oversight

Interstate Child Support: Better Information Needed on Absent Parents for Case Pursuit

Published by the Government Accountability Office on 1990-05-24.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                United   States   General   Accounting   Office
,/‘(                            Report to Congressional Requesters
 u     A0

May 1990
                                 INTERSTATE
                                 CHILD SUPPORT
                                 Better Information
                                 Needed on Absent
                                 Parents for Case
                                 Pursuit




                -    -.,


                    RESTRICTED --Not       to be released outside the
                    General   Accounting Of&e unless specifically
                    approved by the Office of Congressional
                    Relations.




 GAO/HRD-9041
Human Resources   Division

B-239408

May 24,199O

The Honorable Thomas J. Downey
Acting Chairman, Subcommittee on
  Human Resources
Committee on Ways and Means
House of Representatives

The Honorable Hank Brown
Subcommittee on Human Resources
Committee on Ways and Means
House of Representatives

This report responds to your request for information on the extent of problems associated
with insufficient absent parent information for interstate child support enforcement, and
ways to improve the gathering and use of such information. The report explores the
processes child support agencies use to obtain and verify information critical for pursuing
interstate cases. On January 27, 1989, we sent you our report Interstate Child Support: Case
Data Limitations, Enforcement Problems, Views on Improvements Needed (GAO/HRD-89-25).

As arranged with your offices, unless you publicly announce its contents earlier, we plan no
further distribution of this report until 30 days from the date of this letter. At that time, we
will send copies to other interested congressional committees, the Secretary of Health and
Human Services, and the Director of the Office of Child Support Enforcement. We will also
make copies available to others on request.

This work was done under the direction of Franklin Frazier, who can be reached on
(202) 275-1793. Other major contributors to this report are listed in appendix VI.




Lawrence H. Thompson
Assistant Comptroller General
Executive Summary


                   Missing and inaccurate address and employment information on out-of-
Purpose            state absent parents frustrates child support agencies’ efforts to pursue
                   interstate cases. Without good information, interstate collection efforts
                   languish and welfare benefits are paid to families who otherwise might
                   not be entitled to them. The Subcommittee on Human Resources, House
                   Committee on Ways and Means, asked GAO to identify ways to improve
                   the manner of obtaining and using such information.


                   The Congress created the Child Support Enforcement Program to
Background         strengthen state and local efforts to locate parents, establish paternity,
                   obtain support orders, and collect support. The Office of Child Support
                   Enforcement (OCSE) administers the program at the federal level and
                   operates the Federal Parent Locator Service, which provides child
                   support agencies with absent parent information held by such federal
                   agencies as the Internal Revenue Service. State child support agencies
                   administer the program at state and local levels and operate (1) state
                   parent locator services, which obtain information on absent parents
                   residing in their state from such sources as state motor-vehicle records;
                   and (2) central registries, which receive, distribute, and respond to
                   inquiries on cases referred by other states for enforcement action.

                   OCSE  has estimated that up to 30 percent of all child support cases
                   involve a custodial parent and child living in a different state than the
                   absent parent. The child support agency in the state where the child
                   lives (initiating agency) needs information on the absent parent to know
                   where and how to pursue cases. Regulations require agencies to use all
                   appropriate state and local sources of absent parent information within
                   60 days; effective October 1990, agencies will have 75 days to access all
                   appropriate sources, including the federal locator service. The initiating
                   agency often refers cases to the state where the absent parent lives or
                   works (responding state) and relies on that state to establish or enforce
                   support orders. In such cases, initiating agencies must provide “suffi-
                   cient, accurate” information upon which to act. (See pp. S-12.)


Results in Brief   Initiating agencies often lack complete and accurate address and
                   employment information about absent parents that is needed to pursue
                   interstate cases effectively. As a result, they do not pursue some inter-
                   state cases and use lengthy, cumbersome procedures to refer other cases
                   for enforcement to the state where the absent parent lives. Further,
                   when initiating agencies refer cases with missing and inaccurate infor-
                   mation to other states, such states (1) may waste resources trying to


                   Page 2                           GAO/HRD90-41   Need for Absent Parent Information
                          Executive   Summary




                          locate absent parents who may not live there, (2) may encounter delays,
                          and (3) are unlikely to collect support.

                          Initiating agencies often do not use responding state parent locator ser-
                          vices to obtain needed absent parent information because the services
                          respond slowly. Also, some initiating agencies cannot access other data
                          sources (e.g., national motor-vehicle records) that have useful address
                          and employment data. Moreover, initiating agencies sometimes do not
                          verify critical information obtained from custodial parents or other
                          sources before referring cases to other states for action and send some
                          cases to the wrong state. Interstate case enforcement should improve
                          and responding states should save resources if initiating agencies obtain
                          and verify critical information before referring cases to other states.


Principal Findings

Missing Information       Initiating agencies often do not pursue interstate cases because informa-
Hinders Case Pursuit by   tion about the absent parent is missing. Demonstration projects in Mary-
                          land and Connecticut showed that initiating agencies did not pursue one-
Initiating Agencies       fifth of the interstate cases in Maryland and one-third in Connecticut
                          because addresses were missing. Also, each initiating caseworker GAO
                          surveyed had not pursued some interstate cases because the absent par-
                          ent’s address and employment data were missing.

                          When address and employment data are missing, initiating agencies’
                          options for pursuing interstate cases are limited. Initiating agencies
                          often use lengthy, cumbersome legal procedures to refer some cases for
                          enforcement to the state where the custodial parent or other sources
                          indicate the absent parent lives. That state assumes responsibility for
                          the case and uses its own legal procedures to establish and enforce a
                          new support order. A Michigan demonstration project showed that initi-
                          ating agencies can reduce case processing time and increase collections
                          by using enforcement options that avoid or minimize involving other
                          states. With better out-of-state absent parent information, initiating
                          caseworkers GAO surveyed would make greater use of such options as
                          requesting employers who also do business in their states to withhold
                          out-of-state absent parents’ wages. (See p. 13.)




                          Page 3                          GAO/HRD9O-41   Need for Absent Parent Information
                           Executive   Summary




Missing and Inaccurate     Initiating agencies often provide absent parent information with cases
Information Hinders        referred to other states that is not sufficient and accurate. Caseworkers
                           in 10 states told GAO that up to 67 percent of the cases they received
Enforcement by             lacked the absent parent’s correct address and up to 78 percent lacked
Responding States          correct employment information. GAO'S review of 50 interstate cases
                           received by Alameda County, California, also showed that such cases
                           often had missing and inaccurate information.

                           Some cases are sent to the wrong place for action. For example, 10 per-
                           cent of the cases referred by other states to one state’s central registry
                           involved parents who did not live in that state. In such instances,
                           responding states waste time and effort trying to locate absent parents
                           who live elsewhere. Further, caseworkers GAO surveyed experienced
                           delays averaging 6 months when processing cases referred by other
                           states with missing or inaccurate information. Also, GAO'S Alameda
                           County case review showed delays of about 4 months in cases referred
                           by other states with inadequate information. Moreover, Connecticut’s
                           demonstration project and GAO’S case review show the prospects for col-
                           lections decrease when initiating agencies forward cases with missing or
                           inaccurate information. (See pp. 14-16.)


Opportunities to Improve   Initiating caseworkers GAO surveyed often do not use responding state
Information Through        parent locator services to obtain absent parent information because the
                           services respond too slowly. Most state parent locator services can
Better Use of Available    access both motor-vehicle and employment records within 1 day. But
Sources                    one-half take 1 month or longer to respond to requests from other states,
                           some of which take longer than the 60 days that initiating agencies now
                           have to obtain absent parent information; estimates range up to 140
                           days. OCSE recognizes the need for quick responses, but has not estab-
                           lished time frames for responding to other states’ information requests
                           on cases that have not been referred for enforcement action.

                           OCSE  guidance is unclear on the use of states’ central registries for infor-
                           mation requests. Some state officials told GAO that OCSE requires them to
                           process information requests from other states through their central
                           registries, which adds to response time. In November 1989, OCSE officials
                           told GAO that initiating agencies may send information requests directly
                           to other states’ parent locator services. Although XSE had not issued
                           specific guidance on the matter at the time of GAO'S work, it indicated
                           plans to do so in its comments on this report.




