Child Support Enforcement:

Strong Leadership Required to Maximize Benefits of Automated Systems

AIMD-97-72: Published: Jun 30, 1997. Publicly Released: Jul 17, 1997.

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Pursuant to a congressional request, GAO updated its 1992 report on child support enforcement, focusing on: (1) the status of state development efforts, including costs incurred; (2) whether the Department of Health and Human Services (HHS) had implemented GAO's 1992 recommendations; and (3) whether the Department was providing effective federal oversight of state systems development activities.

GAO noted that: (1) it is too early to judge the potential of fully developed automated systems, yet bringing the benefits of automation to bear on child support enforcement appears to have played a major role in locating more noncustodial parents and increasing collections; (2) according to HHS, in fiscal year (FY) 1995, almost $11 billion was collected, 80 percent higher than the amount collected in 1990; (3) while automated state child support systems are being developed, many may not be certified by the October 1, 1997, deadline; (4) furthermore, states have underestimated the magnitude, complexity, and costs of their systems projects; (5) systems development costs for FY 1995 alone were just under $600 million, and over $2.6 billion has been spent since 1980 for county and statewide systems development; (6) GAO's 1992 report discussed significant problems in federal oversight and monitoring of state activity, and made three recommendations; (7) however, only one has been completely implemented; (8) the Office of Child Support Enforcement (OCSE) now works with its audit division to identify and resolve systems problems; (9) GAO's recommendations to suspend federal funding when major problems exist and to require states to initiate corrective actions when problems are first identified were only partially addressed; (10) OCSE's oversight of state child support systems has been narrowly focused and, as a result, not effective or timely in assessing the states' systems approaches and progress; (11) OCSE believes it lacks the technical expertise and resources to be involved at critical points in the systems development process; (12) OCSE's role has been primarily limited to document review and after-the-fact certification when the states request an inspection of completed systems; (13) therefore, OCSE has allowed some funds to be spent without ensuring that states were progressing toward effective or efficient systems; (14) while OCSE has shared some lessons learned, its oversight has operated on a state-by-state basis; (15) lacking this nationwide perspective has hindered the agency's ability to provide proactive leadership to the states; (16) as added systems functional requirements of the newly enacted welfare reform legislation come into play, it will be increasingly important that child support enforcement systems work as envisioned and that OCSE monitor progress on a broader scale; and (17) many recipients may find that they no longer qualify for welfare benefits, with child support being their only remaining income.

Recommendations for Executive Action

  1. Status: Closed - Not Implemented

    Comments: According to the Director of Information Systems, OCSE, OCSE does not intend to assess the additional costs of welfare reform automation efforts in the states. The official stated that it is very difficult to separate systems projects and identify the incremental costs of system changes to comply with the welfare reform requirements. All of the welfare reform automation requirements are to be in place by September 30, 2001. Therefore, the use of the $400 million capped funding also ends September 30. According to the OCSE Official, as of June 30, 2001, only about two thirds of the capped funding amount has been claimed by states (50 states, District of Columbia, Virgin Islands, Guam, and Puerto Rico). Currently, there have been 39 states that have used their full state allocation and 15 states that have not. OCSE is currently reviewing and certifying all of the states' welfare reform automation requirements.

    Recommendation: To maximize the federal government's return on costly technology investments, the Secretary of Health and Human Services should direct and ensure that the Assistant Secretary of the Administration for Children and Families assesses the impact of welfare reform on existing child support programs, including automated systems and business operations, and determines whether states will be able to implement systems requirements within established time frames and without exceeding the $400-million cap. This assessment should also include an estimate of additional regular rate funding for automated systems that states may need to comply with the requirements of welfare reform.

    Agency Affected: Department of Health and Human Services

  2. Status: Closed - Implemented

    Comments: According to the Director of Information Systems, OCSE, several actions are in process to address this recommendation. The ACF website lists the status of state certifications, pointers to many of the state child support websites, and a list of best practices in state systems development efforts. Plans are under way to complete a "requirements completed" document for each state over time. There has not yet been a nationwide assessment of state child support systems. However, the Director added that states do share information at semi-annual users group meetings.

    Recommendation: To maximize the federal government's return on costly technology investments, the Secretary of Health and Human Services should direct and ensure that the Assistant Secretary of the Administration for Children and Families, at least annually, assesses the progress of child support systems projects nationwide to gain and share with the states a broader perspective on costs, systemic problems, potential solutions, and innovative approaches. Information should be shared with other states to help reduce costs and improve effectiveness of the child support program nationally, especially any practices or systems that could benefit states attempting to develop or implement welfare reform systems requirements.

    Agency Affected: Department of Health and Human Services

  3. Status: Closed - Implemented

    Comments: According to the Associate Commissioner of Automation and Program Operations, Office of Child Support Enforcement, technical assistance visits began in 2002, to encourage states to adopt a higher level of automation than what is required to be certified. Although called technical assistance visits, these visits are true post implementation reviews. The reviews focus on the use of higher levels of automation to increase child support collections in such areas as wage withholding, new hires, federal institution data matches,and interstate and tax offsets. The reviews suggest some best practices of other states to help resolve identified problems found during the review.

    Recommendation: To maximize the federal government's return on costly technology investments, the Secretary of Health and Human Services should direct and ensure that the Assistant Secretary of the Administration for Children and Families conducts timely post-implementation reviews on certified child support systems to determine whether they are providing expected benefits, identify any lessons learned, and assess innovative technical solutions.

    Agency Affected: Department of Health and Human Services

  4. Status: Closed - Implemented

    Comments: OCSE within ACF procured an IV&V contractor to augment its ability to monitor states' progress and provide limited assistance to states. With the contractor personnel and the ability to add other contractor staff with special skills, the ACF Associate Commissioner, Office of Automation and Special Projects believes that he has added the expertise and skills needed to allow ACF to become more actively involved in reviewing state systems. Furthermore, ACF has completed a series of training seminars to increase headquarters and regional staffs' knowledge, skills, and abilities in program administration, software development, and system designs.

