported, SSA uses computer
matches of SSI payment records against recipient financial information
contained in the payment files of third parties, such as other federal and
state government agencies. However, SSA does not match computer data
with state CSE agencies’ child support collection systems.
Our analysis in three states indicates that opportunities exist to serve
Opportunities Exist to more SSI children through the CSE program, which should result in
Increase the Number increased child support income for some families and reduced SSI
of SSI Children payments. Providing CSE services to additional families would entail costs
for SSI and CSE program administration, but would help promote parental
Receiving Child responsibility, increase some families’ incomes, and reduce the need for
Support public assistance.
8
Most SSI recipients are also Medicaid recipients and, if they are single parents, are required to
cooperate with the CSE program for the establishment of paternity (if needed) and the collection of
medical support for children in single-parent homes. Moreover, some families with a child receiving
SSI may also have one or more other children receiving TANF. In those cases, the families would be
required to cooperate with CSE to receive TANF benefits. Generally, a child does not receive both SSI
and TANF.
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More Than Half of the In Florida, New York, and Texas, 97,095 children under age 18 received SSI
Children Receiving SSI in in single-parent families as of September 1997.9 This represented about
Single-Parent Families in half of all SSI children in those states.10 The three states’ CSE programs
provided services to a total of 44,756, or 46 percent, of the SSI children in
Three States Did Not single-parent families in those states during the periods of our review.
Receive CSE Services These services resulted in child support collections for a significant
number of families. More than half (54 percent), however, of these states’
SSI children in single-parent families did not receive CSE services. As shown
in table 1, we did not find a CSE record for 47, 53, and 65 percent,
respectively, of children receiving SSI in single-parent families in Florida,
New York, and Texas during the periods of our review.11
Table 1: Receipt of Child Support
Services by Children Receiving SSI in Children receiving SSI in single-parent families
Single-Parent Families in Three States Children’s state of Receiving CSE Not receiving CSE
residence Total servicesa services
Number Number Percent Number Percent
Florida 30,459 16,235 53 14,224 47
New York 42,026 19,825 47 22,201 53
Texas 24,610 8,696 35 15,914 65
Total 97,095 44,756 46 52,339 54
Note: Data are for children in Florida receiving SSI as of July 1998, and in New York and Texas as
of September 1997.
a
Services provided by the Florida CSE during the 12 months ending mid-July 1998, by the New
York CSE for the 8 months ending August 31, 1997, and the Texas CSE for the 12 months ending
July 31, 1997.
Taken together, the three states’ programs collected support for 12,841, or
29 percent, of the 44,756 SSI children they served. Individually, the Florida,
New York, and Texas CSE programs collected support for 32, 21, and
39 percent, respectively, of the SSI children living in those states whom
9
For the purposes of our analysis, the terms single parent and single-parent family do not refer to the
marital status of parents or the number of parents in a household but rather to the situation in which
children are living in a home where only one of their natural or adoptive parents is present. In some
instances, someone other than a parent, such as an adult caretaker or representative payee, may
receive SSI benefits on behalf of a child.
10
The SSI children in single-parent families in Florida, New York, and Texas represented 55, 54, and
45 percent, respectively, of all of the SSI children in each of these states.
11
We found a small number—less than 10 percent—of single parents of SSI children not receiving
services who had reported child support income to SSA. They may receive child support through
means other than the CSE program, such as through the courts or directly from noncustodial parents.
Page 6 GAO/HEHS-99-11 SSI and Child Support
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they served.12 The median annual amount of support collected for these SSI
children was $487 in Florida, $350 in New York, and $501 in Texas. (See
also tables II.1 and II.2 for more detailed data.)
SSI Benefits Could Be Providing CSE services to SSI children in single-parent families who are not
Reduced and Families’ currently receiving them can potentially increase child support income for
Incomes Increased If More some of them and reduce reliance on SSI benefits. It is not possible to
estimate precisely the potential for child support collections among the SSI
Children on SSI Received children not currently receiving services because doing so requires
CSE Services information about the potential for payment by noncustodial parents,
which is not available. To estimate SSI benefit reductions that might result
from more SSI children receiving CSE services in the three states included in
our review, we applied each state’s collection rate for the SSI children it
currently served to the children not currently served and assumed that the
same median amounts of support could be collected. The actual amounts
of CSE collections that may result from serving these families could be
higher or lower than this estimate.
With this methodology, we estimate that CSE could collect a total of
$6.4 million in support for an additional 14,119 SSI children.13 With
two-thirds of the support counted as income for SSI benefit calculations,
we estimate SSI benefits for children in these states could be reduced by a
total of $4.2 million annually—$1.3 million in Florida, $1 million in New
York, and $1.9 million in Texas. Despite this reduction in benefits, the SSI
families’ incomes would be increased by a net of $2.2 million because not
all of the child support received would result in a reduction in SSI benefits.
(See table I.1 for detailed calculations.)
Requiring Parents of SSI Like any enforcement effort, requiring that all single parents applying for
Children to Cooperate With or receiving SSI for their children cooperate with CSE services as a
CSE Increases Costs for condition of receiving aid comes at a cost. SSI eligibility workers would
need to perform additional tasks to implement the requirement, and CSE’s
SSI and CSE but Ensures caseloads would increase, raising costs for these programs. However, such
That Child Support Is a requirement would increase the likelihood that noncustodial parents
Pursued for Those fulfill their financial responsibilities toward their children, thereby
Receiving Aid reducing custodial parents’ dependence on the government for support.