                           Page 4                            GAO ~‘HRlMO-41 Need for Absent Parent Information
                             Executive   Summary




                             Initiating agencies also make varied use of such information sources as
                             nationwide motor-vehicle and employment records, the Federal Parent
                             Locator Service, and commercial sources. Through OCSE and other fed-
                             eral initiatives, information about out-of-state absent parents may be
                             more accessible in the future. (See p. 16-20.)


Verification Needed to       Federal regulations allow initiating agencies discretion in determining
Ensure Accurate              how to check the accuracy of absent parent information before referring
                             cases to other states. While some agencies routinely verify absent parent
Information                  addresses with the post office before referring cases, some do not. Child
                             support officials GAO surveyed said that initiating agencies should verify
                             such information before referring cases, and that doing so should help
                             improve interstate case enforcement. (See p. 20.)


                                  recommends that the Secretary of Health and Human Services
Recommendations              GAO
                             direct OCSE to:
                                                                                                            (HHS)



                         l Require that initiating child support agencies exhaust all reasonable
                           efforts, including, as appropriate, checking other states’ parent locator
                           services, to obtain address and employment information on out-of-state
                           absent parents for use in deciding how best to pursue interstate cases.
                         0 Require initiating agencies to verify out-of-state parents’ addresses with
                           the post office before sending cases with questionable information to
                           other states for action.
                         l Require, by modifying existing performance standards, that responding
                           state parent locator services quickly (preferably within 1 week) provide
                           information from motor-vehicle, employment, and other readily accessi-
                           ble sources when responding to other states’ information requests on
                           cases that have not been referred for action.
                         l Clarify that initiating child support agencies may request absent parent
                           information directly from other states’ parent locator services without
                           sending such requests through the responding states’ central registries.


                                  agreed with GAO’S recommendation to make clear that initiating
Agency Comments              HHS
                             agencies can make direct information requests of other states’ parent
                             locator services. HHS believes, however, that existing standards and new
                             rules effective October 1990. should satisfy GAO's other recommenda-
                             tions. GAO believes that additional actions are needed to bring about the
                             improvements sought by those recommendations. HHS’S technical com-
                             ments were incorporated in this report as appropriate.


                             Page 5                           G.40 ‘HRD-90-41 Need for .4bsent Parent Information
Contents


Executive Summary                                                                                              2

Chapter 1                                                                                                   8
Introduction              How Agencies Pursue Interstate Cases                                              8
                                                                                                           11
                          Program Administration
                          Objectives, Scope, and Methodology                                               11

Chapter 2                                                                                                  13
Better Absent Parent      Missing Information Hinders Case Pursuit by Initiating                           13
                               Agencies
Information Needed        Responding States Cannot Efficiently Pursue Interstate                               15
for Pursuing Interstate        Cases When Critical Information Is Missing
                          Opportunities to Improve Information Through Better                                  16
Cases                          Use of Available Sources
                          Verification Practices Vary                                                      20
                          Conclusions and Recommendations                                                  21
                          Agency Comments                                                                  22

Appendixes                Appendix I: Sources Routinely Accessed by SPLSs                                  24
                          Appendix II: Major Options Available to Initiating                               25
                              Agencies for Interstate Child Support Enforcement
                          Appendix III: Scope and Methodology Details                                      26
                          Appendix IV: SPIS Estimates of Average Response Time                             29
                              to Interstate Requests
                          Appendix V: Comments From the Department of Health                               30
                              and Human Services
                          Appendix VI: Major Contributors to This Report                                   35

Tables                    Table 2.1: Success of Collections in Alameda County                                  16
                              When Certain Types of Information Were Provided
                          Table 2.2: SPLS Access Time for Motor-Vehicle and                                    17
                              Employment Databases
                          Table III. 1: Case Processors Surveyed                                               27

Figure                    Figure 1.1: How Initiating Agencies Pursue Interstate                                 9
                               Child Support Cases With Existing Support Orders




                          Page 6                          GAO/HRD-90-41   Need for Absent Parent Information
Contents




Abbreviations

GAO        General Accounting Office
HHS        Department of Health and Human Services
OCSE       Office of Child Support Enforcement
SPIS       state parent locator service


Page 7                         GAO/HRD-90-41   Need for Absent Parent Information
Chapter 1

Introduction


                      Inadequate information on out-of-state absent parents often hinders
                      state and local agencies’ efforts to provide child support enforcement
                      services, including establishing paternity, obtaining support orders, and
                      collecting support payments. Lack of information on the absent parent’s
                      whereabouts and employment can result in failure to pursue cases,
                      processing delays, and reduced collections.

                      Child support agencies often have more difficulty obtaining information
                      on out-of-state absent parents than on absent parents living in the state
                      because caseworkers generally lack direct access to out-of-state informa-
                      tion sources. The Office of Child Support Enforcement (OCSE), which
                      administers the federal Child Support Enforcement Program, has esti-
                      mated that interstate cases represent up to 30 percent of all child sup-
                      port enforcement cases. This report explores the processes child support
                      agencies use to obtain and verify information critical for pursuing inter-
                      state cases.


                      The child support agency in the state where the child and custodial par-
How Agencies Pursue   ent live (initiating agency) needs information on the out-of-state absent
Interstate Cases      parent in order to decide where and how to pursue interstate cases.’ The
                      initiating agency opens an interstate case based on information provided
                      by the custodial parent when the parent applies for Aid to Families with
                      Dependent Children or seeks child support enforcement services, as
                      shown in figure l.l.? If necessary, the initiating agency seeks missing
                      information on the out-of-state absent parent from other sources. With-
                      out sufficient information concerning the absent parent, the initiating
                      agency may not be able to pursue the case. If sufficient information is
                      obtained, the initiating agency may pursue the case using various
                      enforcement options depending on case circumstances. (See p. 10.)




                      ‘To simplify presentation. we use custodral parent when referring to the person with physical cus-
                      tody of the child. The person could be a relative or an unrelated person,

                      ‘The Aid to Families with Dependent Children program, authonzed by title IV of the Social Security
                      Act, provides cash and other assistance to children m families that meet prescribed income, resource.
                      and other eligibility requirements. As a conditron of eligibility, the custodial parent must assign child
                      support rights to the state and. with few exceptions. must cooperate in providing information con-
                      cerning the absent parent.




                      Page 8                                        GAO ‘HRD-90-41 Need for Absent Parent Information
                                             Chapter 1
                                             Introduction




Figure 1.l : How Initiating Agencies Pursue interstate Child Support Cases With Existing Support Orders
                                                                                    .
                                                            Openscasebasedon
                                                             information provided
                                                              by custodial parent




                                                               Seeks additional
                                                               information from
                                                               other sources, if
                                                                   necessary




                                                             Selects enforcement
                                                            strategy based on the
                                                             information obtained




Obtaining Critical Absent                    Certain information about absent parents is critical to effective inter-
Parent Information                           state child support enforcement:

                                         l   An accurate address. This is needed to determine where to pursue cases
                                             and to notify the absent parent before taking enforcement actions.
                                         l   Income and employment information. This is important for determining
                                             the absent parent’s ability to pay support and identifying the most
                                             effective enforcement option.




                                             Page 9                                     GAO.‘HR.D9O-41   Need for Absent Parent Information
                       Chapter 1
                       Introduction




                       In addition, the social security number and date of birth are useful for
                       confirming the absent parent’s identity and accessing certain databases
                       containing address and employment information.

                       When the custodial parent does not provide sufficient information about
                       an out-of-state absent parent, the initiating agency may seek informa-
                       tion from other sources. For example, the agency may request informa-
                       tion from the state parent locator service (SPLS) in the state where the
                       absent parent is believed to live or work (responding state). Each state
                       operates an SPIS, as required by federal law, to help locate information
                       on absent parents by using such state and local records as motor vehicle,
                       employment, and public assistance. (See app. I for sources routinely
                       accessed by SPILLS.)

                       Initiating child support agencies may also seek information from the
                       Federal Parent Locator Service, operated by OCSE. This service accesses
                       federal records maintained by the Internal Revenue Service, Social
                       Security Administration, Department of Defense, Selective Service Sys-
                       tem, National Personnel Reccrds Center, and Department of Veterans
                       Affairs. Access to these records and other nationwide data is particu-
                       larly helpful when the initiating agency does not know in which state
                       the absent parent lives or works.


