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Facilitate Data Sharing While Protecting Privacy' which was released 
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United States Government Accountability Office: 
GAO: 

Report to Congressional Requesters: 

February 2013: 

Human Services: 

Sustained and Coordinated Efforts Could Facilitate Data Sharing While 
Protecting Privacy: 

GAO-13-106: 

GAO Highlights: 

Highlights of GAO-13-106, a report to congressional requesters. 

Why GAO Did This Study: 

State and local human services agencies administer funds from various 
federal programs to help those in need-—many of whom are served by 
multiple programs. Data sharing across programs can improve 
administrative efficiencies and client service; however, some agencies 
are concerned about how to share more data while maintaining client 
privacy. GAO was asked to review issues related to data sharing. This 
report examines (1) how selected states or localities have shared data 
across programs to improve the administration of human services, (2) 
challenges state and local human services agencies face in balancing 
privacy protections with greater data sharing, and (3) actions that 
the federal government could take to help address these challenges. 
GAO reviewed relevant federal laws, regulations, and policies, 
interviewed federal officials, conducted site visits with state or 
local human services agencies in four selected states, and surveyed 40 
stakeholders from the public, private, and non-profit sectors to 
identify challenges and possible federal actions. 

What GAO Found: 

Four selected states or localities used systematic and automated data 
sharing to improve eligibility verification or case management 
processes. Such data sharing improved eligibility verification 
processes in Michigan and Utah. Specifically, program officials said 
that data sharing improved program integrity because more accurate 
payments were made, and staff noted program efficiencies through more 
automated and consolidated systems. In terms of case management, 
officials from New York City and Allegheny County, Pennsylvania said 
that data sharing helped caseworkers obtain client information more 
quickly and make more informed decisions. For instance, child welfare 
workers used client data from other agencies to quickly obtain 
background information on other household members when child 
maltreatment was reported or to locate potential caregivers when 
needed. Officials cited various factors contributing to the success of 
their initiatives, with strong leadership as the most commonly cited. 

The stakeholders GAO surveyed identified a number of challenges to 
increased data sharing related to the interpretation of federal 
privacy requirements. These included confusion or misperceptions 
around what agencies are allowed to share, as well as a tendency to be 
risk averse and overly cautious in their interpretation of federal 
privacy requirements. For example, stakeholders said an agency’s legal 
counsel may advise against sharing data as a precautionary measure 
rather than because of an explicit prohibition. Stakeholders also 
reported that potential inconsistencies in federal privacy 
requirements that apply to data sharing across multiple programs are a 
challenge. In particular, they, along with some officials at the sites 
GAO visited, noted that child welfare workers have difficulty meeting 
a federal obligation to monitor and support foster care children’s 
educational stability and performance because of the federal law 
limiting access to education records without parental consent. An 
amendment enacted on January 14, 2013, includes provisions to address 
this issue. 

To address identified challenges, stakeholders suggested that federal 
agencies could clarify federal privacy requirements and consider 
harmonizing requirements. Nearly all stakeholders GAO surveyed said 
that coordinated, multi-agency guidance that clarifies what data 
sharing is permissible would be extremely useful. They also suggested 
that developing model data sharing agreements and informed consent 
language that comply with federal privacy requirements, or providing 
existing examples, would be useful. Stakeholders also said it would be 
highly useful to reexamine requirements to ensure more consistent 
privacy rules for data sharing across human services programs and 
agencies. Federal agencies have some related efforts under way. For 
example, the Department of Health and Human Services (HHS) is 
preparing a "toolkit"-—currently under internal review-—that is 
expected to describe privacy rules among several programs as well as 
typical data sharing activities, although specific plans for its 
completion, dissemination, and follow-up have not been established. 
Also, the Office of Management and Budget (OMB) issued a 2010 
memorandum to federal agencies that encouraged sharing data while 
protecting privacy, and has efforts under way to promote data sharing 
generally. However, officials said OMB has no plans to undertake 
specific actions related to privacy requirements, such as identifying 
model data sharing agreements or other tools, citing resource 
constraints, although they acknowledged the usefulness of such tools. 

What GAO Recommends: 

GAO recommends that HHS ensure timely completion of its current work 
to clarify privacy requirements across programs, and OMB consider 
additional ways to disseminate useful data sharing practices and tools 
that address privacy requirements. HHS agreed with our recommendation. 
OMB stated in its technical comments that it already had ongoing 
efforts to promote data sharing. GAO continues to believe that OMB 
should do more in this area to specifically address privacy issues 
within existing resources. 

View [hyperlink, http://www.gao.gov/products/GAO-13-106]. For more 
information, contact Kay E. Brown at (202) 512-7215 or brownke@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Selected States and Localities Use Centralized Data Sharing Systems 
That Enhance Eligibility Verification and Case Management Processes: 

Stakeholders Identified Data Sharing Challenges Related to 
Interpretation of Federal Privacy Requirements and Organizational 
Issues: 

Stakeholders Suggest Federal Agencies Clarify Requirements and 
Consider Changes to Increase Their Consistency: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Additional Information On Selected Sites: 

Appendix II: Scope and Methodology: 

Appendix III: Delphi Survey Results: 

Appendix IV: Delphi Survey Respondents: 

Appendix V: Comments from the Department of Health and Human Services: 

Appendix VI: GAO Contacts and Staff Acknowledgments: 

Tables: 

Table 1: Benefits of Data Sharing in Key Functional Areas of Human 
Services: 

Table 2: Examples of Federal Privacy Requirements That May Apply to 
Human Services Programs: 

Table 3: Examples of How Selected Sites Use Data Sharing: 

Table 4: Challenges Identified by 35 Stakeholders That State and Local 
Human Services Agencies Face When Balancing Data Sharing with 
Protecting Personal Information: 

Table 5: Potential Federal Agency Actions Proposed by 35 Stakeholders 
to Address Challenges That State and Local Human Services Agencies 
Face Balancing Data Sharing with Protecting Personal Information: 

Table 6: Current or Planned Federal Initiatives Related to Stakeholder 
Suggestions: 

Table 7: Challenges Identified by Stakeholders Related to Federal 
Privacy Requirements (Including Federal Laws, Regulations, and Other 
Requirements): 

Table 8: Organizational and Implementation Challenges Identified by 
Stakeholders: 

Table 9: Challenges Related to Income/Wage Data Sources: 

Table 10: Potential Federal Agency Actions Suggested by Stakeholders 
to Address Challenges: Guidance and Models: 

Table 11: Potential Federal Agency Actions Suggested by Stakeholders 
to Address Challenges: Federal Requirements: 

Table 12: List of Individuals That Completed Survey Responses: 

Figure: 

Figure 1: Illustration of Allegheny County's Data Warehouse and 
Examples of Data Shared: 

Abbreviations: 

ACF: Administration for Children and Families: 

BRIMM: Bridges Information Management Mart: 

DHS: Department of Human Services: 

DWS: Department of Workforce Services: 

Education: Department of Education: 

FERPA: Family Educational Rights and Privacy Act of 1974: 

HHS: Department of Health and Human Services: 

HIPAA: Health Insurance Portability and Accountability Act of 1996: 

IDEA: Individuals with Disabilities Education Act: 

OMB: Office of Management and Budget: 

SNAP: Supplemental Nutrition Assistance Program: 

SSN: Social Security number: 

TANF: Temporary Assistance for Needy Families: 

USDA: Department of Agriculture: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

February 8, 2013: 

The Honorable Thomas Carper: 
Chairman: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The Honorable David Reichert: 
Chairman: 
Subcommittee on Human Resources: 
Committee on Ways and Means: 
United States House of Representatives: 

The Honorable Erik Paulsen: 
United States House of Representatives: 

The Honorable Tom Reed: 
United States House of Representatives: 

Each year, state and local human services agencies administer billions 
of dollars of federal funds to assist individuals and families in 
need. Because people often receive services or benefits from multiple 
programs, state and local human services agencies could better 
determine eligibility as well as coordinate the delivery of services 
if they could more easily exchange client data. Historically, however, 
programs have often delivered a relatively narrow range of services 
without sufficient information from or on other related client 
services or benefits. While various factors--including outdated 
systems that do not communicate with each other and lack of standard 
data elements[Footnote 1]--can create significant hurdles to data 
sharing, agencies may also struggle with the extent to which they can 
share increasing amounts of data while continuing to protect client 
privacy.[Footnote 2] 

Moreover, state and local human services agencies must comply with 
various privacy requirements set by laws and regulations, including 
various requirements at the federal level. Specifically, some federal 
laws, such as the Privacy Act of 1974, establish privacy requirements 
that apply across multiple programs,[Footnote 3] while other federal 
laws--including the Health Insurance Portability and Accountability 
Act of 1996 (HIPAA) and the Family Educational Rights and Privacy Act 
of 1974 (FERPA)--establish privacy requirements specific to certain 
types of information.[Footnote 4] Federal statutes and regulations 
that authorize specific human services programs as well as agency-
level policies may also impose privacy requirements. You requested 
that we examine the extent to which privacy-related issues may 
constrain human services agencies and how such issues could be 
addressed in the advent of new technologies that can enable more 
useful and efficient data sharing. 