12
State CSE agencies can also provide services to children residing in other states, which we discuss
later in this report.
13
These data exclude SSI children whose SSA records indicated the receipt of child support.
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A cooperation requirement would necessitate that SSI eligibility workers,
like workers in other programs, provide information about the CSE
program to single parents receiving or applying for SSI on behalf of their
children. SSI eligibility workers would have to explain the requirement for
cooperation with CSE services, obtain information from parents for the
referral of children’s cases to CSE agencies, and make the case referrals.
For the TANF program, for example, some CSE agencies develop an intake
form to be used by the TANF agency in obtaining information on the family
and the noncustodial parent to help the CSE agency establish an
enforceable case.14 Also, in other programs, applicants must be notified of
the right to claim good cause for not cooperating, and then determinations
must be made about whether good cause exists.15 Additional time required
for tasks like these would likely lengthen the initial SSI eligibility interview
and increase associated paperwork.
In November 1997, SSA began interviewing a nationwide sample of
approximately 1,000 SSI recipients about child support issues to determine
the extent to which SSI recipients try to obtain child support and to
estimate the potential cost of adding a component on child support issues
in the initial SSI eligibility interview. SSA officials told us that the agency has
a draft legislative proposal under review by the Office of Management and
Budget that would require persons applying for or receiving SSI on behalf
of children to show they have tried to obtain child support. The proposal
does not require these individuals to cooperate with or to seek support
specifically through the CSE program—as opposed to other means—as is
now required for TANF and Medicaid recipients. The nationwide study
would also help to estimate the costs for SSA to implement its legislative
proposal.
Establishing a CSE cooperation requirement for SSI recipients would also
increase the workload and federal and state costs of the CSE program.16 In
New York and Texas, serving currently unserved SSI children would
increase the total CSE caseload in those states (as of Aug. 1997) by about
2 percent; for Florida, the increase would be about 1.3 percent. There
appears to be no generally accepted methodology for calculating the
14
In some jurisdictions, TANF applicants must cooperate with CSE (usually in the form of an interview
with a state CSE agency) before financial assistance is provided.
15
In the Aid to Families With Dependent Children (now TANF) program for fiscal year 1995—the latest
year for which data were available—8,387 claims of good cause were made and 5,462 were found valid.
The monthly average number of families receiving AFDC was 4.9 million in fiscal year 1995.
16
State CSE agencies are required to provide services to anyone who requests them, and SSI recipients
may all request services.
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actual costs of serving additional families in the CSE program. Although we
did not estimate CSE costs for providing services to additional families, we
believe they could be significant, potentially large enough to offset the
savings in SSI benefit reductions. While the CSE program would bear the
costs of providing services to all of the SSI families with children, it would
not collect child support for all of them, limiting the amount of savings
through SSI benefit reductions. Moreover, 34 percent of these CSE costs
would be borne by the states, which would generally not experience
savings from the reduced SSI benefits. Nevertheless, government cost
reduction is not the only goal of the CSE program. It also promotes parental
responsibility and strives to increase the incomes of single parents,
helping them to achieve and maintain economic independence and
reducing their dependence on public assistance.
In addition to exploring the potential for more SSI recipients to receive CSE
SSI Overpayments services, we also determined the extent to which those already receiving
Occur From CSE services were reporting to SSA the child support income collected for
Nonreporting of Child them by state CSE agencies. Our analysis of data for three states indicated
that many single parents of SSI children did not report to SSA the child
Support Income support collected for them by the CSE program. On the basis of this
analysis, we estimated that SSA overpaid about $7.7 million in SSI benefits
in 1 year as a result of such nonreporting. SSA could identify or prevent
many of these types of overpayments if it had information on CSE
collections for SSI children from one of the existing or
soon-to-be-operational sources of computerized CSE collections data.
Many Parents Did Not The Florida, New York, and Texas CSE programs provided CSE services for
Report Child Support SSI children living in those states as well as to some SSI children living in
Income to SSA other states.17 The three states’ CSE programs served a total of 55,884 SSI
children in single-parent families, including the 44,756 we identified living
in Florida, New York, and Texas and an additional 11,128 SSI children
residing in other states. These CSE programs collected support for 15,427,
or 28 percent, of these SSI children.18
17
A state CSE agency gives services to all children in the state who have requested services or whose
custodial parents are required to cooperate with CSE. In addition, a CSE agency in one state will
provide services to a child in another state when asked to do so by the CSE agency in the child’s state
of residence.
18
The Florida, New York, and Texas CSE programs’ child support collection rates for the SSI children
they served, including children living within and outside those states, were 32, 21, and 37 percent,
respectively. These individual state and aggregate rates are very similar to the collection rates cited
earlier that are based only on the SSI children served who reside in those states.