Initiating Agencies’   An initiating child support agency may have a number of alternative
Enforcement Options    interstate enforcement options depending on the circumstances of the
                       case. Regardless of the circumstances, the agency may refer the case to
                       the state where the absent parent lives for appropriate action, including
                       establishing paternity and support orders, if needed, and enforcement.
                       Under some circumstances the initiating agency can use long-arm stat-
                       utes to establish paternity and support orders.:’ If an out-of state absent
                       parent with a support order works for the military, federal government,
                       or an employer doing business in both the initiating and responding
                       states, the initiating agency can request the employer to withhold wages
                       without involving the other state (direct withholding). Alternatively,
                       the initiating agency can request the child support agency in the state
                       where the absent parent works to have the employer there withhold
                       child support payments (interstate income withholding). (See app. II for
                       details on enforcement options.)

                       %ong-arm statutes are state laws that give the state where the child and custodial parent live author-
                       ity to take action against an out-of-state absent parent under some circumstances, such as when the
                       child was conceived in the initiating state.



                       Page 10                                      GAO/HRD90-41      Need for Absent Parent Information
                         Chapter 1
                         Introduction




                         The Congress created the federal Child Support Enforcement Program to
Program                  strengthen state and local efforts to locate absent parents, establish
Administration           paternity, obtain support orders, and collect support payments. State
                         child support agencies are responsible for administering the program at
                         the state and local levels.4 At the federal level, OCSE, in the Department
                         of Health and Human Services (HHS), is responsible for the program and
                         funds 66 percent of states’ administrative costs.

                         OCSE regulations   provide that responding states must cooperate in locat-
                         ing absent parents and enforcing child support. Further, OCSE issued reg-
                         ulations in February 1988 to improve the processing of cases referred
                         from one state to another for enforcement. The regulations require that,
                         when referring (using an interstate transmittal form) cases for action,
                         the initiating state provide the responding state with “sufficient, accu-
                         rate” information upon which to act. To ensure accountability for inter-
                         state cases, the regulations require that each state operate a central
                         registry as a focal point to receive, distribute, and respond to inquiries
                         on all interstate cases referred from other states. Within 10 days, cen-
                         tral registries must forward cases to the responding SPIS or other appro-
                         priate agency for processing.

                         In August 1989, OCSE issued regulations, effective October 1990, setting
                         forth performance standards, as required by the Family Support Act of
                         1988, to improve the timeliness and effectiveness of child support case
                         processing. These standards provide that, within 75 days of determining
                         that locator services are needed, states access all appropriate informa-
                         tion sources, including the Federal Parent Locator Service, to obtain
                         information to pursue child support cases and ensure the information is
                         sufficient to take the next appropriate action. Currently, states are
                         required to use all appropriate state and local sources within 60 days of
                         receiving a case. OCSE lengthened the time to allow for accessing the fed-
                         eral locator service, to ensure the sufficiency of information, and to
                         allow time for states that lack automated access to the sources.


                         On July 19, 1988, the Acting Chairman and then Ranking Minority Mem-
Objectives, Scope, and   ber, Subcommittee on Human Resources, House Committee on Ways and
Methodology              Means, asked us to review the extent of problems associated with insuf-
                         ficient information for interstate child support enforcement and identify


                         “Throughout this report, the word “state” refers to the 50 states. the District of Columbia, Puerto
                         Rico, Guam. and the Virgin Islands.



                         Page 11                                      GAO/HRI%9O-41      Need for Absent Parent Information
Chapter 1
Introduction




ways to improve the gathering and use of such information. In a previ-
ous review, we reported that absent parent data were a barrier to suc-
cessful child support enforcement.”

In doing our work we (1) examined relevant interstate demonstration
projects and other child support studies; (2) discussed the issues with
OCSE officials; and (3) interviewed officials and reviewed cases at the
child support agency in Alameda County, California, and interviewed
officials in the San Diego County, California, agency. We selected these
agencies because they were in a state that has a large number of inter-
state cases.

To further corroborate our earlier work and the results of the demon-
strations and other available studies, we sought the views of state and
local child support enforcement practitioners. We conducted a telephone
survey of SPISS in the 50 states, the District of Columbia, Puerto Rico,
Guam, and the Virgin Islands to obtain views on the extent and timeli-
ness of their services. Also, we conducted a telephone survey of central
registry officials and state and local child support agency caseworkers
in 10 states to determine their practices and views on initiating and
responding to interstate cases. Further, we attended ocX+sponsored
conferences and discussed relevant issues with national child support
organization officials. Although we did not independently verify these
practitioners’ views, we found them internally consistent and reflective
of the results of available studies. For more details on our audit scope
and methodology, see appendix III.

Our work was conducted between December 1987 and March 1989 in
accordance with generally accepted government auditing standards.




‘The results of this review were summarized m the report. Interstate Child Support: Case Data Limi-
tations. Enforcement Problems. Views on Improvements Needed (GAO/HRD89-25. Jan. 27, 1989).



Page 12                                     GAO ~HRB90-41 Need for Absent Parent Information
Chapter 2

Better Absent Parent Information Needed for
Pursuing Interstate Cases

                         Initiating child support agencies often do not obtain critical information
                         on out-of-state absent parents that is needed to efficiently and effec-
                         tively pursue interstate child support cases. As a result, initiating agen-
                         cies do not pursue some interstate cases and refer some cases to other
                         states for pursuit using lengthy, cumbersome procedures. Further, agen-
                         cies refer some cases with missing and inaccurate information to other
                         states for enforcement and send cases to the wrong state. When
                         responding states receive such cases, they waste resources trying to
                         locate individuals or their employers, encounter delays in case process-
                         ing, and are unlikely to collect support payments. Initiating agencies
                         often do not use responding SPISS or other sources to obtain needed out-
                         of-state absent parent information because such sources are slow in pro-
                         viding requested information. Also, some initiating agencies cannot
                         access some sources that contain useful absent parent information. Fur-
                         ther, they sometimes do not verify critical absent parent information
                         obtained before referring cases to other states for enforcement.


                         Initiating child support agencies often do not pursue cases involving out-
Missing Information      of-state absent parents because addresses and other pertinent informa-
Hinders Case Pursuit     tion are missing. A 1986 Maryland interstate demonstration project esti-
by Initiating Agencies   mated that the state did not pursue 20 percent of the interstate cases
                         originating in Maryland because an address was lacking.’ Similarly, our
                         analysis of data from a 1987 Connecticut demonstration project found
                         the state did not pursue 37 percent of the interstate cases originating in
                         Connecticut due to lack of addresses.’ Also, a review by the Department
                         of Health and Human Services’ (HHS’S) Inspector General of 649 cases
                         where no support order had been established for 2 years disclosed that
                         child support agencies did not pursue 57 percent of the cases because
                         the absent parent could not be located. The study cited difficulty in
                         obtaining addresses from other states as a contributing problem. Also,
                         the initiating agency caseworkers we surveyed all said they had not pur-
                         sued some cases due to lack of sufficient and accurate information.”




                         ‘bstd   on a sample of 226 cases drawn from interstate cases mitiated in calendar years 1982 to 198.5.

                         ‘Based on a sample of 294 cases drawn from interstate cases mitiated in calendar years 1983 to 1986.

                          ‘OCSE‘s new regulations. effective October 1990, will require agencies to make repeated attempts to
                         locate absent parents when previous attempts have failed. At a mimmum, the agencies must check
                         the Federal Parent Locator Service annuall)



                         Page 13                                      GAO/HTUMO41      Need for Absent Parent Information
                           Chapter 2
                           Better Absent Parent Information     Needed for
                           Pnrsning Interstate cases




Enforcement Options        When initiating agencies lack address and employment data for out-of-
Limited When Information   state absent parents, they often use the lengthy, cumbersome civil pro-
                           cedures outlined in model legislation embodied in the Uniform Recipro-
Is Missing                 cal Enforcement of Support Act to pursue the cases.” To use these
                           procedures, initiating agencies must identify the state where the absent
                           parent lives. Responsibility for the case is transferred to that state,
                           which then uses its own legal processes to establish and enforce a new
                           support order. Demonstration projects in Maryland, Connecticut, and
                           Michigan and our review of 50 cases sent by other states to Alameda
                           County, California, indicate that cases pursued using these procedures
                           usually took about a year to process and that most do not result in
                           collections.