To that end, this report provides information on the following 
questions: 

1. In what ways have selected states or localities implemented 
promising data sharing practices across programs to improve their 
administration of human services? 

2. What did stakeholders identify as challenges that state and local 
human services agencies face in balancing privacy protections with 
sharing data? 

3. What actions do stakeholders suggest the federal government take to 
address identified challenges? 

To perform this work, we conducted site visits in two states (Michigan 
and Utah) and two localities (Allegheny County, Pennsylvania and New 
York City, New York) with human services agencies that were repeatedly 
identified during our exploratory research and interviews as having 
promising data sharing efforts. Specifically, we selected sites that 
share data in order to improve eligibility verification or case 
management processes in their administration of human services. 
[Footnote 5] During our site visits, we spoke with relevant program 
and policy officials, including program administrators, information 
technology officials, and attorneys, as well as frontline staff using 
the data sharing systems in their daily work. To gather information on 
challenges and potential federal actions, we surveyed 40 stakeholders 
from various sectors: (1) state and local officials in program 
administration, information technology, and legal positions as well as 
associations representing these agencies;[Footnote 6] (2) private or 
nonprofit technology service providers; and (3) representatives from 
client advocacy groups and research organizations. We used a two-
survey iterative technique, referred to as a Delphi survey,[Footnote 
7] to gather ideas on relevant challenges and possible federal actions 
from stakeholders who were identified through our initial interviews 
and research, were members of relevant trade associations, or were 
recommended to us by other stakeholders.[Footnote 8] The first Delphi 
survey asked open-ended questions and the responses were used to 
develop the second Delphi survey, which asked the same group of 
stakeholders to rate the degree of possible challenges and the 
usefulness of possible actions. For each survey, the response rate was 
88 percent (35 of 40 people responded). In addition, to better 
understand the federal role as well as existing initiatives that may 
help address some of the challenges identified by stakeholders and 
suggested actions, we interviewed officials at the Department of 
Health and Human Services (HHS) and the Department of Agriculture 
(USDA) who oversee key human services programs, officials at the 
Department of Education (Education) who oversee FERPA, and officials 
at the Office of Management and Budget (OMB) who oversee relevant 
multi-agency initiatives. Finally, we examined relevant federal laws, 
regulations, and policy guidance, as needed. We conducted this 
performance audit from November 2011 through January 2013, in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. (See appendix 
II for more information on our scope and methodology.) 

Background: 

Data Sharing in Human Services: Eligibility Verification and Case 
Management: 

The federal government funds a wide array of programs that provide 
benefits and services to individuals, families, and households needing 
financial assistance or other forms of social support. These programs 
often involve state or local administration and vary in their purpose 
and target populations. For instance, human services programs may help 
address a family's economic situation or the needs of vulnerable 
children or adults. Some examples include: 

* Economic assistance programs: Through block grants to states, the 
Temporary Assistance for Needy Families (TANF) program, for instance, 
helps provide assistance, such as cash benefits, to eligible families, 
as well as supports to help individuals return to work, including job 
training and child care. The Supplemental Nutrition Assistance Program 
(SNAP), a federally-funded benefit program which states help 
administer, provides monthly food assistance to eligible low-income 
individuals and families. Medicaid, a joint federal-state program, 
finances health care coverage for a variety of vulnerable populations, 
including certain low-income children, families, and individuals. 
State child support enforcement programs, also supported through 
federal funds, are designed to ensure that parents financially support 
their children by locating noncustodial parents and collecting and 
distributing child support payments. 

* Programs for at-risk children and families: Various federal funding 
streams and programs, such as those administered under Titles IV-B and 
IV-E of the Social Security Act, support family preservation and child 
welfare programs. For instance, states' child welfare agencies may use 
federal funds to provide family support, family preservation, and 
family reunification services intended to assist families at risk for 
child abuse or neglect. States also receive federal funds to help 
children from low-income families or those with certain special needs 
who have been removed from their homes and are in need of temporary or 
permanent care. 

Because the range of possible services is broad and administration of 
these programs is multi-faceted, state and local human services 
agencies may use data sharing in different ways to enhance various 
functional areas (see table 1). 

Table 1: Benefits of Data Sharing in Key Functional Areas of Human 
Services: 

Key functional areas: Eligibility, enrollment, recertification; 
Description: Frontline workers collect and assess information needed 
to determine and update eligibility and benefit amounts; 
Potential benefits of data sharing: 
* Use existing data sources to prepopulate forms and reduce need for 
clients to provide the same information and documentation to multiple 
agencies; 
* Use existing reliable data sources to automate verification of 
information instead of conducting manual checks to improve payment 
accuracy and worker efficiency[A]; 
* Provide more timely updates on changes in circumstances that affect 
benefit levels, reducing need to recoup payments later; 
* Use data matching to facilitate the recertification of clients who 
continue to meet eligibility criteria. 

Key functional areas: Case management; 
Description: Caseworkers assess client needs, refer to services, and 
monitor service delivery; 
Potential benefits of data sharing: 
* Ensure caseworkers have necessary and more complete information to 
make appropriate case decisions; 
* Provide caseworkers with updated information on addresses and 
household composition, which helps them contact clients more 
efficiently; 
* Reduce demands on staff to manually look up and provide data on 
client inquiries from other agencies; 
* Provide more integrated services for families or individuals with 
complex and overlapping needs. 

Key functional areas: Program oversight and accountability; 
Description: State, local, and federal officials monitor and assess 
program administration for accuracy, efficiency, and program 
performance measures on an ongoing basis; 
Potential benefits of data sharing: 
* Conduct data matching inquiries to identify program integrity issues 
(e.g., fraud) and improve payment accuracy[A]; 
* Offer a more complete picture of how services are being provided and 
the degree to which they are effective; 
* Better understand the number and populations of clients served and 
the extent that they are accessing multiple services; 
* Monitor outcomes of participants across domains (e.g., education, 
employment or health). 

Key functional areas: Research and evaluation; 
Description: State, local, and federal officials as well as private 
researchers analyze de-identified information on caseload 
characteristics, needs, or trends as well as program outcomes; 
Potential benefits of data sharing: 
* Use administrative program information to supplement or replace data 
otherwise gathered through surveys or other research methods.[B] 
Obtain larger samples at lower costs than those obtained through 
surveys; 
* Avoid underreporting and selection biases known to be associated 
with survey responses about program participation. 

Source: GAO analysis. 

Note: This report looks particularly at how data sharing has been used 
in eligibility verification and case management processes for human 
services. 

[A] For example, see GAO, Improper Payments: Moving Forward with 
Governmentwide Reduction Strategies, GAO-12-405T (Washington, D.C.: 
Feb. 7, 2012). 

[B] For example, see GAO, Federal Statistical System: Agencies Can 
Make Greater Use of Existing Data, but Continued Progress Is Needed on 
Access and Quality Issues, GAO-12-54 (Washington, D.C.: Feb. 24, 2012). 

[End of table] 

Regarding eligibility verification, a family and its members may apply 
for or receive assistance from multiple human services programs, but 
each program may use a separate eligibility verification process. 
While many states have combined eligibility verification processes for 
certain programs (including TANF, SNAP, and Medicaid),[Footnote 9] to 
apply for other supports, such as housing assistance or disability 
benefits, a client may have to provide the same basic personal and 
financial information and documentation multiple times.[Footnote 10] 
Reducing duplicative processes, such as by sharing common eligibility 
information through increased automation, can lower program costs. 
Additionally, benefits from public assistance programs may be counted 
as unearned income by other programs, which supports the need for 
timely and accurate data sharing across programs. It can also improve 
program integrity through reduced improper payments by validating 
initial or ongoing eligibility information with data from other 
databases considered reliable--instead of depending solely on client 
provided documentation.[Footnote 11] In the past decade, the federal 
government has paid greater attention to the problem of improper 
payments, as evidenced by the enactment of the Improper Payments 
Information Act of 2002 and subsequent amending legislation.[Footnote 
12] 

Regarding case management, data sharing can help program staff provide 
integrated case management, in a more systematic way, for families 
with overlapping and complex service needs. For instance, the family 
of a child placed in foster care may interact with other social 
service systems, including substance abuse or mental health treatment, 
juvenile justice, schools, courts, health care, and housing. Over the 
years, greater emphasis has been placed on providing a more 
coordinated approach to serve families with multiple needs.[Footnote 
13] However, information about these families may be maintained in 
different files or systems across different agencies and, in order to 
provide an integrated approach, caseworkers may be faced with the 
difficult task of piecing together this information through 
inefficient or ad hoc means. Accordingly, more systematic data sharing 
can provide workers with more complete information and enhance the 
ability of agencies and other service providers to coordinate care. 