Page 9 GAO/HEHS-99-11 SSI and Child Support
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Our comparison of SSA and CSE records indicates that many parents of SSI
children with child support income did not report the income to SSA. As
shown in table 2, we found no indication of child support being reported
for 10,432, or 68 percent, of the SSI children for whom the three states’ CSE
programs collected support. (See also tables II.1 and II.2 for more detailed
information by state on the numbers and percentages served and for
whom collections were made.)19
Table 2: Parental Reporting of Child
Support Collections by Three States’ SSI children for whom CSE collected child supporta
CSE Programs for SSI Children in Parent reported Parent did not report
Single-Parent Families support to SSA support to SSA
Total
State CSEb number Number Percent Number Percent
Florida 5,828 1,755 30 4,073 70
New York 5,720 1,704 30 4,016 70
Texas 3,879 1,536 40 2,343 60
Total 15,427 4,995 32 10,432 68
Note: Data are for children in Florida receiving SSI as of July 1998, and in New York and Texas as
of September 1997.
a
Collections made by the Florida CSE during the 12 months ending mid-July 1998, by the New
York CSE for the 8 months ending August 31, 1997, and by the Texas CSE for the 12 months
ending July 31, 1997.
The total amount of unreported child support collected by these three
states for SSI children was almost $12 million.20 Because parents did not
report this income to SSA, SSA was not able to adjust benefit amounts
accordingly. We estimate that as a result, SSA overpaid $7.7 million in SSI
benefits in 1 year in these three states (see table 3).21
19
Because we relied on a computerized match of extracts of CSE and SSI automated records and not a
detailed review of case file information, we were not able to confirm that the child support collections
recorded in the CSE records were in fact distributed to each child’s custodial parent and, therefore,
were required to be reported to SSA. In some cases, for example, where other children in a family were
receiving TANF, the support collected for the SSI child may have been inappropriately retained by the
government and not distributed to the family. In other cases, the child support for an SSI child could
have been past due for a previous period of time during which the child was receiving TANF; in this
case, the child support collected may have been retained, appropriately, by the government and not
distributed to the family. In both cases, the support would not be counted by SSA as income because
the family did not receive it.
20
To arrive at this total, the collections by New York’s CSE over an 8-month period were projected to
12 months.
21
For our estimate, we calculated the estimated annual SSI overpayment for each child as two-thirds of
the annual unreported child support (the amount considered as income under law) or the annual SSI
benefit, whichever was less, and summed these amounts for all children for whom support was not
reported.
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Table 3: Estimated Annual SSI
Overpayments Resulting From Estimated
Nonreporting of Child Support annual
Collected by Three States’ CSE State collecting support overpayment
Programs Florida $2,858,205
New York 3,206,240
Texas 1,658,028
Total $7,722,473
Data on CSE Child Support We have in the past reported on the need for SSA to verify information
Collections Are Available voluntarily reported by SSI recipients by using existing state and other
for Verifying SSI databases.22 We specifically recommended that, to prevent overpayments
or detect them sooner, SSA (1) identify additional income sources for
Recipients’ Income which SSA does not currently have computer matches and (2) use on-line
access to routinely check for unreported sources of income in states when
it is cost-effective to do so.23 SSA has taken some actions in response to our
recommendations, including expanding use of on-line data maintained by
state agencies to better verify recipients’ financial information. In a recent
report, we recommended that SSA accelerate efforts to identify more timely
and complete sources for verifying financial eligibility information.24 In
this report, we identify another opportunity for SSA to improve its
administration of the SSI program.
Although no single, nationwide source of computerized data on all states’
CSE collections exists, states are required by the Social Security Act to
have three statewide computerized data files containing information on
child support collections from which SSA may obtain data for SSI recipients.
The first computerized data files from which SSA may obtain CSE
collections information are states’ CSE automated data processing and
information retrieval systems. State CSE programs were required by the
Family Support Act of 1988 to have statewide automated systems that
meet federal specifications by October 1, 1997. In addition, the 1996
welfare reform legislation required that states enhance these systems to be
22
Supplemental Security Income: Timely Data Could Prevent Millions in Overpayments to Nursing
Home Residents (GAO/HEHS-97-62, June 3, 1997); Supplemental Security Income: SSA Efforts Fall
Short in Correcting Erroneous Payments to Prisoners (GAO/HEHS-96-152, Aug. 30, 1996);
Supplemental Security Income: Opportunities Exist for Improving Payment Accuracy
(GAO/HEHS-98-75, Mar. 27, 1998).
23
Supplemental Security Income: Administrative and Program Savings Possible by Directly Accessing
State Data (GAO/HEHS-96-163, Aug. 29, 1996).
24
Supplemental Security Income: Action Needed on Long-Standing Problems Affecting Program
Integrity (GAO/HEHS-98-158, Sept. 14, 1998).
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B-279807
capable of electronically interfacing with other federal and state agencies.
As of November 16, 1998, 37 states’ CSE programs had received federal
certification for their data processing and information retrieval systems.25
Two other computerized statewide data systems were required by the 1996
welfare reform legislation to be in operation by October 1, 1998: (1) states’
centralized child support payment collection and disbursement units,
required for the identification, receipt, and distribution of support
payments on both CSE and non-CSE child support cases,26 and (2) states’ CSE
case registries, required to comprise information on all CSE and non-CSE
cases.27 For CSE cases, the registries must also include information on any
amounts owed that have been collected. Information contained in the state
case registries must be capable of being extracted from the state’s CSE
system and shared and compared with information contained in other
databases.