                           When initiating agencies obtain address and employment data on out-of-
                           state absent parents, they often can use more effective interstate
                           enforcement options, such as direct and interstate income withholding.
                           (See p. 10 and app. II.) The 1988 Michigan demonstration project indi-
                           cated that these enforcement options eliminate or reduce the need to
                           involve another state, thereby eliminating lengthy delays and increasing
                           collections.

                           Initiating caseworkers we surveyed would use direct and interstate
                           income withholding more frequently if out-of-state absent parent infor-
                           mation was more readily available. The supervisor of the Interstate Unit
                           in Allegheny County, Pennsylvania, told us that using direct withhold-
                           ing may result in payment in as little as 30 days. With better access to
                           employment information, initiating caseworkers estimated they would
                           be able to use either direct or interstate income withholding in 50 to 90
                           percent of their interstate cases having support orders.”




                           ‘All states have enacted some form of this   model   legislation   for enforcing interstate child support
                           (See app. II.)

                           ‘According to a 1987 Connecticut study and our Alameda case file review, about one-half of inter-
                           state cases have exrsting support orders. For I,ertain cases without orders. initiating agencies can
                           establish support orders without involving responding states. (See app. II for details on long-arm
                           statutes.) The initiating agency must obtain an accurate address to notify the absent parent, as
                           required by law, before taking any direct actlons to establish or enforce support obligations.



                           Page 14                                        GAO/HRD-90-41         Need for Absent Parent Information
                            Chapter 2
                            Better Absent Parent Information   Needed for
                            Pursuing lnt.erstate cases




                            Responding states often cannot efficiently or effectively pursue inter-
Responding States           state cases because complete and accurate address and employment
Cannot Efficiently          information about the absent parent is lacking. Caseworkers we sur-
Pursue Interc+o+fi
               ababc
                            veyed estimated that 25 to 67 percent of the cases referred to them by
                            other states lacked a correct address, 40 to 78 percent lacked accurate
Cases When Critical         employment information, and 50 to 96 percent lacked wage or income
Information Is Missing      information. Further, of the 50 Alameda County cases we reviewed, 27
                            lacked correct addresses and 29 lacked correct employer information.


Resources Wasted            When the initiating agency lacks accurate out-of-state absent parent
                            information, it sometimes sends cases to the wrong state or jurisdiction
                            for enforcement. The responding state then wastes time and effort
                            establishing case records and trying to locate absent parents who do not
                            live or work there. Idaho central registry officials told us that in 10 per-
                            cent of the cases referred from other states, the absent parents did not
                            live in Idaho, and that many of the absent parents were subsequently
                            found to be residing in the state that initiated the request.


Case Processing Delayed     Case processing is delayed when agencies refer cases to other states
                            with missing and inaccurate information. If unable to locate the absent
                            parent, responding caseworkers contact the initiating child support
                            agency to request additional information. Responding caseworkers esti-
                            mated that processing time for interstate cases is extended an average
                            of 6 months while they try to locate absent parents for whom the
                            initiating agency does not provide accurate address and employment
                            information. Similarly, our Alameda County case review indicated that
                            establishment of support orlers is delayed about 4 months when cases
                            are received with missing or inaccurate information.


Likelihood of Collections   Lack of absent parent information is a major factor contributing to the
Reduced                     lack of collections in most cases sent to responding states for enforce-
                            ment. The 1987 Connecticut study concluded that when the initiating
                            agency did not provide an accurate address, employment information,
                            social security number, or date of birth, the responding state was
                            unlikely to find the absent parent and collect support. In Wayne County,
                            Michigan, a study of 1,000 cases received from other states showed that
                            inability to locate the absent parent was the major reason a support
                            order was not established and collections not obtained for 641 cases.




                            Page 15                                   GAO ‘HRJMO-41 Need for Absent Parent Information
                                       Chapter 2
                                       Better Absent Parent Information     Needed for
                                       pursuing Interstate cases




                                       Our Alameda County case file review also indicated that cases were less
                                       likely to result in collections when initiating agencies did not provide
                                       accurate information, as shown in table 2.1.

Table 2.1: Success of Collections in
Alameda County When Certain Types of                                                                  Number of                Number with
Information Were Provided*             Information provided by initiating agency                         cases                  collections
                                       Correct address and employer                                              9                          9
                                       Neither address nor employer                                             21                          3
                                       Correct employer only                                                     5                          3
                                       Correct address onlv                                                      5                          2
                                       Unable to determine what informatlon was
                                          provided                                                               3                          2
                                       Initiating jurisdiction requested dismissal”                              7                           0
                                       Total                                                                    50                          19
                                       aBased on 50 Interstate cases received between January and March 1987 CollectIon status as of Apnl
                                       1988
                                       bCases wlthdrawn   due to such circumstances   as the absent parent assuming custody of the child


                                       As table 2.1 shows, the Alameda County child support agency collected
                                       payments in less than one-half the cases. When the initiating agency
                                       provided neither accurate address nor employment information, the
                                       county collected nothing in 18 of 21 cases. In 2 of the 18 cases the par-
                                       ent lacked the ability to pay; in 15 cases the parent was not found in
                                       Alameda County; and in 1 case collection action was still pending. When
                                       the initiating agency provided both accurate address and employment
                                       information, Alameda County collected child support in all 9 cases.


Opportunities to
Improve Information
Through Better Use of
Available Sources

Limited Use of Responding              Initiating child support agencies often do not use responding states’
States’ SPLSs                          SPISS   to obtain absent parent information, although these services gener-
                                       ally have access to address, employer, and wage data for individuals
                                       who live or work in the state. Of the 10 initiating caseworkers we sur-
                                       veyed, 2 never used this information source; 1, rarely; and 2, sometimes.
                                       Four were discouraged from using this source because the SPIss



                                       Page 16                                        GAO,BMMO-41      Need for Absent Parent Information
                                         Chapter 2
                                         Better Absent Parent Information    Needed for
                                         F?lrsuing interstate cases




                                         responded so slowly to their requests. Moreover, all could more success-
                                         fully process interstate cases if they could quickly obtain address,
                                         employer, and wage data for out-of-state absent parents.

                                         Available data indicate SPISS sometimes take months to respond to inter-
                                         state requests. SPIS officials estimated that their average response time
                                         for such requests ranged between 1 and 90 days; 27 of the 54 SPISS esti-
                                         mated an average response time of 30 days or longer. (See app. IV for
                                         SPISS response-time estimates.) Initiating caseworkers we surveyed
                                         estimated that responding SPISS took 21 to 140 days to reply to their
                                         requests. California officials reviewed 384 information requests they
                                         had made to 47 other states in 1987, and found that average response
                                         times ranged from 20 to 353 days, with 20 SPISS averaging more than 60
                                         days to reply.”

Quicker Response Possible                SPU  officials we surveyed, if required, could provide information
                                         quickly from readily accessible databases, although some have backlogs
                                         and may need additional resources. Most SPISS do not quickly respond to
                                         requests from other states. However, 34 SPIS officials we contacted can
                                         access their state’s employment and motor-vehicle records within 1 day,
                                         as shown in table 2.2.
Table 2.2: SPLS Access Time for Motor-
Vehicle and Employment Databases                                                               States accessing
                                         Access time                           Motor-vehicle data Employment data                      Both
                                         Immediate or same day                                    45                     37                 34
                                         1 to 2 days                                               3                      7                  6
                                         3 to 7 days                                               2                      4                  5
                                         Greater than 7 days                                       4                      4                  7
                                         No access                                                 0                      2                  2
                                         Total                                                    54                     54                 54


                                         OCSE  recognizes the need for quicker responses to requests for informa-
                                         tion by responding state parent locator services when cases are not
                                         referred for enforcement action. In comments accompanying the August
                                         1989 regulations establishing performance standards for case process-
                                         ing, OCSE said that responding states should respond more quickly to
                                         such interstate information requests by providing data from automated
                                         sources. However, OCSE has not established time frames for responding
                                         to such requests.


                                         “Interstate Location Study, California Parent Locator Sen-ice. August 1988.