Federal Privacy Requirements: 

Collectively, human services agencies obtain a great deal of personal 
information from their clients that, if not properly protected, could 
be vulnerable to wrongful use or disclosure.[Footnote 14] Accordingly, 
various laws and regulations, including those at the federal level, 
have established requirements that protect individuals' privacy, such 
as requiring that safeguards be put in place to ensure that only 
authorized individuals are able to view specific pieces of 
information. For instance, certain federal laws, and their 
corresponding regulations and guidance, establish privacy protections 
for certain types of personal information, such as health or education 
records (see examples in table 2). Additionally, the federal statute 
authorizing a specific program may also include provisions that 
prescribe when a state agency can or cannot share data related to 
administering that program. For instance, the statute authorizing the 
TANF program requires that states outline how they will restrict the 
use and disclosure of information about individuals and families 
receiving assistance from federal funds.[Footnote 15] The statute 
authorizing federal assistance for state child support enforcement 
programs generally requires that states establish safeguards to 
protect the privacy of the parties involved, but also requires that 
the state agency use an automated system to share data as necessary 
with its state counterparts that administer TANF and Medicaid. 
[Footnote 16] Finally, although not covered in this report, states may 
have their own laws or policies that affect the use and sharing of 
personal information in human services programs. 

Table 2: Examples of Federal Privacy Requirements That May Apply to 
Human Services Programs: 

The Privacy Act of 1974 (Privacy Act) protects individually-
identifiable records maintained by federal executive agencies and 
retrieved using a name or other individual identifier. Generally, 
federal agencies are prohibited from disclosing such records without 
the written consent of the individual to whom the record pertains. The 
Privacy Act identifies several exceptions to this requirement, 
including "routine use" that is compatible with the purpose for which 
the record was collected. State and local agencies must comply with 
certain Privacy Act requirements when they electronically match their 
records with those of a federal agency. 
5 U.S.C. § 552a. Federal agencies adopt their own regulations to 
implement the Privacy Act. 

Regulations implementing the Health Insurance Portability and 
Accountability Act of 1996 (HIPAA) require the protection of 
individually identifiable health information, including information 
about a person's physical or mental health or condition, treatment, or 
payment for services. These requirements generally apply to health 
plans, health care clearinghouses, and those health care providers 
that electronically transmit health information in connection with 
certain health care transactions. The regulations require appropriate 
safeguards and set limits and conditions on the uses and disclosures 
that may be made of such information without patient authorization. 
Information may be disclosed without authorization in specified 
circumstances--including for certain treatment, payment, and health 
care operations--and must be disclosed to individuals upon their 
request or to HHS for compliance or enforcement purposes. 
See generally 42 U.S.C. §§ 1320d to 1320d-9, 45 C.F.R. parts 160 and 
164 (subparts A and E). 

To be eligible for federal funding under programs administered by the 
Department of Education, the Family Educational Rights and Privacy Act 
of 1974 (FERPA) requires that educational agencies and institutions 
take certain steps with respect to student education records. Parents 
must have the right to inspect and review their children's education 
records. Generally, schools and educational agencies must obtain 
written consent from the parent in order to release information from a 
student's education record. Schools may disclose, without parental 
consent, "directory information" including a student's name, address, 
telephone number, date and place of birth, degrees and awards, and 
dates of attendance, provided they give public notice of these 
categories and a reasonable opportunity for parents to opt out of 
allowing schools to release this information. FERPA also authorizes 
schools to disclose education records without parental consent to 
specifically enumerated parties or under certain circumstances, 
including pursuant to a court order. 
20 U.S.C. § 1232g, see generally 34 C.F.R. part 99. 

Section 523 of the Public Health Service Act and its implementing 
regulations (codified at 42 C.F.R. Part 2), restrict the disclosure 
and use of alcohol and drug abuse patient records maintained in 
connection with federally-assisted substance abuse programs. 
Information may be disclosed without patient consent only in specific 
circumstances, such as medical emergencies. 
42 U.S.C. § 290dd-2, see generally 42 C.F.R. part 2. 

States receiving grants under the Child Abuse Prevention and Treatment 
Act must have methods in place to preserve the confidentiality of all 
records and reports of child abuse and neglect in order to protect the 
rights of the child and the child's parents or guardians, and must 
limit the availability of records only to specifically enumerated 
people or entities. 
42 U.S.C. § 5106a, 45 C.F.R. §§ 1340.14(i), 1340.20. 

Section 6103 of the Internal Revenue Code prohibits disclosure of tax 
returns and return information except in specifically enumerated 
circumstances. Where disclosure is permitted, section 6103 generally 
imposes safeguarding requirements and requires the IRS to monitor 
compliance with those requirements. The requirements apply to federal 
agencies as well as state and local agencies and others who have 
lawfully received taxpayer information from the IRS. 
26 U.S.C. § 6103, 26 C.F.R. §§ 301.6103(a)-1 to 301.6103(p)(7)-1. 

Source: GAO review of selected federal laws and regulations. 

Note: This table is for illustrative purposes only and is not intended 
to provide a comprehensive list of all federal privacy requirements 
that apply to human services programs. In addition, the description of 
each requirement provides only a general summary; additional 
provisions may apply that are not described in this table. 

[End of table] 

Selected States and Localities Use Centralized Data Sharing Systems 
That Enhance Eligibility Verification and Case Management Processes: 

Human services agencies we visited in two selected states (Michigan 
and Utah) and two selected localities (Allegheny County and New York 
City) use central systems to share client data. Officials at these 
locations cited improved payment accuracy and greater program 
efficiencies as some of the benefits of their respective data sharing 
systems. Among the various factors that have contributed to the 
success of the data sharing initiatives, strong leadership support was 
the most commonly cited. 

Selected Sites Use a Central Repository or Portal to Give Specified 
Workers Access to Data from Various Sources: 

The data sharing systems in each of the four selected sites provided 
specified workers with automatic access to certain client information, 
such as demographics or services received from other departments or by 
family members. Although each site's data sharing system was distinct, 
they shared some common elements: 

* Central repository or portal: With a central repository, as used in 
Michigan and Allegheny County, data from various source agencies are 
collected, copied, and stored in one central location, such as a "data 
warehouse," and information is refreshed on a regular basis. With a 
central portal, as used in Utah and New York City, users can view data 
from multiple systems through one point of entry, but the data are not 
copied or stored separately from their original sources. See figure 1 
for an illustration of how data are shared through a data warehouse 
system, such as in Allegheny County. For a description of each site's 
data sharing system, see appendix I. 

* Interfaces with external parties other than human service agencies: 
Data sources may include other government entities, such as schools, 
courts, state treasury departments, and motor vehicle departments. For 
example, eligibility workers from Utah's Department of Workforce 
Services can access car registration and lien information from the 
state's Department of Motor Vehicles to assess a client's assets when 
determining eligibility for program benefits. 

* Common identifier to match client records: The four sites used 
different means to match client records across different data systems, 
including assigning clients a unique client index number across 
programs, searching on Social Security numbers (SSN),[Footnote 17] or 
employing algorithms based on a collection of key client demographic 
elements. For instance, to match client records across different data 
systems, New York City's system generates a common index number for 
each client using algorithms based on certain demographic information 
(e.g., full name, mailing and residential addresses, and date of 
birth.) 

* Role-based access: At these four sites, users are granted access 
only to information that is needed to perform their job function, as 
agreed upon in advance, and that they are legally authorized to 
access.[Footnote 18] For instance, New York City's data sharing 
initiative involved a lengthy process with program officials, 
department attorneys, and others to determine exactly what information 
34 different user groups would have access to, for what business 
purpose, and under what legal authority, according to city officials. 
Officials at all four sites also used various security measures to 
control access to sensitive information, such as user training, 
password-protected screens, and audit trails to track which 
individuals have accessed databases or to flag excessive use. 

* Data sharing agreements: All four sites had multiple data sharing 
agreements in place to outline exactly what data will be shared, with 
whom, how, and for what purpose. Allegheny County's Department of 
Human Services, for instance, has a data sharing agreement in place 
with multiple external government entities. It most recently 
established one with Pittsburgh Public Schools to share data on 
students who are receiving services in order to offer these students 
additional assistance, if needed, and help them to achieve better 
educational outcomes. 

Figure 1: Illustration of Allegheny County's Data Warehouse and 
Examples of Data Shared: 

[Refer to PDF for image: illustration] 

Allegheny County Data Warehouse: 

Examples of types of data shared: 

All sources include client demographics, service history, provider 
information, and cost. 

Allegheny County DHS data sources: 

Child Welfare[A]: 
* Children in protective custody; 
* Family services received by the family or household members; 
* Family court activity. 

Behavioral Health and Intellectual Disability[A]: 
* Clients receiving mental health and substance abuse services, and 
information about these services for county and Medicaid funded 
programs; 
* Clients with intellectual disabilities receiving support services. 

Aging Services: 
* Senior clients receiving nursing home prevention, senior center 
services, or elder care. 

Community Services[A]: 
* Clients receiving rental or homeless assistance; 
* Clients receiving jail reentry support; 
* Clients receiving Head Start or family support center services. 

Outside DHS: 

Public Schools[A]: 
* Student directory information; 
* Performance and attendance information for certain students; 
* Four districts: Pittsburgh, Clairton, Woodland Hills, Elizabeth 
Forward. 

State and local correction agencies: 
* Incarceration history of clients; 
* Current status of release or sentencing for a client. 

City and County government housing authorities: 
* Clients currently receiving low income housing assistance. 

Pennsylvania Department of Public Works: 
* Recipients of TANF, SNAP or Social Security Disability Insurance. 