SSA officials expressed concern that CSE data files do not contain sufficient
detail for them to determine accurately the amounts of child support
income received by SSI children that should be considered as income for
the purposes of ascertaining eligibility and payment amounts for SSI
benefits. In addition, they said that in the past they encountered problems
in accessing various kinds of state data because of the differing capacities
of state data systems and state policies on and willingness to share data
considered confidential. SSA officials noted, for example, that after several
years of effort, exchanges of data on quarterly wages have not been
achieved with all states. They suggested that it would be more efficient if
CSE was responsible for reporting to SSA collections for SSI children, rather
than requiring SSA to access state data systems.
We agree with SSA that some states’ CSE data files may not contain
sufficient information upon which to base adjustments to SSI benefit
calculations. But states’ CSE data could, at a minimum, indicate to SSA those
cases for which child support may be a potential source of income that
should be further investigated. In addition, we acknowledge that the ease
and costs of obtaining CSE collections data will vary from state to state
because different degrees of automation exist in the data files of state CSE
25
The 37 include Guam and Puerto Rico.
26
If in August 1996 local courts were being used to process payments, the state has an additional year
before it must have a central payment disbursement unit. State disbursement units must process
non-CSE cases issued on or after January 1, 1994, which are subject to income withholding.
27
State case registries must contain information on non-CSE cases established or modified after
October 1, 1998.
Page 12 GAO/HEHS-99-11 SSI and Child Support
B-279807
agencies. However, as more state CSE systems become federally certified
and the state case registries and centralized collection and distribution
units become operational, we expect the ease of access to increase and
costs to decrease. It is also possible that the most efficient and
cost-effective option is for CSE to report collections to SSA.
We did not estimate the potential costs of the various approaches for SSA
and CSE agencies to exchange data on child support collections. The
decision on whether state CSE programs should report data to SSA or SSA
should access state data files should be based on an assessment of the
relative costs and efficiencies of various possible approaches.
The Congress established the CSE program and expanded it over the years
Conclusions to minimize public expenditures for low-income families and enhance
families’ self-sufficiency by helping to obtain child support income for
them. Even though SSI is an important source of cash support for many
children, single-parent families applying for or receiving SSI are not
required to cooperate with CSE. Yet, we found that many SSI children who
could benefit from CSE services are not receiving them. If more SSI children
received CSE services and ultimately received child support, SSI benefits
would be reduced, and families receiving support would be less dependent
on public assistance and closer to achieving self-sufficiency. The Congress
could ensure that families receiving SSI receive CSE program services by
amending the Social Security Act to require cooperation with CSE as a
condition of eligibility for SSI benefits. This would be in keeping with the
principle that parents, not the federal government, have primary
responsibility for supporting their children and should seek child support,
if appropriate, when applying for or receiving federal public assistance.
In addition, many single parents of SSI children who are already receiving
child support through the CSE program are not reporting the child support
to SSA, resulting in millions of dollars of SSI overpayments. SSA could
prevent or detect these overpayments by identifying child support
collected by CSE for SSI recipients. Several computerized sources of such
data are available to facilitate such an effort.
We recommend that the Congress amend the Social Security Act to require
Recommendation to that all single parents applying for or receiving SSI benefits on behalf of
the Congress children under age 18 be required to cooperate with CSE services, unless
Page 13 GAO/HEHS-99-11 SSI and Child Support
B-279807
they have good cause not to do so. The Congress also will need to consider
how best to enforce such a requirement.
We recommend that the Commissioner of Social Security and the
Recommendation to Secretary of HHS take steps to implement a cost-effective method for
the Commissioner of ensuring that data on CSE collections for children receiving SSI are made
Social Security and available to SSA and used in making eligibility determinations. This may
include seeking legislative changes to allow SSA access to states’ data on
the Secretary of HHS child support collections.
In commenting on a draft of this report, SSA agreed with our
Agency Comments recommendation that parents applying for and receiving SSI for children
and Our Response under age 18 be required to cooperate with CSE agencies. SSA said it is
considering various options for effecting such changes through legislation.
SSA also agreed with our recommendation that SSA and CSE explore ways to
implement a cost-effective method for ensuring that data on CSE
collections for children receiving SSI are made available to SSA and used in
making eligibility determinations. SSA commented that it had already
begun discussions with HHS’ Office of Child Support Enforcement about
alternative ways to obtain child support payment data to improve the SSI
eligibility determination process. It also noted that legislation may be
needed to require all states to report CSE payment data to SSA. At the same
time, SSA said it continues to negotiate on-line access to state data on an
individual state basis, addressing privacy issues as needed. It also noted
that to address privacy issues more generally and thus facilitate its access
to a wide range of state data, including child support data, it has developed
a legislative proposal that would deem that SSA’s privacy standard would
meet all states’ privacy standards for sharing data. SSA’s comments appear
in appendix III.