                                         Page 17                                     GAO/HRD-90-41     Need for Absent Parent Information
                                    Chapter 2
                                    Better Absent Parent Information   Needed for
                                    Pnralling Interstate cases




Central Registries Delay            Some child support officials told us that interstate information requests
Response Time                       were slowed by the OCSE requirement that such requests be processed
                                    through the responding state’s central registry. The Indiana SPIS direc-
                                    tor told us that routing requests through states’ central registries added
                                    at least 10 days to the overall response time. California SPIS officials
                                    said that their system would allow information requests from other
                                    states to be phoned in and entered immediately on a computer screen for
                                    action, but that the requirement to submit requests through the state’s
                                    central registry prevented using the phone-in system. Moreover, central
                                    registries often do little more than act as conduits to SPISS for informa-
                                    tion requests.

                                    State officials attending locate conferences in October 1988 and May
                                    1989 asked OCSE to eliminate the requirement that information requests
                                    be processed through the central registry. In November 1989, OCSE offi-
                                    cials told us that initiating agencies may make information requests to
                                    responding SPISS without going through the central registry. OCSE had
                                    not issued specific guidance to states setting forth this position at the
                                    time of our review, but it indicated that it plans to do so in its formal
                                    comments to this report.

OCSEInitiatives to Improve          OCSE has  taken steps to improve initiating agencies’ access to absent
Interstate Access to Information    parent address and employment information in interstate cases. OCSE
                                    funded demonstration projects to establish regional locate networks in 2
                                    of HHS'S 10 regions. Agency officials in those regions told us that the
                                    networks are useful in obtaining data from participating states. Also,
                                    OCSE is planning to establish a nationwide automated child support net-
                                    work by 1992, which OCSE officials told us should facilitate quick
                                    responses by SPLSS to interstate information requests. The network plans
                                    were still being developed at the time of our review.


Use of Other Information            Child support officials make varying use of national and regional infor-
Sources                             mation sources for obtaining data on out-of-state absent parents. Such
                                    sources are particularly helpful when the initiating caseworker does not
                                    know which state to contact for information.

Nationwide   Motor-Vehicle   Data   SPLS officials told us that child support agencies in 11 of the 54 states
                                    have access to nationwide motor-vehicle records. The agencies access
                                    these data through the National Law Enforcement Telecommunications
                                    System-an automated communication network that provides on-line
                                    nationwide access to motor-vehicle records. Officials in most of the 11
                                    states routinely use this network before initiating interstate cases to


                                    Page I8                                   GAO/~90-41   Need for Absent Parent Information
                                 Chapter 2
                                 Better Absent Parent Information   Needed for
                                 Pursuing Interstate cases




                                 obtain or help confirm absent parent addresses, and such queries pro-
                                 vide absent parent addresses 40 to 80 percent of the time.

                                 The network was established and is operated by state law enforcement
                                 agencies to provide information for criminal justice purposes. Some
                                 state child support agencies have been denied access to the network
                                 because network operators do not view them as law enforcement agen-
                                 cies or do not believe they would use the information for criminal justice
                                 purposes.

                                 By 199 1, access to nationwide motor-vehicle data may become available
                                 through a communications network being developed by the American
                                 Association of Motor Vehicle Administrators with funds provided by the
                                 Department of Transportation. This planned network will be used to
                                 meet the needs of state motor vehicle administrators and other govern-
                                 ment agencies for motor vehicle business. OCSE has encouraged child
                                 support agencies to arrange access to this network.

Federal Parent Locator Service   Of the initiating caseworkers we surveyed in 10 states: 1 always uses
                                 the Federal Parent Locator Service; 5 often use it; 2, sometimes; and 2,
                                 rarely. Some did not use the service more frequently because data from
                                 federal records obtained through the service are sometimes out of date,
                                 obtaining the data can be time consuming, or more accurate data can be
                                 obtained from other sources. However, six believed the data are often
                                 useful for interstate case pursuit. OCSE has taken steps to improve the
                                 response time and accessibility to the service, and child support agencies
                                 are making increased use of this source.

Nationwide Employment Data       OCSE is negotiating with the Department of Labor and state employment
                                 services to allow all child support agencies to have access to nationwide
                                 employment records, as called for in the Family Support Act of 1988.
                                 The agencies will access this information through Federal Parent Loca-
                                 tor Service quarterly cross-matches with state employment records. One
                                 state child support agency reported participating in such a match. That
                                 agency submitted a tape of 1,173 absent parents for which address and
                                 employment information were lacking, and reported receiving informa-
                                 tion on 41 percent of the parents.

Commercial Sources               Some states have found that such commercial sources as credit bureaus
                                 and regional telephone databases are useful when initiating interstate
                                 cases. Five of the 10 initiating caseworkers we surveyed use credit
                                 bureaus to obtain information on out-of-state absent parents and some-
                                 times find such data useful to the case. One state official believed that a


                                 Page 19                                   GAO~‘HRD9O-41   Need for Absent Parent   Information
                         Chapter 2
                         Better Absent Parent Infomuxtion   Needed for
                         Pursuing rnterBtat4? casea




                         regional telephone database is often useful for finding or completing an
                         address or obtaining an out-of-state absent parent’s phone number.


                         Initiating agencies obtain absent parent address and employment infor-
Verification Practices   mation from custodial parents or other sources that sometimes is inaccu-
Vary                     rate or out-of-date. However, their verification practices vary. While
                         some initiating agencies routinely verify information before forwarding
                         cases to other states for enforcement, others do not. Initiating case-
                         workers in 7 of the 10 states we surveyed reported always verifying
                         out-of-state absent parent addresses with the post office, and
                         caseworkers in 6 states reported always contacting employers to verify
                         employment. Federal regulations do not set forth requirements for infor-
                         mation verification, leaving to the child support agency’s discretion
                         what steps to take to ensure that information provided to responding
                         states is sufficient and accurate enough to act on.

                         There was a general consensus among child support officials surveyed
                         that initiating agencies should verify absent parent address and employ-
                         ment data before forwarding the cases for interstate enforcement. Initi-
                         ating caseworkers in all 10 states surveyed believed that data
                         verification by initiating agencies saves case processing time and
                         increases the likelihood of collections by responding states. Officials in
                         six central registries we surveyed believed that if initiating agencies
                         obtained and verified absent parent information before forwarding
                         cases, there would be a great improvement in interstate enforcement.
                         Three other central registry officials believed doing so would be a mod-
                         erate improvement because they thought initiating agencies now obtain
                         and verify such information. Also, SPLS officials in 11 of 13 states with
                         whom we discussed the issue said that initiating agencies should verify
                         absent parent information.

                         Some child support officials told us that employment verification should
                         be done by responding states. Oregon SPLS officials have asked that ver-
                         ification checks with employers in their state be handled through the
                         Oregon SPLS so that large employers are not burdened with individual
                         requests from all over the country. OCSE officials also expressed concern
                         about child support agencies contacting out-of-state employers directly
                         to verify employment on cases initiating agencies intend to refer to
                         other states for enforcement. The OCSE officials told us that this might be
                         burdensome on some employers, and that responding states are more
                         familiar with local employers.



                         Page 20                                   GAO/HRD9O-41   Need for Absent Parent Information
                      Chapter 2
                      Better Absent Parent Information   Needed for
                      Pnrsning Interstate cases




                      Initiating child support agencies often fail to obtain and verify critical
Conclusions and       information about out-of-state absent parents. As a result, initiating
Recommendations       agencies do not pursue some cases and use inefficient procedures to pur-
                      sue others. Also, agencies often refer cases to other states with missing
                      and inaccurate information, resulting in wasted resources, case process-
                      ing delays, and decreased collections by the responding states.

                      Initiating child support agencies often do not use all available sources to
                      obtain missing information on out-of-state absent parents. Some do not
                      use the SPLS in the state where the absent parent lives or works because
                      the services respond too slowly. Most SPLSS have l-week access to state
                      records with address and employment data, but many do not respond
                      quickly to requests for information from other states. Moreover,
                      response time increases when child support agencies send information
                      requests through responding states’ central registries, which merely act
                      as conduits for such requests. Interstate child support cases could be
                      pursued more efficiently and effectively if initiating agencies could
                      access needed information sources in other states more directly and
                      receive requested information more quickly.