[A] Data exchange is two way and source agencies also use certain data 
shared through the system. The graphic shows examples of data provided 
by agencies but does not depict what data each agency receives or how 
data are used. 

Source: GAO analysis based on information collected from Allegheny 
County officials. 

Note: GAO did not evaluate this system for compliance with any 
applicable laws or regulations. 

[End of figure] 

Data Sharing Was Used to Improve Eligibility Verification and 
Caseworker Efficiency at the Four Selected Sites: 

According to officials, data sharing improved eligibility verification 
processes in Michigan and Utah and case management processes in New 
York City and Allegheny County. For instance, the data sharing systems 
of the two selected states were built, at least in part, with the 
purpose of reducing error rates in payments made for SNAP or Medicaid 
programs. Officials from Michigan and Utah told us that their data 
sharing systems have improved program integrity through more accurate 
benefit payments. As we have reported in prior work, strong preventive 
controls, such as validating initial eligibility through data sharing, 
remain the frontline defense in reducing improper payments.[Footnote 
19] State officials also said that data sharing systems have improved 
program efficiencies by reducing the need for staff to manually search 
or ask for documentation needed to verify eligibility. For example, 
according to officials we interviewed in Utah, the process of checking 
other data sources to verify eligibility information was reduced from 
17 minutes to 3 minutes, allowing staff to manage higher caseloads. In 
addition, caseworkers in the two localities we visited said that 
automated access to data on demographics, family members, and service 
history has facilitated their ability to make timely and informed 
decisions for families or individuals in need. Finally, officials at 
three sites we visited noted a reduced burden on staff in responding 
to information requests from other agencies as another benefit to 
automated data sharing. Table 3 includes additional information on 
ways that the selected sites used data sharing to facilitate 
eligibility verification or case management processes. For a better 
understanding of how data are shared at each site we visited, 
including detailed information on the characteristics, goals, and data 
providers and users of each site's system, see appendix I. 

Table 3: Examples of How Selected Sites Use Data Sharing: 

Site and type of worker: Michigan: Department of Human Services' 
eligibility worker; 
Ways data sharing is used to improve eligibility verification 
processes: 
Job function: Eligibility workers in the Department of Human Services 
determine eligibility for several human service programs, including 
TANF, SNAP, and Medicaid. Since 2010, local offices have used a data 
sharing management tool --the Bridges Information Management Mart 
(BRIMM) - to access data from the state's Enterprise Data Warehouse. 
The warehouse stores client data from various state systems. 
Eligibility workers can then access this data, which is refreshed on a 
nightly basis, to determine eligibility and monthly benefit amounts 
for public assistance programs; 
Type of data used: Data used to determine benefits include payroll or 
unemployment data, income sources such as receipt of other benefits 
and lottery winnings, family composition information, and client 
demographics; 
Stated benefits: Officials reported that BRIMM has helped: 
* Improve the speed of eligibility determinations, as all case history 
and demographic information are available online in one place. Before 
BRIMM, caseworkers needed to review both printed and electronic 
information from multiple data sources. In particular, 
redeterminations are done more quickly since summary information 
across multiple benefit programs is consolidated. A report from 
Michigan's Department of Technology, Management, and Budget noted that 
since local offices of the Department of Human Services began using 
BRIMM, benefit redeterminations are 50 percent faster for each 
individual case; 
* Streamline client service. Clients now deal with one caseworker 
across programs and can complete redeterminations after a single 
interview instead of multiple ones. 

Site and type of worker: Utah: Department of Workforce Services' 
eligibility worker; 
Ways data sharing is used to improve eligibility verification 
processes: 
Job function: Department of Workforce Services eligibility workers 
access multiple data sources through eFind to verify information on a 
client's benefit application. People seeking benefits from programs, 
such as SNAP, Medicaid TANF or child care assistance, often submit 
applications online, which may include incomplete information; 
Type of data used: Eligibility workers access links to: vital records, 
including birth certificates or death records, from the Department of 
Vital Statistics; real-time wage information captured by private 
vendors; car registration and lien information from the state 
Department of Motor Vehicles; and possible sources of other unearned 
income, including child support payments or income as a child care 
provider; 
Stated benefits: Eligibility workers and officials we interviewed said 
that the system has helped to: 
* Reduce the amount of documentation the client must submit. For 
example, clients may not have to submit pay stubs if eFind has timely 
wage and employment information; 
* Make the eligibility verification process more uniform and user 
friendly. It has consolidated data from disconnected systems to 
provide useful eligibility information. For example, a worker is able 
to assess a client's assets by looking to see if he or she has a 
registered vehicle, the value of that vehicle, and the likelihood that 
the vehicle is actually the client's based on other demographic 
information, in one screen; 
* Reduce the chance of improper payments because eligibility 
verification using external data sources is easier and more automated. 
With eFind and Department of Workforce Services' more recent move to 
prepopulate applications with externally validated data, there is less 
need to rely on self-reported information from the client and fewer 
chances for staff to make manual transcription errors. 

Site and type of worker: Allegheny County: Department of Human 
Services' child welfare intake worker; 
Ways data sharing is used to improve eligibility verification 
processes: 
Job function: When responding to a call regarding potential 
maltreatment, a child protective services intake worker may look up 
information on a person, child, or family in the data warehouse system; 
Type of data used: According to officials, the data warehouse has 
increased the amount of client information intake workers have at 
their disposal. This information can help them identify whether the 
reported person or another member of the family or household has 
received other government services, such as behavioral health, or has 
a criminal history. Intake workers are able to access demographic 
information collected by other departments, such as the state 
Department of Public Welfare that administers the TANF and SNAP 
programs. Such information may include an exact address or alternative 
addresses, or names and information on other household members, 
relatives, or noncustodial parents; 
Stated benefits: Intake workers we interviewed said that the system 
has helped to: 
* Speed up their ability to get information on a family when limited 
or inaccurate information is provided at intake, including the 
location of reported maltreatment or the full name of the reported 
person; 
* Probe in their questioning with a client who may not always be 
forthcoming; 
* Manage their time, such as by knowing who else is living in the 
house and who they need to interview before conducting a home visit; 
* Ensure their own safety because they have better background 
information on household members before making the home visit (e.g., 
information on criminal history or mental health status); 
* Search for and contact potential relative caregivers. 

Site and type of worker: New York City: Health and Hospital 
Corporation's financial counselor; 
Ways data sharing is used to improve eligibility verification 
processes: 
Job function/process: Financial counselors often work with patients 
visiting the corporation's facilities (e.g., hospitals, acute care 
facilities) that come in without any proof of identification, 
residence, or citizenship. Counselors must work with them to determine 
if they are eligible for Medicaid or other health insurance programs; 
Types of data used: Counselors access basic information through a 
system called Worker Connect such as most recent address, birth date, 
previous Medicaid status, and family composition; 
Stated benefits: Officials we interviewed said that the system has 
helped their workers: 
* Save time that they would otherwise spend with the client or with 
other agencies tracking down information (e.g., obtaining a birth 
certificate or determining Medicaid status); 
* Better serve a transient population that often has behavioral health 
issues and precarious housing situations. Clients do not always have 
needed documentation on them, nor are they always able to clearly 
describe their history or situation. 

Source: GAO analysis based on information collected from state and 
local officials at each site. 

[End of table] 

Several Factors Have Contributed to the Success of Data Sharing 
Efforts at the Selected Sites: 

While officials we interviewed at all four sites said that they faced 
and continue to face a number of challenges in developing and 
expanding their data sharing systems, they noted several factors that 
have contributed to the success of their data sharing efforts. (See 
the following section for further discussion on challenges.) These 
included strong leadership and support by both internal and external 
stakeholders, the organizational structure of the agency, financial 
support or seed funding, and a legal review or analysis. 

* Strong leadership and support: Strong leadership and support for 
data sharing as a way to achieve critical policy goals and priorities 
was the most common factor cited by officials at each site we visited. 
In Utah, state officials told us that data sharing was supported by 
the Governor, and they noted their department's ongoing willingness to 
try new things and take risks. According to New York City officials, 
their initiative was led by the Deputy Mayor, who established an 
Executive Steering Committee that consisted of Commissioners from all 
of the agencies involved--that would provide and use the data--to 
promote buy-in and leadership support for sharing data across multiple 
agencies. 

* Organizational structure: Officials at two sites told us that having 
an organizational structure that houses multiple human services 
programs under one agency makes sharing data easier. For instance, 
Utah officials said that sharing is easier because there is more trust 
that everyone in the department is under the same controls, standards, 
and protocols regarding oversight and data security. 

* Financial support or seed funding: Funding to initially develop the 
systems was also cited as a factor that contributed to the success of 
data sharing. In Allegheny County, according to officials, seed 
funding from the local foundation community helped support the initial 
development of the County's data warehouse without relying exclusively 
on the Department of Human Services' resources. A coalition of 12 
local foundations came together to create the Human Services 
Integration Fund, which provided the necessary funding to start the 
data warehouse and has supported periodic improvements. Utah's system 
was created because USDA had sanctioned the state for high payment 
error rates in its food assistance program, according to state 
officials. As part of Utah's plan to reduce error rates, state 
officials told us that USDA allowed the state to reinvest the 
sanctioned funds to build an eligibility verification system. 
[Footnote 20] 

* Legal review and analysis: We also heard that the use of outside 
legal experts or the establishment of legal workgroups to review 
privacy requirements across programs was instrumental in developing 
data sharing agreements. For instance, Allegheny County officials said 
that consulting with an attorney who was considered a national expert 
in these areas was invaluable. Similarly, New York City officials told 
us that their initiative relied on interagency groups comprised of 
policy and legal staff to assess the city's authority to collect, use, 
and share personal data among agencies. 