In commenting on a draft of this report, HHS also agreed with our
recommendation that parents applying for and receiving SSI for children
generally should be required to cooperate with CSE agencies. HHS said it is
prepared to work with SSA and the Congress to address the numerous
issues related to such a change and to develop legislation that achieves
our recommendation. Regarding the recommendation about working with
SSA to ensure that CSE data are available to SSA, HHS said that discussions
are already under way with SSA about ways to provide payment data and
noted along with SSA that legislation may be needed to require all states to
report CSE payment data to SSA. In the meantime, it is supporting SSA’s
Page 14 GAO/HEHS-99-11 SSI and Child Support
B-279807
efforts to negotiate on-line access to state data on an individual state basis.
HHS also noted that the report appears to equate child support enforcement
services with the IV-D caseload, stating that some SSI children may also
receive services as part of the non-IV-D caseload. We have clarified this
point in the report. HHS’ comments appear in appendix IV.
We also provided copies of a draft of this report to the Florida, New York,
and Texas CSE agencies. Florida and Texas officials expressed concerns
about the costs to the states of providing CSE services to SSI clients. In
addition, officials from all three states raised a range of implementation
issues, including how strongly the cooperation requirement will be
enforced for parents and their children; what the specific responsibilities
would be for SSA and the child support agencies, such as for collecting
relevant information from custodial parents and determining good cause
exemptions; and the potential burden to their information systems of
sharing information at a time of great demands on their systems as a result
of welfare reform and federal requirements for updating their CSE
automated systems.
We noted in the report that states would bear some of the costs due to
additional CSE caseloads and would not share in the potential savings in SSI
benefits to children, which are federally funded. However, the federal
government also pays incentives to states for their CSE program
performance in specified ways, giving greater weight to TANF cases than
non-TANF cases in the calculation of these performance incentives, and we
have added this information to the report. In developing legislation to
implement a cooperation requirement for parents of SSI children, the
Congress could do the same for SSI cases, which could mitigate the cost
impact on states to some extent.
We also acknowledge that many implementation details will need to be
addressed by the Congress, SSA, and states’ CSE agencies and that some
changes to how states are currently operating may be needed. However,
we believe that implementing a cooperation requirement and exchanging
key program data are important goals in keeping with promoting personal
responsibility among individuals receiving government aid and managing
government programs efficiently and effectively.
We are sending copies of this report to the Commissioner of Social
Security, the Secretary of Health and Human Services, and other interested
parties.
Page 15 GAO/HEHS-99-11 SSI and Child Support
B-279807
If you have any questions about this report, please contact Mark V. Nadel,
Associate Director, on (202) 512-7215 or Gale C. Harris, Assistant Director,
on (202) 512-7235. Other major contributors were Catherine V. Pardee,
Evaluator-in-Charge, and Vanessa R. Taylor, Computer Systems Specialist.
Richard L. Hembra
Assistant Comptroller General
Page 16 GAO/HEHS-99-11 SSI and Child Support
Page 17 GAO/HEHS-99-11 SSI and Child Support
Contents
Letter 1
Appendix I 20
Identifying Children Receiving SSI in Single-Parent Families 20
Scope and Determining Extent of Receipt and Reporting of CSE Services 21
Methodology and Support Collections
Estimating Potential SSI Benefit Reductions From Increased 22
Receipt of Child Support Services and Collections
Estimating Potential Reductions in SSI Overpayments by 24
Improved Support Reporting
Appendix II 25
Receipt and Reporting
of Child Support
Services and Income
Through Three States’
CSE Programs for SSI
Children in
Single-Parent Families
Appendix III 28
Comments From the
Social Security
Administration
Appendix IV 29
Comments From the
Department of Health
and Human Services
Related GAO Products 30
Tables Table 1: Receipt of Child Support Services by Children Receiving 6
SSI in Single-Parent Families in Three States
Page 18 GAO/HEHS-99-11 SSI and Child Support
Contents
Table 2: Parental Reporting of Child Support Collections by 10
Three States’ CSE Programs for SSI Children in Single-Parent
Families
Table 3: Estimated Annual SSI Overpayments Resulting From 11
Nonreporting of Child Support Collected by Three States’ CSE
Programs
Table I.1: Calculation of Estimated Annual SSI Benefit 23
Reductions From Providing CSE Services to Additional SSI
Children
Table II.1: Receipt and Reporting of Child Support Services and 25
Income, SSI Children in Single-Parent Families in Florida, New
York, and Texas
Table II.2: Recipient and Reporting of Child Support Services and 27
Income Provided Through the Florida, New York, and Texas CSE
Programs for Children Receiving SSI in Single-Parent Families in
Other States
Abbreviations
CSE Child Support Enforcement
HHS Department of Health and Human Services
SSA Social Security Administration
SSI Supplemental Security Income
TANF Temporary Assistance for Needy Families
Page 19 GAO/HEHS-99-11 SSI and Child Support
Appendix I
Scope and Methodology
We examined the extent to which opportunities exist for reducing SSI
payments by increased receipt of services from and reporting of child
support income received through the CSE programs in three
states—Florida, New York, and Texas. We used SSA computerized records
to identify SSI children under age 18 in single-parent families nationwide.
We matched this information with data from the computerized CSE records
of Florida, New York, and Texas to determine which of these children
received CSE services and child support income and reported support
received to SSA. We then estimated potential reductions in SSI benefits that
could occur if CSE services were provided and support collected for
additional SSI children and if unreported child support was reported to SSA.