                      Responding states should save time and resources, and the chances for
                      successful enforcement should increase, if initiating agencies obtained
                      critical absent parent information before deciding where or how to pur-
                      sue cases and verified absent parent addresses before referring cases to
                      other states for action.

                      We recommend that the Secretary of Health and Human Services direct
                      OCSE to:

                  . Require that initiating child support agencies exhaust all reasonable
                    efforts, including, as appropriate, checking other states’ parent locator
                    services, to obtain address and employment information on out-of-state
                    absent parents for use in deciding how best to pursue interstate cases.
                  l Require initiating agencies to verify out-of-state absent parents’
                    addresses with the post office before sending cases with questionable
                    information to other states for action.
                  l Require, by modifying existing performance standards, that responding
                    state parent locator services quickly (preferably within 1 week) provide
                    information from motor-vehicle, employment. and other readily accessi-
                    ble sources when responding to other states’ information requests on
                    cases that have not been referred for action.




                      Page 21                                   GAO %RD90-41   Need for Absent Parent Information
                      Chapter 2
                      Better Absent Parent Information   Needed for
                      Fnrsuing Interstate cases




                  l   Clarify that initiating child support agencies may request absent parent
                      information directly from other states’ parent locator services without
                      sending the requests through the responding states’ central registries.


                      HHSshared our concern about the inadequacy of information for locating
Agency Comments       absent parents in interstate cases and agreed with our recommendation
                      to make clear that initiating agencies can make direct information
                      requests of other states’ parent locator services. HI-Bsaid, however, that
                      existing and new rules, effective October 1990, will substantially meet
                      our recommendation that initiating agencies should be required to
                      exhaust all reasonable efforts to obtain address and employment infor-
                      mation on out-of-state absent parents for use in deciding how best to
                      pursue interstate cases.

                      While we agree the new rules are a step in the right direction, we ques-
                      tion whether they go far enough to address the problems we found with
                      interstate cases. Neither the current nor new rules effective October
                      1990 make clear what actions are needed to effectively pursue cases
                      involving parents living out of state, Such actions often are more time
                      consuming, difficult to administer, and critical to effective enforcement
                      than actions needed when parents live within a state. For example, the
                      rules do not address direct wage withholding for interstate cases, which
                      we believe to be among the most effective enforcement options for such
                      cases and which initiating caseworkers we surveyed often identified as
                      their preferred enforcement option. However, the technique often was
                      not used because out-of-state absent parent address and employment
                      information was lacking.

                      Also, while the rules identify many information sources for locating
                      absent parents, they do not identify, for use in finding out-of-state par-
                      ents, other states’ parent locator services. These normally have address,
                      employer, and other information on persons living or working in the
                      state, and, thus, are critical references when initiating interstate cases.
                      We also found that many case initiators were not routinely checking this
                      source. Thus, notwithstanding the new rules, we continue to question
                      whether initiating states will exhaust all reasonable efforts to obtain
                      accurate address and employment information before deciding on the
                      most appropriate enforcement action. We have revised our recommenda-
                      tion to specify that such reasonable efforts should include “as appropri-
                      ate, checking other states’ parent locator services.”




                      Page 22                                   GAO/HRD9O-41   Need for Absent Parent Information
Chapter 2
Better Absent Paremt Information   Needed for
Pnrsning interstate ca8es




Regarding our recommendation that agencies, before referring cases to
other states for services, verify absent parents’ addresses with the post
office, HHS said that its new rules would accomplish the recommenda-
tion’s purpose. HHS also said that post-office verification may be
counterproductive and hinder location efforts when an initiating agency
is reasonably certain of an address’s validity.

While we agree that initiating agencies should act on cases when they
are reasonably certain they have accurate information, we believe that
HHS'S rules should require post-office verification when there is doubt,
such as when there are indications that the parent could be living or
working in more than one state. Routine post-office verification is a rela-
tively simple and quick way of verifying that information is accurate so
that cases are referred to the correct state for action. We found that
cases often are sent to the wrong state or referred with incomplete or
inaccurate addresses, which results in long delays and wasted effort.
States that routinely conduct post-office verifications said the process
takes 2 to 3 weeks, while responding caseworkers estimated that case
processing time is extended an average of 6 months when they must
locate absent parents for whom initiating agencies fail to provide accu-
rate addresses. In such cases, the short delay needed for case initiators
to do post-office verification would be more than offset by the substan-
tial amounts of processing time and effort that could be saved. Our rec-
ommendation was revised to require post-office verification for cases
“with questionable information.”

Regarding our recommendation that state locator services be required to
quickly (preferably within 1 week) respond to other states’ requests for
absent parent information, HHS said that there already are time frames
for this purpose. In addition, HHS commented that its new rules will
require agencies to check all appropriate location sources. However, the
time frames do not apply to responding agencies unless a case has been
referred to them for action. Thus, the standards do not apply to requests
for location information when cases have not been referred for action.
Initiating agencies expeditiously need such information to decide the
most effective enforcement option or where to refer the cases. We have
clarified our recommendation to require performance standards to
ensure state agencies quickly provide readily accessible information
“when responding to other states’ information requests on cases that
have not been referred for action.”




Page 23                                   GAO/HRIMO-41   Need for Absent Parent Information
Amendix   I

SourcesRoutinely Accessedby SPSs


                                                                                                   States with
              Information sources                                                                      access
              Motor vehicle (driver Incense, auto registration)                                                 54
              Employment (employer, wage, unemployment)                                                         52”
              Public assistance (Food Stamps, Aid to Families With Dependent
                Children, Medrcaid)                                                                             32
              Correctrons/crimrnal                                                                              16
              Credit bureaus                                                                                    13
              State tax (for address only)                                                                      10
              State tax (including financial data)                                                               6
              State personnel department                                                                         4
              Miscellaneous                                                                                      7
              aOhlo and Rhode Island do not yet access employment data pending completion of planned automatlon
              projects Of the 52 states that do access employment data, Puerto RICOreported collecting employer
              but not wage data.




              Page 24                                    GA0/‘HRD90-41     Need for Absent Parent Information
Auuendix II

Major Options Available to Initiating Agencies
for Interstate Child Support Enforcement

                     This can be used to enforce an existing support order when the absent
Direct Income        parent works for the military, the federal government, or an employer
Withholding          that does business in the initiating and responding states. The initiating
                     child support agency can enforce income withholding through these
                     employers without involving the state where the absent parent works.


                     This can be used to enforce an existing support order when the absent
Interstate Income    parent is employed in the responding state. Federal law requires that,
Withholding          upon request of the initiating child support agency, the responding state
                     must enforce income withholding without amending the existing order
                     or further court action.


                     These can be used by an initiating child support agency to establish
Long-Arm Statutes    paternity and support orders for out-of-state absent parents without
                     involving the other state, under certain circumstances. For example,
                     many states have long-arm statutes that allow support order establish-
                     ment when couples were married, were divorced, or conceived the child
                     in the initiating state. Enforcement of the order must be carried out
                     through one of the other options.


                     The model legislation can be used to establish paternity and support
Uniform Reciprocal   orders, as well as to enforce orders. It is the most frequently used
Enforcement of       enforcement option. Upon request of the initiating child support agency,
Support Act          the responding state uses its own legal processes to establish and
                     enforce a new order, even if one already exists. The responding state
(Civil Procedure)    may use all avlilable tools to enforce the order, including income with-
                     holding, liens, etc. All states have such procedures.