In addition to these contributing success factors, officials from a 
few sites also emphasized that successful data sharing takes time to 
implement and execute. For instance, program officials in Allegheny 
County told us that the data sharing agreement with the public school 
district, alone, took 18 months to develop, and their data warehouse, 
which started with one data source, has incrementally added other 
sources over a span of years. 

Stakeholders Identified Data Sharing Challenges Related to 
Interpretation of Federal Privacy Requirements and Organizational 
Issues: 

The stakeholders from state and local human services agencies, 
information technology providers, and research and advocacy 
organizations we surveyed identified a number of challenges that state 
and local human services agencies face as they balance the need to 
protect clients' personal information while increasing the use of data 
sharing. The challenges identified fell into two main categories: (1) 
challenges related to federal privacy requirements, and (2) 
organizational and implementation challenges (see table 4). The top 
three items identified as extreme or great challenges by the highest 
number of stakeholders were related to federal privacy requirements. 

Table 4: Challenges Identified by 35 Stakeholders That State and Local 
Human Services Agencies Face When Balancing Data Sharing with 
Protecting Personal Information: 

Confusion or misperceptions around what agencies are or are not 
allowed to share[A]: 
Number of stakeholders who rated each of the following an "extreme 
challenge" or "great challenge" (% of 35 stakeholders): 32 (91%). 

Agencies may be overly cautious and interpret federal privacy 
requirements more narrowly than necessary[A]: 
Number of stakeholders who rated each of the following an "extreme 
challenge" or "great challenge" (% of 35 stakeholders): 29 (83%). 

Federal privacy requirements that govern data sharing are inconsistent 
across multiple programs[A]: 
Number of stakeholders who rated each of the following an "extreme 
challenge" or "great challenge" (% of 35 stakeholders): 24 (69%). 

Agencies have outdated technology systems that are unable to share 
data securely[B]: 
Number of stakeholders who rated each of the following an "extreme 
challenge" or "great challenge" (% of 35 stakeholders): 23 (66%). 

Data sharing agreements between agencies are cumbersome to 
establish[B]: 
Number of stakeholders who rated each of the following an "extreme 
challenge" or "great challenge" (% of 35 stakeholders): 21 (60%). 

Past practice has created a mindset or culture that agencies should 
not share data[B]: 
Number of stakeholders who rated each of the following an "extreme 
challenge" or "great challenge" (% of 35 stakeholders): 20 (57%). 

Agencies may not always be aware of the capacity of technology to 
protect personal information[B]: 
Number of stakeholders who rated each of the following an "extreme 
challenge" or "great challenge" (% of 35 stakeholders): 20 (57%). 

Agencies do not provide sufficient training to workers on allowable 
sharing[B]: 
Number of stakeholders who rated each of the following an "extreme 
challenge" or "great challenge" (% of 35 stakeholders): 20 (57%). 

Agencies are not always sure when client consent is required to share 
data[A]: 
Number of stakeholders who rated each of the following an "extreme 
challenge" or "great challenge" (% of 35 stakeholders): 20 (57%). 

Federal privacy requirements about sharing data with third parties 
(e.g., non-profit service providers) are overly restrictive[A]: 
Number of stakeholders who rated each of the following an "extreme 
challenge" or "great challenge" (% of 35 stakeholders): 18 (51%). 

Agencies may not trust that other agencies will sufficiently protect 
shared data[B]: 
Number of stakeholders who rated each of the following an "extreme 
challenge" or "great challenge" (% of 35 stakeholders): 18 (51%). 

Security standards for sharing and storing data are inconsistent[A]: 
Number of stakeholders who rated each of the following an "extreme 
challenge" or "great challenge" (% of 35 stakeholders): 15 (43%). 

Agencies tend to adopt data sharing agreements that are too specific 
and do not allow for flexibility[B]: 
Number of stakeholders who rated each of the following an "extreme 
challenge" or "great challenge" (% of 35 stakeholders): 15 (43%). 

Public perception regarding sharing personal information deters 
agencies from sharing data[B]: 
Number of stakeholders who rated each of the following an "extreme 
challenge" or "great challenge" (% of 35 stakeholders): 14 (40%). 

Agencies are hesitant to use clients' Social Security numbers to match 
data across systems[B]: 
Number of stakeholders who rated each of the following an "extreme 
challenge" or "great challenge" (% of 35 stakeholders): 13 (37%). 

Agencies are concerned about the accuracy of data from other 
agencies[B]: 
Number of stakeholders who rated each of the following an "extreme 
challenge" or "great challenge" (% of 35 stakeholders): 11 (31%). 

[A] Challenges related to federal privacy requirements: 

[B] Organizational and implementation challenges: 

Source: GAO analysis of responses from the second of two surveys to 
the same group of stakeholders. 

Note: Stakeholders rated challenges on a 5-point scale from "extreme 
challenge" to "not a challenge." 

[End of table] 

Interpretation of Federal Privacy Requirements and Inconsistencies Are 
Significant Challenges, According to Stakeholders: 

The challenges stakeholders identified relating to federal privacy 
requirements primarily concern the understanding or interpretation of 
these requirements. With the exception of a specific concern regarding 
FERPA, stakeholders did not consistently identify individual laws or 
regulations as overly restrictive;[Footnote 21] rather, the challenges 
they identified relate to how the federal requirements are understood 
and applied by state and local agencies and how they interact across 
programs. 

We found that some of the challenges discussed here are inter-related 
and may also reinforce each other. For example, confusion about what 
data may be shared and whether the different federal privacy 
requirements are consistent were both identified as challenges. Not 
only are they inter-related, but they may contribute to the cautious 
interpretation of requirements by state and local agencies--another 
challenge that was identified by the stakeholders. The items related 
to federal privacy requirements that were identified as challenges by 
the highest number of stakeholders (as shown in table 4) are described 
in more detail below, including illustrative examples drawn from 
stakeholder comments:[Footnote 22] 

* Confusion or misperceptions around what agencies are or are not 
allowed to share was identified as an extreme or great challenge by 32 
of 35 stakeholders. For example, many stakeholders commented that 
state and local agencies may cite privacy requirements in general as a 
reason not to share data, but may not be familiar with the actual 
scope of the specific privacy laws at issue. Several of these 
stakeholders noted further that agencies may assume that laws or 
regulations do not permit them to share data when no actual 
prohibitions exist. Several stakeholders also noted that human 
services agencies are subject to multiple privacy requirements and may 
not always understand which are applicable to a particular situation. 
As one stakeholder noted, "It is challenging to understand what 
information may be shared with whom when four or five confidentiality 
laws may be applicable at the same time." 

* Agencies may be overly cautious and interpret federal privacy 
requirements more narrowly than necessary was identified as an extreme 
or great challenge by 29 of 35 stakeholders. According to several 
stakeholder comments, state and local agencies may decide not to share 
data based on advice from their legal departments, which may be based 
on a desire to minimize the risks associated with client data being 
shared improperly rather than due to a prohibition in law or policy. 
One stakeholder said that "a great deal of practice is based on 
avoiding risk and taking what is assumed to be a safe course without 
any necessary connection to the original policies' requirements or 
intentions." Several stakeholders stressed the importance of 
protecting personal information, but were concerned that "the 
overzealous interpretation of privacy and confidentiality laws" may 
negatively impact agencies' ability to provide services. Agency 
officials we visited who manage New York City's data sharing 
initiative explained that attorneys at the different departments they 
worked with were initially hesitant to allow their data to be shared. 
Only after a rigorous process of reviewing all the relevant laws and 
regulations did the attorneys determine that sharing for the specific 
purposes identified was permissible. 

* Federal privacy requirements that govern data sharing are 
inconsistent across multiple programs was identified as an extreme or 
great challenge by 24 of 35 stakeholders. In their comments, 
stakeholders generally did not identify specific inconsistencies in 
federal privacy requirements. Rather, several stakeholders cited as a 
challenge the combination of many separate requirements for human 
services programs and a lack of clarity about how they interact. One 
stakeholder noted: "There is a curious mix of enabling and inhibiting 
legislation in the areas of confidentiality and privacy. There are 
identified rules for data sharing and there are protections for 
privacy but these are not well aligned and often are governed by the 
requirements of services to a specific population such as the 
homeless, or victims of domestic violence, child welfare, healthcare, 
behavioral health, education, etc. They do not coexist in alignment 
and often work against each other." 