The period of review varied among the states because of the availability of
state CSE data. It covered the 12 months ending July 1998 in Florida, the 8
months ending August 1997 in New York, and the 12 months ending July
1997 in Texas. While we did not independently verify the accuracy of the
data, the SSI and the state CSE information systems are subject to periodic
quality assurance reviews, and the CSE records serve as the official state
records for purposes of administering the CSE programs. We did our work
between May 1997 and December 1998 in accordance with generally
accepted government auditing standards.
To identify children receiving SSI in single-parent families, we obtained
Identifying Children from SSA extracts of the Supplemental Security Record—SSA’s main
Receiving SSI in administrative files and payment record for the SSI program—of all SSI
Single-Parent Families recipients with birth dates on or after July 1, 1979, who were receiving
benefits in September 1997. These records also indicated living
arrangements of the recipients and whether child support income was
being reported to SSA. Using these records, we identified children receiving
SSI who were living with only one natural or adoptive parent. More
specifically, we selected cases SSA coded as a child living with only a
mother or a father, or as living with both parents if the person to whom
benefits were paid was coded as being a stepparent. Also, we selected
these cases only if the payee of the benefits was also specified by SSA as a
natural or adoptive mother or father, or a stepparent. About 1,600 SSI
children lived in families with two parents, one of whom was a stepparent.
We did not include children in foster care, who constitute less than
3 percent of SSI children under 18, or children in institutions or other living
arrangements. Also, we excluded from our study children who had
reached age 18 in September 1998.
Page 20 GAO/HEHS-99-11 SSI and Child Support
Appendix I
Scope and Methodology
To determine the extent to which children receiving SSI in single-parent
Determining Extent of families received CSE services and had support collected for them and
Receipt and Reporting reported to SSA, we obtained extracts of CSE records from the states of
of CSE Services and Florida, New York, and Texas and matched these records with the SSA
records using the children’s names, months and years of birth, and Social
Support Collections Security numbers. Since we obtained CSE records only from Florida, New
York, and Texas, we cannot generalize the results of our analysis to SSI
children nationwide.28
The state CSE records we obtained included all CSE cases active at any time
during January through August 31, 1997, in New York; August 1996
through July 31, 1997, in Texas; and July 1997 through mid-July 1998 in
Florida.29 These records indicated all child support collections made on
the cases during those time periods. In our calculations, we multiplied
New York’s CSE child support collections during the 8-month period by
1.516 to estimate a full year’s child support collections. We matched the
CSE records of New York and Texas against September 1997 SSA records of
SSI recipients under age 18 receiving benefits at that time. We matched the
Florida CSE records against July 1998 SSA records of children who had been
receiving SSI in September 1997.30
We considered as support that should have been reported for SSI benefit
determinations any support collections made by CSE for children receiving
SSI whose SSA record did not show child support income as having been
reported to SSA. We limited our work to nonreporting of child support—we
did not attempt to identify underreporting by comparing amounts of
support collected by CSE with amounts reported to SSA.
When there was more than one child on a CSE case, we calculated the
amount of support collected for the SSI child by dividing the total amount
of support collected by the number of children involved in the CSE case.
This was necessary because CSE collection amounts on the records we
28
SSI children living outside these three states—and receiving CSE services—would not have a record
in the Florida, New York, or Texas CSE program unless the children’s state of residence requested
services from these three states.
29
Some families may receive state child support services other than those provided by the CSE
agencies, including assistance with the collection and disbursement of child support payments subject
to income withholding. Such services were not within the scope of this study.
30
About 12 percent of the children under age 18 in single-parent families in Florida receiving SSI as of
September 1997 were no longer receiving benefits as of July 1998 and were not included in the
analysis. We did not identify children who began receiving SSI between September 1997 and July 1998.
Page 21 GAO/HEHS-99-11 SSI and Child Support
Appendix I
Scope and Methodology
obtained were not separately identified by child.31 In addition, it is possible
that in a case where other children in a family received TANF, support
collected for an SSI child may have been inappropriately retained by the
government along with support collected for the children receiving TANF,
or that, in a case where an SSI child formerly received TANF, support
collected may have been retained by the government as recoupment for
prior TANF payments. In these situations, the support we attributed to an
SSI child would not have been reportable to SSA because it was not received
by the family. From the computerized files we reviewed, we could not
determine precisely how much collected support was distributed to
families.
We based our estimates of the potential annual SSI benefit reductions that
Estimating Potential could occur if more SSI children received CSE services on the number of SSI
SSI Benefit children we identified as not receiving services. We identified as not
Reductions From receiving CSE services SSI children who did not have a CSE record and did
not have child support income reported on their SSA record.32
Increased Receipt of
Child Support To estimate potential annual SSI benefit reductions, we assumed that the
states’ CSE programs would collect support for only the same proportion of
Services and SSI recipients not receiving CSE services as the program was collecting for
Collections those receiving services. We further assumed that (1) the CSE system could
collect for each SSI recipient not receiving CSE services an amount of
support equal to the median amount collected for SSI recipients receiving
services and (2) each SSI recipient not receiving CSE services was receiving
the median SSI benefit received by all SSI potential child support recipients
who were not receiving CSE services.