                     The model legislation can be used to enforce an existing support order.
Uniform Reciprocal   At the request of the initiating child support agency, the responding
Enforcement of       state legally certifies (registers) the order; no new order is established.
Support Act          The registered order is then treated the same as it would be if estab-
                     lished by the responding state. Thirty-six states have such procedures.
(Registration)




                     Page 25                           GAO ~HRD90-41 Need for Absent Parent Information
Appendix III

Scopeand Methodology Details


                            Based on a literature search and a survey of interstate demonstration
Review of Relevant          projects, we identified and examined the following studies:
Interstate Studies
                        l Interstate Child Support Collections Study, by Dennis Cooper, funded by
                          HHS and published in 1985, surveyed local and state child support
                          officials.
                        l The Maryland (1986), Connecticut (1987’), and Michigan (1988) inter-
                          state demonstration projects, funded by OCSE demonstration grants,
                          reviewed files on initiating and responding interstate cases.
                        l Child Support Enforcement Collections on AFDC Cases-Non-Pursuit
                          (OAI-05-87-00033), published in August 1987 by HHS'S Office of Inspec-
                          tor General, reviewed a sample of cases that had been open at least 2
                          years but had not resulted in support orders.
                        l Analysis of Legal Remedies for Establishing, Modifying, and Enforcing
                          Interstate Child Support Orders, a February 1987 Delaware study
                          funded by an OCSE demonstration grant, described various options for
                          pursuing interstate cases.
                        l Interstate Location Study, published by the California Parent Locator
                          Service in August 1988, reviewed a sample of location requests sent by
                          California to other SPLSS.
                        l Interstate Child Support Enforcement Model System, a study by the
                          Center for Health Services Research, University of Southern California,
                          funded by HHS, published in 1980, examined the interstate process.
                        . Previous GAO reports, including Interstate Child Support: Case Data Lim-
                          itations, Enforcement Problems, Views on Improvements Needed (GAO!
                          HRD-89-25, Jan. 27, 1989).



                            We did fieldwork in San Diego and Alameda Counties in California,
Work in Local Offices       where we examined the process of initiating and responding to inter-
                            state cases and interviewed the personnel involved. We selected Califor-
                            nia because it has a large number of interstate cases; Alameda and San
                            Diego are large counties in the northern and southern parts of the state.
                            In April 1988, we reviewed Alameda County files on cases received from
                            other states. We selected a random sample of 50 cases of the 187 cases
                            received between January and March 1987, and examined the informa-
                            tion that was provided by the initiating child support agencies and iden-
                            tified what had happened to those cases by April 1988. In San Diego we
                            observed the court proceedings and traced several cases from intake
                            through enforcement.




                            Page 26                         GAO/HRD-90-41   Need for Absent Parent Information
                                           Appendix III
                                           Scope and Methodology   Detaila




                                           To obtain information concerning the extent and timeliness of SPISS, in
Survey of SPLSs                            June and July of 1988, we conducted a telephone survey of all 54 SPISS
                                           (the 50 states, the District of Columbia, Puerto Rico, Guam, and the Vir-
                                           gin Islands). When SPISS reported difficulties accessing state department
                                           of motor vehicle and employment databases, we conducted follow-up
                                           interviews with various state officials to determine the reasons for lack
                                           of quick access.


                                           In February 1989, we conducted a telephone survey of case initiators,
Survey of Interstate                       central registries, and case responders in 10 states to determine their
Case Processors                            practices and views concerning the gathering of absent parent informa-
                                           tion in interstate cases and any changes that have occurred since imple-
                                           mentation of the 1988 interstate regulations. We selected one state from
                                           each HHS region. We interviewed state central registry officials, as well
                                           as case initiators and responders in one major local office in each state.
                                           States and localities were selected to represent programs with varying
                                           organization structure, level of automation, and effectiveness. The
                                           states included in the survey account for about 50 percent of nationwide
                                           child support collections. The locations are shown in table III. 1.
Table 111.1:Case Processors Surveyed
                                           Central registries                                     Local offices
                                           Massachusetts                                          Boston (Dorchester)
                                           New York                                               Onandaga County (Syracuse)
                                           Pennsylvania                                           Allegheny County (Pittsburgh)
                                           Florida                                                HIllsborough County (Tampa)
                                           Michigan                                               Wayne County (Detroit)
                                           Texas                                                  San Antonio
                                           Missourl                                               Jackson County (Kansas City)
                                           Colorado                                               Denver
                                           California                                             San Bernardlno Countv
                                           Idaho                                                  Boise



                                           To gather information on other sources of absent parent data and dis-
Discussions With                           cuss possible improvements, we interviewed officials from
Relevant Officials
                                       l   the Office of Child Support Enforcement, including the Federal Parent
                                           Locator Service, concerning policies and procedures for obtaining infor-
                                           mation on out-of-state absent parents;




                                           Page 27                           GAO ~HRD-90-41 Need for Absent Parent Information
    Appendix Ill
    Scope and Methodology   Details




l   the Department of Labor and the Interstate Conference of Employment
    Security Agencies, concerning nationwide access to employment data;
    and
l   the National Law Enforcement Telecommunications System, the Depart-
    ment of Justice, and the American Association of Motor Vehicle Admin-
    istrators, concerning nationwide access to motor-vehicle data.

    We also attended oCsE-sponsored conferences in 1988 and 1989, where
    interstate absent parent information issues were discussed by state and
    federal officials.




    Page 28                           GAO/HRD90-41   Need for Absent Parent Information
Appendix   IV

SPIS Estimaks of Average ResponseTime to
Interstate Requests

                                                      Time                                                        Time
                State                            (in days)                 State                             (in days)
                Anzona                                    1                Alabama                                   30
                Missouri                                  1                Kansas                                    30
                Virainra                                  2                Montana                                   30
                Nebraska                                  4                New Jersey                                30
                Iowa                                      8                Tennessee                                 30
                Nevada                                    8                Utah                                      30
                Idaho                                    10                Wyoming                                   30
                New Mexrco                               10                Flonda                                    31
                Colorado                                 14                Kentucky                                  31
                Illinois                                 14                Indiana                                   35
                Minnesota                                14                New Hampshire                             35
                North Carolina                           14                Wisconsin                                 45
                Vermont                                  14                Alaska                                    49
                California                               17                Massachusetts                             49
                Guam                                     17                Louisiana                                 53
                Mississippi                              18                Maryland                                  55
                South Carolina                           18                Drstnct of Columbia                       60
                North Dakota                             20                Hawaii                                    60
                Virgin Islands                           20                Ohio                                      60
                Connecticut                              21                Oregon                                    60
                Georara                                  21                Puerto Rico                               60
                New York                                 21                South Dakota                              60
                Rhode Island                             21                West Virginia                             60
                Texas                                    21                Michigan                                  75
                Maine                                    24                Delaware                                  75
                Pennsylvania                             24                Arkansas                                  90
                Washington                               28                Oklahoma                                  90
                Note- Based on a telephone survey of all 54 SPLSs (the 50 states, the Dlstnct of Columbia. Puerto RICO.
                Guam. and the Vlrgln Islands) conducted In June and July 1988.




                Page 29                                       GAO/HRDSO-41      Need for Absent Parent Information
Appendix   V

Comments From the Department of Health and
Humm Services


                  DEPARTMENTOF             HEALTH&HUMAN       SERVICES                       Oll~ce of Inspector General




                                                              MAR27l990



               Mr. Franklin      Frazier
               Director,     Income Security              Issues
               United States General
                  Accounting     Office
               Washington,      D.C.     20548

               Dear     Mr.     Frazier:
               Enclosed are the Department's         comments on your draft         report,
               "Interstate       Child Support:   Better   Information     Needed on Absent
               Parents     for Case Pursuit."     The comments represent         the tentative
               position      of the Department   and are subject       to reevaluation      when
               the final      version  of this report    is received.
               The Department    appreciates the opportunity                     to comment on this
               draft report   before its publication.
                                                               Sincerely     yours,



                                                               Richard   P. Kusserow
                                                               Inspector   General
               Enclosure




                      Page 30                                      GAO/HRD9O41   Need for Absent Parent Information
       Appendix V
       Comments From the Department      of Health
       and Human Services




COMMENTSOF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES ON
DRAFT GAO REPORT "INTERSTATE CHILD SUPPORT: BETTER INFORMATION
NEEDED ON ABSENT PARENTS FOR CASE PURSUIT"
GAO recommendation:
That the Secretarv     of HHS direct  OCSE to recuire   that
initiatina  child   sunoort  aaencies  exhaust  all reasonable
  ff rts to obtaindress       and emolovment inform ation on out-of-
EtaFe absent oaren ts for use in decidina      how best to oursue
interstate  case S.
g eat
   D r ment comments:

Like GAO, we are concerned           about the inadequacy            of locate
information    in interstate       cases.       However, we believe           new
program operations        standards,      effective       October 1990, and new
regulations    for interstate        cases, effective          in 1988, will
substantially     meet this recommendation              and will     contribute    to
more effective      resolution     of child       support     cases (see 45 CFR
Part 303).     These new rules,         by establishing          more stringent
requirements     for case management and tighter                 time frames for
States to take action          in child    support      cases, will      alleviate
many of the problems cited            in this     report.
Under the new program operations                rules,     States will        be required
to access all appropriate             location      sources,     including       the
Federal      Parent Locator      Service      (FPLS), public        assistance
offices,       social   services    offices,      and State employment and tax
offices      within    75 calendar      days   after    determining        that location
services       are necessary.       In addition,        the rules      require      States,
within     this time frame, to ensure that location                     information       is
sufficient        to take the next appropriate             action     on a case.        We
believe      these requirements         will   ensure that States take
vigorous       action   in locating       absent parents.
GAO recommendation:
That the Secretarv           of HHS direct     OCSE to recruire  initiatinq
aaencies   to verifv         out-of-State     parents' addresses     with the
Post Office   before         sendins     such cases to other States       for
action.
Deoartment       comments:
As with our above comments, we believe          that the new rules,
requiring  States to access all appropriate           location   sources and
to ensure that the location      information      is sufficient    to
proceed with next step in the case, will            accomplish   GAO's
objective  that location   information       be as accurate     as possible.
We disagree,  however,           that the Department  should specify                 to the
degree stated  in this           recommendation  how agencies ensure                 that




       Page 31                                       GA0.WUMO-41   Need for Absent Parent Information
      AppendixV
      CommentsFrom the Department       of Health
      and HumanServices




location    information      is sufficient       to proceed with a case.
While States may use the U.S. Post Office                     in their     location
efforts   and it is one source cited             in Federal        regulations       as a
source for location        information,        we do not believe           that
requiring     Post Office      verification      is a necessary          prerequisite
for further      case development.          In fact,      in some instances,          it
may be counterproductive            to require     verification         with the Post
Office,   such as when the State has obtained                   a recent address
and is reasonably       certain       of its validity.          We believe       agencies
should act quickly       upon obtaining         such information,            and that
requiring     Post Office      verification      could hinder          absent parent
location    efforts.
GAO recommendation:
That the Secretarv       of HHS direct       OCSE to recruire,            bv modifvinq
existinu    Derformance     standards,     that resDondins             State Darent
locator    services   uuicklv    (ureferablv    within   one           week) Drovide
&nformation      from motor vehicle,       emDlovment,   and           other readilv
accessible     sources when actina       on other States'              reouests   for
such information.
peDartment       comments:
Standards    for program operations  already    establish     clear time
frames for States to take actions      in each child      support    case
for which the State is responsible.        These time frames and
requirements     for action have been substantially       strengthened    in
new rules.
Until      an initiating      State forwards    a case   using an interstate
transmittal         form, the case remains the responsibility           of the
initiating        State to work on and resolve.          This includes
providing       location     services.   Within   75 calendar     days,
according       to new regulations,      all appropriate      location   sources
must be accessed and the sufficiency              of the location
information         ensured.
When a State determines               that a case requires        interstate        action,
the initiating         State must refer          the case to the responding
State's     central      registry.        The case then becomes         the responding
State's     responsibility.             The responding    State must then take
appropriate       actions,       including     providing   location        services,
within    time limits         established      in Federal    regulations.          These
actions     include      forwarding       to the State's     parent      locator
service.
GAO recommendation:
That the Secretarv            of HHS direct     OCSE to clarifv     that
initiatins       child      SuDDort asencies     may request    absent Darent
information        directlv     from other States'      Darent locator       services
without     sendina the reauests          throucrh the resDondinq        States'
central     resistries.




      Page32                                        GAO/HRIMO-41NeedforAbsentParentlnformation
                          Appendix V
                          Comments From the Department    of Health
                          and Human Services




                                                                                                                            1

               peoartment           comments:
               The Department   concurs with this recommendation.        The OCSE is
               currently  in the process of clarifying    this situation     with the
               States and will   soon issue guidance   in this area.
               In general,       we believe     that States,       when attempting       to locate
               an absent      parent,    should have the option            of sending their
               request    for location       information        to the responding       States'
               central    registries      or directly       to the other States'         parent
               locator    services.       If the initiating          State requests      information
               directly     from another       State's     parent    locator   service,     the
               initiating      State is still         responsible      for the case and thus,
               this action       must be taken within           the time frames specified          in
               Federal    regulations.
               Alternatively,        if the State chooses to forward            the request     for
               location     information        to a responding     State's   central   registry
               using an interstate           transmittal    form, the case becomes an
               interstate      case and the responding          State must take actions         in
               the case within         specific     time frames,    as established     in Federal
               regulations.
               Technical         comments
Nowonp     2   Page    3, second paragraph            - The report       incorrectly         states      that
               regulations         require   initiating        agencies     to "obtain        absent
               parent     information      within       60 days (75 days effective               October
               1990)."       More precisely,          current    regulations         require      that
               agencies      use all State and local             location      sources within            60
               days.      New regulations,           effective     October 1990, require               that,
               within     75 calendar      days, agencies          access all appropriate
               sources,       including    the FPLS, and ensure that information                         is
               sufficient        to take the next action            in the case.
Now on p 3     Page 4, second paragraph            - GAO asserts        that initiating     States
               often do not use the responding               State's      PLS because the
               responding       State services      are slow.        This statement     should be
               clarified      to reflect     the fact that when an initiating              State
               transmits      a case to a responding          State,      and creates   an
               interstate       case,  the responding        State must take appropriate
               action,     including     providing     locate    services     if necessary,
               within     60 days (90 calendar         days,    effective     October 1990).
Now on   P 4   Page 6        - GAO imprecisely          states     that Federal        regulations
               require         initiating     States to provide             other States with absent
               parent        information      that is "accurate"             and "sufficient".
               Current         regulations      require      States to refer          cases to other
               States        "if there is a reasonable               belief     that the absent parent
               may be        present      in such State."          "Accurate"       and "sufficient"
               refers        to the forms involved            in interstate         referrals.       The
               initiating            State must provide         the responding         State "sufficient,
               accurate          information      to act on the case bv submitting                 with each




                          Page 33                                     GA0,'HRD904NPed       for Absent Parent Information
                       Commenta From the Department   of Health
                       and Human Servicea




               case                                                           the Interstate
               ;                                                                 the URESA Action
               Bauest       Forms   nackacre as anDroDriate.ll           (emphasis added)
Now on P 9     Page 15, figure     1.1 - The statement     that a child      support    agency
               lldoes not pursue (the) case if absent parent           cannot be locatedI'
               reflects   current   regulations.     New regulations      require    repeat
               location   attempts    in cases where previous      attempts     have failed,
               including,    at a minimum, quarterly      submissions    to State
               employment security      files,   and annual submissions       to the FPLS.
Nowonp   11    Page 19 - For the sentence beginning    I'OCSE lengthened the
               time...",  we suggest the following  language which more
               accurately  reflects  the regulatory change:
                      OCSE lengthened     the time to allow for access to the Federal
                      Parent Locator    Service,   to ensure the sufficiency  of
                      information   received,    and to allow adequate time for States
                      which do not yet have automated access to sources.
Nowonp    13   Page 22 - Contextual        information      would be useful        here to
               clarify    that the situations       described      (no location     attempts,
               failed   location)   are inconsistent,         or soon will      be, with
               federal    policy.   New and current        regulations     require     that IV-D
               agencies     attempt to locate     all absent parents;          new regulations
               require    repeat location     attempts     where previous       attempts    have
               failed.
Now on P. 17   Page 29 - GAO asserts         that OCSE has not established            time
               frames for responding       States to respond to initiating              State's
               location   information     requests.     As previously        mentioned,     when
               initiating     States refer     a case to another       State's    central
               registry,    it becomes an interstate       case.       In such instances,
               OCSE has established      time frames for responding            States to act,
               including    time frames for location       activities.




                        Page 34                                   GAO/HRD-90-41Need for Absent Parent Information
Major Contributors to This Report


                   Daniel M. Brier, Assistant Director, (202) 275-0636
Human Resources    Byron S. Galloway, Assignment Manager
Division,
Washington, D.C.

                   Margie K. Shields, Evaluator-in-Charge
San Francisco      Donald J. Porteous, Site Senior
Regional Office    Stephen Secrist, Evaluator
                   Jonathan Silverman, Reports Analyst




(105464)           Page 36                          GAO/HRD90-41   Need for Absent Parent Infornuxtion
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