The one specific federal law that many stakeholders and officials in 
localities we spoke to identified as creating a challenge was FERPA. 
[Footnote 23] Under Title IV-E of the Social Security Act, state child 
welfare agencies are required to include in the case plan the 
education records of the child, including the child's grade-level 
performance and school record, among other information.[Footnote 24] 
Congress expanded these requirements with the enactment of the 
Fostering Connections to Success and Increasing Adoptions Act of 2008, 
which gave states additional responsibilities for monitoring the 
education of children in foster care, but did not provide child 
welfare agencies with additional access to education records.[Footnote 
25] According to several stakeholders, the available options for child 
welfare agencies to obtain education records under FERPA, including 
parental consent or court order, were difficult and time consuming, 
and the limitations on the agencies' access to records could 
negatively affect their ability to make timely decisions for children 
in care.[Footnote 26] For instance, one stakeholder noted that in 
instances when a child first enters the child welfare system, 
caseworkers may have faced delays in obtaining education records that 
they needed to determine an appropriate living and school placement 
for the child. She further noted that this delay, in some 
jurisdictions, could have resulted in a child being forced to sit out 
of school for a period of time. Experts we interviewed noted that a 
delay of even a few days can be harmful when children are 
transitioning in and out of schools and can affect child welfare 
workers' ability to meet goals around school stability. Similarly, 
officials we interviewed in Allegheny County and New York City cited 
FERPA as a challenge and noted that their child welfare agencies had 
experienced difficulty accessing records to monitor the educational 
status of children in foster care. 

Stakeholders Also Identified Organizational Challenges: 

Stakeholders also identified organizational and implementation 
challenges to balancing increased data sharing with the protection of 
clients' personal information. These challenges may apply to data 
sharing in general; however, for this study, stakeholders focused on 
the facets of these issues that relate to privacy protections. For 
example, outdated technology systems may be a barrier to data sharing 
for multiple reasons, but stakeholders discussed the implications for 
privacy protections. 

As with the prior category of challenges, these organizational 
challenges are likely to be inter-related. For example, data sharing 
agreements may be more cumbersome to establish when workers operate in 
a culture that is wary of sharing data, and outdated technology 
systems may contribute to skepticism that data can be shared securely. 
The items related to organizational and implementation issues that 
were identified as challenges by the highest number of stakeholders 
are described in more detail below, including illustrative examples 
from stakeholder comments: 

* Agencies have outdated technology systems that are unable to share 
data securely was identified as an extreme or great challenge by 23 of 
35 stakeholders. For example, many stakeholders commented that the 
information technology infrastructure of state and local human 
services agencies poses a challenge to data sharing efforts. More 
specifically, several stakeholders suggested that outdated technology 
systems, often referred to as legacy systems, raise privacy concerns 
because they cannot share client data securely in the way that modern 
systems can. A few stakeholders noted that these systems were not 
built with data sharing in mind, and one stakeholder said they may not 
be able to perform important functions related to privacy protection, 
such as allowing certain users access to only a specific subset of 
information. One stakeholder said that the slow pace of information 
technology innovation in public sector human services has inhibited 
agencies from deploying tools that facilitate appropriate data sharing 
while also protecting personal information. 

* Data sharing agreements between agencies are cumbersome to establish 
was identified as an extreme or great challenge by 21 of 35 
stakeholders. For example, several stakeholders commented that 
negotiating data sharing agreements may be difficult, time consuming, 
require the participation of many parties, or suffer from a lack of 
standard models. According to one stakeholder, "The process of getting 
agencies and individual entities (such as schools) on board and 
getting to data-sharing agreements is so exhausting that the effort 
just dies." Additionally, a few stakeholders, as well as officials we 
spoke with in Michigan, noted that when data sharing arrangements are 
negotiated, they may be too narrow to allow for future uses of the 
data for similar purposes. According to Michigan officials, if the 
agencies involved later decide they want to add a few additional data 
elements, they must establish a new agreement, which slows down the 
process. They further noted that Michigan's human services agency has 
more than 180 separate data sharing agreements in place, and 
establishing and maintaining these agreements is time consuming. 

* Past practice has created a mindset or culture that agencies should 
not share data was identified as an extreme or great challenge by 20 
of 35 stakeholders. For example, several stakeholders commented that 
human services agencies have traditionally operated in independent 
"silos" and developed cultures that do not promote data sharing. One 
stakeholder said that workers at human services agencies believe that 
they cannot share information and that their agency will be punished 
in some way if they share such information. Officials at sites we 
visited also identified agency culture as a challenge. For example, 
officials in Allegheny County said that workers at human services 
agencies may have grown accustomed to not sharing data over many years 
and fear violating privacy requirements. One official said there had 
been a tendency not to share data and use privacy requirements as an 
excuse rather than fully explore possibilities. 

Stakeholders Suggest Federal Agencies Clarify Requirements and 
Consider Changes to Increase Their Consistency: 

Stakeholders we surveyed suggested actions that federal agencies could 
take to address the challenges that state and local agencies face in 
balancing increased data sharing with the need to protect personal 
information. The proposed federal actions fell into two broad 
categories: (1) those related to providing additional information, 
including guidance and models, and (2) those related to re-examining 
federal privacy requirements. Overall, stakeholders rated many of 
these proposed actions as highly useful, with a large majority of 
stakeholders rating nearly all of the actions as "extremely useful" or 
"very useful" (see table 5). Coordinated multi-agency guidance was the 
highest rated proposed action, with 30 of 35 stakeholders rating it 
"extremely useful." In addition, some federal agencies have already 
taken some actions suggested by stakeholders we surveyed, and, 
according to federal officials, plan to pursue others. 

Table 5: Potential Federal Agency Actions Proposed by 35 Stakeholders 
to Address Challenges That State and Local Human Services Agencies 
Face Balancing Data Sharing with Protecting Personal Information: 

Provide coordinated multi-agency guidance that clarifies what data 
sharing is permissible[A]: 
Number of stakeholders who rated each of the following actions as 
"extremely useful" or "very useful": (% of 35 Stakeholders): 32 (91%). 

Develop model or provide existing examples of data sharing agreements 
that comply with federal privacy requirements[A]: 
Number of stakeholders who rated each of the following actions as 
"extremely useful" or "very useful": (% of 35 Stakeholders): 32 91%). 

Develop model or provide existing examples of informed consent 
language (including possibilities for "opt out" provisions) that 
complies with federal privacy requirements[A]: 
Number of stakeholders who rated each of the following actions as 
"extremely useful" or "very useful": (% of 35 Stakeholders): 32 (91%). 

Review and harmonize non-statutory requirements to ensure more 
standardized privacy rules for data sharing across human services 
programs and agencies[B]: 
Number of stakeholders who rated each of the following actions as 
"extremely useful" or "very useful": (% of 35 Stakeholders): 32 (91%). 

Review non-statutory privacy requirements across human services 
programs to ensure rules are appropriate for current available 
technologies[B]: 
Number of stakeholders who rated each of the following actions as 
"extremely useful" or "very useful": (% of 35 Stakeholders): 32 (91%). 

Continue or increase the provision of funds for pilots and 
demonstration projects for data sharing, including those that address 
privacy-related challenges[A]: 
Number of stakeholders who rated each of the following actions as 
"extremely useful" or "very useful": (% of 35 Stakeholders): 32 (91%). 

Provide guidance from individual federal agencies that clarifies what 
data sharing is permissible for the programs the agency administers[A]: 
Number of stakeholders who rated each of the following actions as 
"extremely useful" or "very useful": (% of 35 Stakeholders): 30 (86%). 

Revise FERPA to ensure child welfare agencies have access to education 
records (or recommend Congressional action if necessary)[B]: 
Number of stakeholders who rated each of the following actions as 
"extremely useful" or "very useful": (% of 35 Stakeholders): 29 (83%). 

Communicate that the federal agency views data sharing as beneficial 
to the administration of human services programs[A]: 
Number of stakeholders who rated each of the following actions as 
"extremely useful" or "very useful": (% of 35 Stakeholders): 28 (80%). 

Create consistent standards for data security across programs and 
agencies[B]: 
Number of stakeholders who rated each of the following actions as 
"extremely useful" or "very useful": (% of 35 Stakeholders): 28 (80%). 

Identify and publicize examples of state and local agencies that have 
successfully addressed privacy-related challenges to data sharing[A]: 
Number of stakeholders who rated each of the following actions as 
"extremely useful" or "very useful": (% of 35 Stakeholders): 28 (80%). 

Identify statutory limits to data sharing that Congress should 
consider changing[B]: 
Number of stakeholders who rated each of the following actions as 
"extremely useful" or "very useful": (% of 35 Stakeholders): 27 (77%). 

Provide technical assistance and training that focuses on how human 
services agencies can enhance data sharing under existing federal 
privacy requirements[A]: 
 Number of stakeholders who rated each of the following actions as 
"extremely useful" or "very useful": (% of 35 Stakeholders): 27 (77%). 

Explore ways to expand access to federal sources of income and wage 
information[B]: 
Number of stakeholders who rated each of the following actions as 
"extremely useful" or "very useful": (% of 35 Stakeholders): 21 (60%). 

[A] Actions related to guidance and models: 

[B] Actions related to re-examining federal privacy requirements: 

Source: GAO analysis of responses from the second of two surveys to 
the same group of stakeholders. 