As shown in table I.1, we calculated the total amount of potential annual
support collections by multiplying the total estimated number of cases to
be collected on by the median annual support amount collected. We
multiplied this by 66 percent to derive the total amount of annual support
collections countable as income for SSI, which in this case represented the
amount of potential annual SSI benefit reductions.33
31
The amount of child support ordered to be paid can vary for children in the same family by the ages
of the children, when the orders were issued, and other individual family circumstances.
32
There may have been SSI children who first received CSE services in the month of September 1997
through the New York CSE program or in the months of August and/or September through the Texas
program that we counted as not receiving CSE services because the CSE records we obtained did not
include those months.
33
The Social Security Act specifically provides that one-third of child support income be excluded from
determining income for eligibility of children for SSI benefits.
Page 22 GAO/HEHS-99-11 SSI and Child Support
Appendix I
Scope and Methodology
Table I.1: Calculation of Estimated Annual SSI Benefit Reductions From Providing CSE Services to Additional SSI Children
Factor and computation Florida New York Texas Total
Additional SSI children in the state to receive CSE services (CSE record not found
and no child support income reported on SSA record) 12,726 20,817 14,296 47,839
Multiplied by collection rate for other SSI children in the state for whom CSE Not
collects child support 32.4% 20.9% 39.4% applicable
Yields additional SSI recipients in the state for whom CSE will collect child support 4,128 4,355 5,636 14,119
Multiplied by median annual collections per other SSI children in the state for Not
whom CSE makes collections $487 $350 $501 applicable
Yields estimated annual support collections $2,010,247 $1,524,931 $2,825,468 $6,360,646
Multiplied by percentage of child support counted as income for SSI Not
66% 66% 66% applicable
Yields estimated SSI benefit reductionsa $1,326,763 $1,006,454 $1,864,809 $4,198,026
Note: Intermediate calculations appear inexact because intermediary numbers are shown in
rounded numbers, whereas actual calculations use nonrounded numbers.
a
Had 66 percent of the median child support collection been greater than the median SSI benefit,
estimated benefit reductions would be limited to the amount of SSI benefits. Median SSI benefits
received by SSI children not receiving CSE services were $5,928 in Florida, $5,870 in New York,
and $5,808 in Texas.
We did not directly assess the potential for child support collections
among the SSI children not currently receiving services, and thus our
estimate of SSI reductions may be understated or overstated. Some
research indicates that a significant portion of noncustodial parents may
have limited ability to pay child support, and it is possible that many of
those custodial parents that have not pursued child support through the
CSE program are associated with the noncustodial parents least able to
pay. If that were so, our estimate would overstate the potential for child
support collections among those not currently receiving child support
services. However, we did not have information on the socioeconomic
characteristics of the SSI children and their noncustodial parents needed to
assess their ability to pay. In addition, the potential SSI benefit reductions
we estimated may be overstated if some of the SSI recipients for whom we
did not find a CSE record were already receiving child support income but
not reporting it to SSA or had earlier received CSE services but had their
cases closed, for example, because the identity of the noncustodial parent
was not known, the noncustodial parent could not be located,34 or the
34
Federal regulations allow case closure after repeated attempts to locate noncustodial parents using
multiple sources over 3 years.
Page 23 GAO/HEHS-99-11 SSI and Child Support
Appendix I
Scope and Methodology
noncustodial parent died.35 Also, some SSI children may have received CSE
services, but we did not find a CSE record because the Social Security
number and/or name and month and year of birth of the SSI child was in
error on either the SSA or CSE record.
We estimated the annual reduction in SSI overpayments that would occur if
Estimating Potential all unreported child support collected for SSI recipients by the Florida,
Reductions in SSI New York, and Texas CSE programs were reported to SSA for SSI benefit
Overpayments by determinations. The estimated overpayment reduction that could occur for
SSI children if unreported CSE collected support were reported to SSA is
Improved Support equivalent, for each child, to 66 percent of the annual amount of child
Reporting support collected by CSE or the annual SSI benefit, whichever is less. We
performed this comparison for each SSI child recipient whose CSE record
indicated that support collections were made but their companion SSI
record did not indicate child support income had been reported. The
summation of these amounts for all cases represents the total estimated
overpayment reductions.
35
However, our work does consider such cases to some extent. The CSE cases against which we
matched did include some closed cases—those either closed or identified for closure during the
periods of our review.