    Recommendation: To maximize the federal government's return on costly technology investments, the Secretary of Health and Human Services should direct and ensure that the Assistant Secretary of the Administration for Children and Families evaluates current staff systems knowledge, skills, and abilities and identify what additional technical expertise is needed, develops the technical skills needed to allow OCSE to become more actively involved with the states at critical points in their development processes, and enhances the skills of existing systems reviewers through additional training. This expertise should include program management, software development, and systems engineering.

    Agency Affected: Department of Health and Human Services

  5. Status: Closed - Implemented

    Comments: Under the new rules, funding will only be approved for the most immediate milestones, with funding for later milestones contingent upon successful completion. ACF plans to more closely monitor the progress of systems developments, assess deliverables, and take corrective action. The rules provide a list of triggers that will require states to obtain IV&V assessments of their projects with reports submitted directly to OCSE. OCSE has also procured an IV&V contractor to augment its ability to monitor states' progress and provide limited assistance to states. The new rule also provides that if a state fails to meet milestones in its APD, the agency may fully or partially suspend the APD and associated funding. The agency stopped funding for at least one state that failed to meet a critical milestone, and several states have been required to obtain IV&V assessments. Also, the agency's IV&V contractor has assisted in reviewing several state systems.

    Recommendation: To maximize the federal government's return on costly technology investments, the Secretary of Health and Human Services should direct and ensure that the Assistant Secretary of the Administration for Children and Families uses an evaluative approach for planned and ongoing state information technology projects that focuses on expected and actual cost, benefits, and risks. OCSE should require states to implement needed corrective actions for federally funded systems when problems and major discrepancies in cost and benefits are first identified. If a state experiences delays and problems and is not following generally accepted systems development practices, OCSE should suspend funding until the state redirects its approach.

    Agency Affected: Department of Health and Human Services

  6. Status: Closed - Implemented

    Comments: OCSE has made several changes to strengthen oversight and management of systems development projects. OCSE also issued an addendum to the State Systems Guide. This addendum identified examples of critical milestones for both developing a system using life-cycle methodology and enhancing or modifying an existing system. The addendum provides that states must identify all critical milestones and address the status of each; failure to meet a milestone may result in suspension of all or part of funding until satisfactory correction. States have now begun to submit their new APD and Annual APD Updates under the new requirements and are identifying project milestones and deliverables with the related budgets. OCSE plans to more closely monitor the progress of systems developments, assess deliverables, and take corrective action if a project goes astray. OCSE has stopped funding for at least one state that failed to meet a critical milestone until the state took the corrective action needed.

    Recommendation: To maximize the federal government's return on costly technology investments, the Secretary of Health and Human Services should direct and ensure that the Assistant Secretary of the Administration for Children and Families develops a mechanism for verifying that states follow generally accepted systems development practices to minimize project risks and costly errors. OCSE should revise the guidance for the advance planning documents and advanced planning document updates to ensure that these documents provide the information needed to assess different phases of development and are consistent from year to year. This information should include clearly defined requirements, schedules reflecting the amount of data converted, code written, modules produced, and the results of testing, and other measures to quantify progress.

    Agency Affected: Department of Health and Human Services

  7. Status: Closed - Implemented

    Comments: HHS issued a final rule on August 21, 1998, part of which provides for more systematic determinations and monitoring of key milestones in state systems developments, and more closely ties project funding to those milestones. Language was added to clarify that the advance planning document (APD) must contain an estimated schedule of life-cycle milestones and project deliverables (modules) related to the description of estimated expenditures by category. ACF issued an addendum to the State Systems Guide that expands upon the new rule by providing guidance to the states on the contents of the APDs, the changes in requirements to the APDs, and the new level of review and monitoring that will be performed. States have now begun to submit their new APDs and APD Updates under the new requirements, and are identifying project milestones and deliverables with the related budgets. OCSE has begun to approve funding by milestone, rather than on a year-to-year basis, in accordance with the published rule.

    Recommendation: To maximize the federal government's return on costly technology investments, the Secretary of Health and Human Services should direct and ensure that the Assistant Secretary of the Administration for Children and Families develops and implements a structured approach to reviewing automation projects to ensure that significant systems development milestones are identified and that the costs of project decisions are justified during the entire effort. Each major systems phase should be reviewed and, at critical points--analysis, design, coding, testing, conversion, and acceptance--that OCSE, according to preestablished criteria, formally report to the state whether it considers the state ready to proceed to the next milestone or phase.

    Agency Affected: Department of Health and Human Services

  8. Status: Closed - Implemented

    Comments: ACF agreed with the recommendation, and has published and distributed large amounts of materials covering the welfare reform requirements and the child support enforcement systems requirements. These materials include a new regulation published in August 1998, a new certification guide, a new test deck for testing transactions in the statewide system, several policy action transmittals, technical specifications, user guides, and questions and answers regarding state systems requirements under welfare reform. Since October 1998, ACF has published a revised Guide for States on Automated Systems for Child Support Enforcement, an addendum to the State Systems APD Guide, and several additional policy and guidance documents relating to the welfare reform requirements.

    Recommendation: To maximize the federal government's return on costly technology investments, the Secretary of Health and Human Services should direct and ensure that the Assistant Secretary of the Administration for Children and Families provides the states with technical requirements for implementing welfare reform systems, including the new hire, central case, centralized collection, and disbursement registries in enough time to allow the states to meet the legislatively mandated deadlines of October 1997, 1998, and ultimately 2000.

    Agency Affected: Department of Health and Human Services

 

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