Note: Stakeholders rated actions on a 5-point scale from "extremely 
useful" to "not at all useful." 

[End of table] 

Stakeholders Suggest Federal Agencies Provide Information to Clarify 
Permissible Data Sharing: 

Stakeholder suggestions included actions that federal agencies could 
take to make federal privacy requirements clearer and easier to 
implement for state and local human services agencies. The items that 
the most stakeholders identified as useful actions related to 
providing additional information are described in more detail below, 
including illustrative examples from stakeholder comments: [Footnote 
27] 

* Provide coordinated multi-agency guidance that clarifies what data 
sharing is permissible was identified as an extremely or very useful 
federal action by 32 of 35 stakeholders. In their comments, many 
stakeholders provided suggestions for areas that the guidance could 
cover, including: 

- A broad statement of cross-agency support for appropriate data 
sharing that discusses the potential benefits; 

- The different uses or purposes for which agencies might share data, 
and how privacy requirements may vary by purpose; 

- Data security, including the mechanics of how data may be shared 
(e.g., through web-based portals), stored, and protected; 

- Data governance, or which agency owns the shared data and retains 
responsibility for its maintenance; and: 

- The relationship between federal and state law, including 
information on when federal law preempts state law that may conflict. 

* Develop a model or provide existing examples of data sharing 
agreements and/or informed consent language (including possibilities 
for "opt out" provisions) that comply with federal privacy 
requirements were identified as extremely or very useful federal 
actions by 32 of 35 stakeholders. For example, several stakeholders 
proposed having federal agencies develop model data sharing agreements 
or templates that include provisions on how data should be shared, 
maintained, and used. A few suggested that federal agencies could 
collect and share examples, such as by creating a database of sample 
data sharing agreements that could inform other agencies in developing 
their own data sharing protocols. Several stakeholders suggested that 
clarifying guidance on allowable data sharing be paired with model 
language, forms, or agreements. Several stakeholders also suggested 
federal agencies provide model "informed consent" language, which is 
used to either notify clients that their data will be shared unless 
they request it not be ("opt-out" consent) or to request their 
permission to share the data ("opt-in" consent).[Footnote 28] They 
suggested federal agencies work toward developing informed consent 
language and procedures that could be used across states and programs. 

* Continue or increase the provision of funds for pilots and 
demonstration projects for data sharing, including those that address 
privacy-related challenges was identified as an extremely or very 
useful federal action by 32 of 35 stakeholders. For example, several 
stakeholders and officials at sites we visited suggested the federal 
government could use funded demonstration projects to encourage data 
sharing that complies with privacy requirements, and to send a message 
that such sharing is useful and appropriate. One stakeholder, for 
instance, said that federal agencies should offer competitive grants 
to fund data sharing systems that have the capability to comply with 
applicable privacy laws, and that can be modified over time to comply 
with changing laws. An outcome of such demonstration projects could be 
to publicize examples of agencies that have successfully addressed 
privacy-related challenges to data sharing, which is another potential 
action that most stakeholders rated as useful. 

Stakeholders Suggest Federal Agencies Re-examine Privacy Requirements 
and Consider Changes to Increase Consistency: 

Stakeholders also suggested actions that federal agencies could take 
to ensure that the federal privacy requirements that apply to state 
and local human services agencies are reasonable and consistent. In 
general, stakeholders did not consistently identify specific laws or 
regulations in need of revision. Instead, they raised questions in 
more general terms about whether some privacy requirements should be 
re-examined in light of changes in society and technology. With 
respect to FERPA, however, a number of stakeholders specifically 
suggested the law be revised to ensure child welfare agencies have 
appropriate and timely access to the educational records of children 
in foster care.[Footnote 29] 

The items that the most stakeholders identified as useful actions 
related to re-examining federal privacy requirements are described in 
more detail below, including illustrative examples from stakeholder 
comments: 

* Review and harmonize non-statutory requirements to ensure more 
standardized privacy rules for data sharing across human services 
programs and agencies was identified as an extremely or very useful 
federal action by 32 of 35 stakeholders. In their comments, several 
stakeholders suggested reviewing and revising federal privacy 
requirements as needed to increase consistency. Several stakeholders 
also suggested a comprehensive federal effort to ensure all relevant 
privacy requirements work together. A few stakeholders identified 
specific areas for closer review. For instance, one stakeholder 
observed that the differing privacy protections for substance abuse 
and mental health records were developed separately, but that today, 
standard practice integrates treatment for substance abuse and mental 
illness. As a result, the stakeholder noted that these "treatment 
providers must deal with conflicting standards for privacy and 
confidentiality." 

* Review non-statutory privacy requirements across human services 
programs to ensure rules are appropriate for current available 
technologies was identified as an extremely or very useful federal 
action by 32 of 35 stakeholders. For example, several stakeholders 
suggested that federal privacy requirements be examined in light of 
evolving technologies to ensure an appropriate balance between 
protecting personal information and innovative use of technology to 
improve efficiency and client service. One stakeholder suggested that 
privacy requirements be reviewed to identify restrictions that impede 
beneficial data sharing while offering little protective benefit to 
clients. Another stakeholder noted that "privacy should not be used as 
an excuse to thwart innovation or data sharing that would enable 
agencies to better serve citizens, or to do so more efficiently and 
economically." 

* Revise FERPA to ensure child welfare agencies have access to 
education records (or recommend Congressional action if necessary) was 
identified as an extremely or very useful federal action by 29 of 35 
stakeholders. Most stakeholders supported federal action to reconcile 
FERPA's restrictions on access to education records with the 
responsibilities of child welfare agencies. In their comments, several 
stakeholders suggested FERPA be amended to permit disclosure of the 
education records of foster children to child welfare agencies without 
needing to first obtain parental consent or a court order. For 
example, a state or local child welfare agency with responsibility for 
a child in foster care could be authorized to access education records 
as needed to address the child's educational needs, with requirements 
for appropriate protection of the information. Officials from HHS and 
Education indicated that expanding disclosure without parental consent 
or court order would require Congress to amend the statute. Because 
the exceptions to FERPA are statutory, Education does not have 
authority to add additional exceptions by regulation. Education 
officials told us that they could provide additional guidance that 
clarifies that child welfare agencies may access education records 
under FERPA if they are defined as "parents" of foster children under 
state law, but that approach has limitations. For example, they noted 
that such an approach may give child welfare agencies additional 
rights as a parent beyond accessing education records, such as the 
right to challenge or correct the content of the records.[Footnote 30] 
Furthermore, the Individuals with Disabilities Education Act (IDEA) 
and its implementing regulations also require parental consent prior 
to the disclosure of education records of children with disabilities. 
However, according to Education officials, the definition of parent in 
IDEA does not permit a child welfare agency to be considered a parent. 
[Footnote 31] As a result, even if a child welfare agency was defined 
as a parent under state law for purposes of FERPA, child welfare 
agencies could not obtain the education records of foster children 
with disabilities without parental consent or a court order. These 
complications could be avoided by adding child welfare agencies to the 
existing list of parties under FERPA to whom schools may disclose 
records without first obtaining parental consent. Officials from both 
agencies said that such a change would help facilitate child welfare 
agencies' timely access to education records for children in foster 
care. On January 14, 2013, the president signed into law the 
Uninterrupted Scholars Act, which among other provisions, amends FERPA 
by authorizing disclosure of education records without parental 
consent to child welfare agencies that have a right of access to a 
student's case plan and are legally responsible for the care and 
protection of the student.[Footnote 32] 

Existing Federal Initiatives Address Some Actions Suggested by 
Stakeholders: 

Several federal agencies we reviewed have some initiatives underway or 
planned that relate to actions suggested by stakeholders (see table 
6). In particular, HHS's Administration for Children and Families 
(ACF) and OMB both have efforts that concern data sharing in human 
services programs, and which have components related to federal 
privacy requirements. In addition to these ongoing initiatives, ACF 
and HHS's Office of the Assistant Secretary for Planning and 
Evaluation told us that they have additional efforts planned to 
clarify federal privacy requirements. 

Table 6: Current or Planned Federal Initiatives Related to Stakeholder 
Suggestions: 

Initiatives completed or currently ongoing: 

Stakeholder suggestion: Continue or increase the provision of funds 
for pilots and demonstration projects for data sharing, including 
those that address privacy-related challenges; 
Federal initiative: Initiatives completed or currently ongoing: 
* Since fiscal year 2011, OMB's Partnership Fund for Program Integrity 
Innovation has allocated over $22 million for pilot projects to 
improve federal assistance programs that are jointly administered by 
federal and state agencies, or where federal-state cooperation could 
be beneficial.[A] Part of the Partnership Fund's mission is to 
streamline program administration and strengthen program integrity, 
which includes addressing obsolete technologies and conflicting 
requirements. Proposals for the Partnership Fund pilots are developed 
with the help of the Collaborative Forum, a group of federal, state, 
local, and non-government stakeholders who work together to develop 
ideas for improving state-administered federal assistance programs. 
The Forum and its working groups meet regularly and disseminate 
information to its members. 
Through the Partnership Fund, in September 2012, ACF awarded nearly $8 
million to seven states (Colorado, New York, Oklahoma, Illinois, 
Indiana, California, and Maryland) for 12-month grants to plan 
improved integration in health and human services information 
technology systems. As part of these projects, each state will be 
required to produce a public report that includes the privacy and 
confidentiality framework developed to support appropriate data 
sharing. 