Page 24 GAO/HEHS-99-11 SSI and Child Support
Appendix II
Receipt and Reporting of Child Support
Services and Income Through Three States’
CSE Programs for SSI Children in
Single-Parent Families
Table II.1: Receipt and Reporting of Child Support Services and Income, SSI Children in Single-Parent Families in Florida,
New York, and Texas
Residing in Florida Residing in New York Residing in Texas Total, three states
Number Percent Number Percent Number Percent Number Percent
Not receiving CSE servicesra
No child support income
reported to SSAb 12,726 42 20,817 50 14,296 58 47,839 49
Child support income
reported to SSA 1,498 5 1,384 3 1,618 7 4,500 5
Subtotal, not receiving
services 14,224 47 22,201 53 15,914 65 52,339 54
c
Receiving CSE services
Child support being collectedd
No child support income
reported to SSA 3,707e 12 2,741f 7 2,050g 8 8,498 9
Child support income
reported to SSA 1,559 5 1,406 3 1,378 6 4,343 4
Subtotal, support being
collected 5,266 17 4,147 10 3,428 14 12,841 13
Child support not being collected
No child support income
reported to SSA 10,388 34 15,197 36 5,065 21 30,650 32
Child support income
reported to SSA 581 2 481 1 203 1 1,265 1
Subtotal, child support not
being collected 10,966 36 15,678 37 5,268 21 31,915 33
Subtotal, receiving services 16,235 53 19,825 47 8,696 35 44,756 46
h
Total 30,459 100 42,026 100 24,610 100 97,095 100
(Table notes on next page)
Page 25 GAO/HEHS-99-11 SSI and Child Support
Appendix II
Receipt and Reporting of Child Support
Services and Income Through Three States’
CSE Programs for SSI Children in
Single-Parent Families
Note: Data are for children under age 18 as of July 1997 and who had not reached age 18 by
September 1998, residing with only one natural or adoptive parent, and receiving SSI in Florida as
of July 1998 and in New York or Texas as of September 1997.
a
For whom we did not find a state CSE record for the 12 months ending mid-July 1998 in Florida;
the 8 months ending August 31, 1997, in New York; and the 12 months ending July 31, 1997, in
Texas.
b
SSA records did not indicate child support had been reported.
c
Children receiving SSI in single-parent families for whom we found CSE computerized records.
d
CSE records indicated child support had been collected for the SSI child.
e
We also found 366 SSI recipients from other states for whom the Florida CSE program collected
child support, but this income was not reported to SSA.
f
We also found 1,275 SSI recipients from other states for whom the New York CSE program
collected child support, but this income was not reported to SSA.
g
We also found 293 SSI recipients from other states for whom the Texas CSE program collected
child support, but this income was not reported to SSA.
h
Numbers do not add because of rounding.
Page 26 GAO/HEHS-99-11 SSI and Child Support
Appendix II
Receipt and Reporting of Child Support
Services and Income Through Three States’
CSE Programs for SSI Children in
Single-Parent Families
Table II.2: Recipient and Reporting of Child Support Services and Income Provided Through the Florida, New York, and
Texas CSE Programs for Children Receiving SSI in Single-Parent Families in Other States
Served by Florida CSE Served by New York Served by Texas CSE
program CSE program program Total, three states
Number Percent Number Percent Number Percent Number Percent
a
Child support being collected
No child support income
reported to SSAb 366 17 1,275 18 293 17 1,934 17
Child support income
reported to SSA 196 9 298 4 158 9 652 6
Subtotal, support being
collected 562 26 1,573 22 451 26 2,586 23
Child support not being collected
No child support income
reported to SSA 1,464 69 5,129 70 1,204 70 7,797 70
Child support income
reported to SSA 106 5 583 8 56 3 745 7
Subtotal, support not being
collected 1,570 74 5,712 78 1,260 74 8,542 77
Total 2,132 100 7,285 100 1,711 100 11,128 100
Note: Data are for children under age 18 as of July 1997 and who had not reached 18 by
September 1998, residing with only one natural or adoptive parent, and receiving SSI in July 1998
for children served by the Florida CSE program and in September 1997 for children served by
New York and Texas CSE programs.
a
CSE records indicated child support had been collected for the SSI recipient.
b
SSA records did not indicate child support had been reported.
Page 27 GAO/HEHS-99-11 SSI and Child Support
Appendix III
Comments From the Social Security
Administration
Page 28 GAO/HEHS-99-11 SSI and Child Support
Appendix IV
Comments From the Department of Health
and Human Services
Page 29 GAO/HEHS-99-11 SSI and Child Support
Related GAO Products
Supplemental Security Income: Action Needed on Long-Standing Problems
Affecting Program Integrity (GAO/HEHS-98-158, Sept. 14, 1998).
Welfare Reform: Child Support an Uncertain Income Supplement for
Families Leaving Welfare (GAO/HEHS-98-168, Aug. 3, 1998).
Child Support Enforcement: Certification Process for State Information
Systems (GAO/AIMD-98-134, June 15, 1998).
Supplemental Security Income: Opportunities Exist for Improving
Payment Accuracy (GAO/HEHS-98-75, Mar. 27, 1998).
Child Support Enforcement: Strong Leadership Required to Maximize
Benefits of Automated Systems (GAO/AIMD-97-72, June 30, 1997).
Supplemental Security Income: Timely Data Could Prevent Millions in
Overpayments to Nursing Home Residents (GAO/HEHS-97-62, June 3, 1997).
Supplemental Security Income: Administrative and Program Savings
Possible by Directly Accessing State Data (GAO/HEHS-96-163, Aug, 29, 1996).
Supplemental Security Income: SSA Efforts Fall Short in Correcting
Erroneous Payments to Prisoners (GAO/HEHS-96-152, Aug. 30, 1996).
(116000) Page 30 GAO/HEHS-99-11 SSI and Child Support
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Address Correction Requested
Supplemental Security Income: Increased Receipt and Reporting of Child Support Could Reduce Payments
Published by the Government Accountability Office on 1999-01-12.
Below is a raw (and likely hideous) rendition of the original report. (PDF)