Stakeholder suggestion: Communicate that the federal agency views data 
sharing as beneficial to the administration of human services programs; 
Federal initiative: Initiatives completed or currently ongoing: 
* ACF recently started an initiative focusing on the importance of 
"Interoperability"--the ability of two or more systems to exchange 
information. ACF has posted information for state and local agencies 
on a website, including an Interoperability Toolkit that was first 
published in 2011 and updated in 2012; 
* A 2010 OMB memorandum entitled "Sharing Data While Protecting 
Privacy" encouraged federal agencies to engage in coordinated efforts 
to share data to improve program implementation. The memo noted that 
"OMB stands ready to assist agencies as they evaluate proposals for 
data sharing activities and as they take the necessary steps for 
ensuring that their data sharing activities comply with applicable 
laws, regulations, and policies." 

Stakeholder suggestion: Create consistent standards for data security 
across programs and agencies; 
Federal initiative: Initiatives completed or currently ongoing: 
* In June 2012, ACF released data security guidance as part of a 
larger initiative (the National Human Services Interoperability 
Architecture) to develop standards for information technology systems 
that will enable information exchange across federal, state, local, 
and private human services systems. 

Initiatives planned: 

Stakeholder suggestion: Provide coordinated multi-agency guidance that 
clarifies what data sharing is permissible; 
Federal initiative: Initiatives completed or currently ongoing: 
* As part of its Interoperability Initiative, ACF plans to release a 
Confidentiality Toolkit for sharing data among six human services 
programs (TANF, SNAP, Low-Income Home Energy Assistance Program, child 
welfare, child support, and child care) aimed at state and local human 
services agencies. According to ACF officials leading this effort, 
they worked with policy and legal officials from each program, 
including USDA officials overseeing SNAP, to develop this toolkit. 
Officials said that for each program the toolkit will contain a 
narrative description of the relevant privacy rules, an explanation of 
typical data sharing activities, and a matrix of what data can be 
shared across which programs. Although the toolkit's scope has evolved 
over time and its publication has encountered some delay, ACF 
officials told us in October 2012 that the toolkit was undergoing 
internal review and expected it would be published soon. 

Stakeholder suggestion: Develop a model or provide existing examples 
of data sharing agreements that comply with federal privacy 
requirements; 
Federal initiative: Initiatives completed or currently ongoing: 
* In response to confusion from state and local agencies regarding 
federal privacy requirements, HHS's Office of the Assistant Secretary 
for Planning and Evaluation has undertaken a limited review of 
requirements. Officials said that an outcome of their review may be to 
identify model data sharing agreements for specific data sharing 
purposes; however, they had not yet finalized the scope of their work. 

Source: GAO summary of information provided by federal agencies. 

[A] The Partnership Fund was established by the Consolidated 
Appropriations Act, 2010, Pub. L. No. 111-117, div. C, tit. II, 123 
Stat. 3034, 3171-72 (2009). OMB established the Collaborative Forum to 
comply with the Act's requirement to consult with an "interagency 
council" consisting of representatives of federal agencies, states, 
and other stakeholders. 

[End of table] 

These efforts also demonstrate the importance that OMB and HHS have 
placed on breaking down silos across programs and systems to provide 
better and more efficient service delivery. For example, the 
Collaborative Forum, which was established through one of OMB's 
initiatives, involves members from all levels of government, as well 
as a range of programs and disciplines, considering ways to improve 
state-administered federal assistance programs. The Confidentiality 
Toolkit that ACF plans to release cuts across six human services 
programs and involves interagency work with USDA on SNAP. This planned 
Confidentiality Toolkit is part of a larger effort by ACF, which 
recently started focusing on the importance of "Interoperability"--the 
ability of two or more systems to exchange information. 

These recent initiatives represent important steps by OMB and HHS in 
facilitating data sharing while addressing important privacy issues. 
However, some questions remain about the final content and completion 
dates of these efforts. For example, the actual completion date of 
HHS's planned Confidentiality Toolkit is not yet known. According to 
ACF officials, it was originally expected to be completed earlier in 
the year, but had encountered some delay. When we spoke with officials 
in October 2012, the Toolkit was still undergoing internal review, 
including by legal counsel. Further, ACF did not yet have specific 
plans for the Toolkit's dissemination or the collection of feedback 
from potential users on the information's usefulness. In addition, the 
plans and scope for another HHS effort that may potentially 
incorporate model or existing examples of data sharing agreements have 
not been finalized. In our work, we found that the stakeholders we 
surveyed ranked the provision of models or examples of data sharing 
agreements addressing privacy issues among the highest actions desired 
from the federal level. OMB officials also said that building a 
repository of model agreements would be helpful to facilitate the 
sharing of promising practices. The officials also noted that a key 
factor that facilitates improved data sharing among programs is 
leadership--a key success factor that was also discussed by officials 
at our selected states and localities. Given OMB's role in overseeing 
federal agencies, it is positioned to encourage and facilitate 
appropriate cross-agency activities and practices and has done so in 
the past. For example, OMB issued a 2010 memorandum entitled "Sharing 
Data While Protecting Privacy" that encouraged federal agencies to 
engage in coordinated efforts to share data to improve program 
implementation, while emphasizing that they must do so in a way that 
fully protects individual privacy. The memorandum states that OMB 
"stands ready to assist agencies" consider ways to expand useful data 
sharing activities that comply with applicable privacy laws, 
regulations, and policies. OMB also continues to seek opportunities to 
promote and facilitate data sharing efforts generally. For example, 
OMB officials said that, in response to recent legislation,[Footnote 
33] OMB is working with several federal agencies on data exchange 
standardization to improve the ease and accuracy of information 
exchanges between and within human services programs. However, 
according to OMB officials, the agency did not have plans to undertake 
specific actions related to privacy requirements, such as identifying 
and disseminating model data sharing agreements or other tools, that 
might better facilitate the implementation of new and appropriate data 
sharing efforts. Moreover, funding for the Partnership Fund for 
Program Integrity Innovation, which supports pilots, including the one 
related to developing privacy and confidentiality frameworks noted in 
the table above, expires at the end of fiscal year 2013. 

Conclusions: 

The steps the federal government and some states and localities have 
taken to provide more seamless and standardized data exchange promote 
greater interoperability across health and human services programs. 
Advances in technology, in some locations, have also increasingly 
allowed agencies to better manage exactly who has access to what 
information. Yet, even with the technology to share data, state and 
local agencies may be stymied by uncertainties regarding what can or 
cannot be shared consistent with the myriad of privacy laws and 
requirements that affect the delivery of human services. Absent more 
explicit clarification on what data sharing is permitted under these 
requirements, as well as specific examples and tools related to how 
some states and localities are actually sharing data in new ways while 
fully maintaining client privacy protections, other state and local 
agencies may be stalled in their efforts. While HHS and OMB have 
demonstrated leadership by taking some initial steps to help states 
and localities move forward in this area, these efforts need sustained 
attention--to ensure their completion, appropriate content, effective 
dissemination, and usefulness to program administrators and other 
users. 

Recommendations for Executive Action: 

HHS: 

To ensure that state and local human services agencies have additional 
information to help facilitate useful data sharing, we recommend that 
the Secretary of HHS ensure timely completion of the department's 
planned activities to clarify what data sharing is permissible under 
federal privacy requirements and consider other ways to bolster the 
efficacy of its efforts. For example, HHS could develop a strategy for 
the effective dissemination of its Confidentiality Toolkit and 
consider ways to solicit and incorporate feedback on the information's 
usefulness from a range of users. 

OMB: 

To follow through on its efforts to improve the delivery of federal 
assistance programs and to help federal agencies promote useful data 
sharing activities that comply with federal privacy requirements, we 
recommend that the Director of OMB take a more active leadership role 
in considering additional opportunities to identify and disseminate 
useful data sharing practices and tools that address privacy 
requirements among human services programs. For example, OMB could 
leverage the Collaborative Forum's existing network of federal, state, 
and local agencies and other stakeholder organizations to collect and 
disseminate useful information, such as model data sharing agreements 
that comply with federal privacy requirements. 

Agency Comments and Our Evaluation: 

We provided a draft of our report to Education, HHS, OMB, and USDA for 
review and comment. We received written comments on the draft report 
from HHS, which are reproduced in appendix V. We also received 
technical comments from OMB, Education, HHS, and USDA which we 
incorporated as appropriate. 

In the report that we sent to the agencies for comment, we had 
included a suggestion for Congress to consider amending FERPA to 
ensure that child welfare agencies have timely and appropriate access 
to the education records of children in foster care, such as by adding 
state and local child welfare agencies to the existing list of parties 
to whom schools may disclose records without first obtaining parental 
consent. We removed this suggestion from the final report due to the 
passage of the Uninterrupted Scholars Act in January 2013 which 
amended FERPA in this manner. 

In its comments, HHS concurred with our recommendation for the 
department and stated that it is in the process of refining its 
Confidentiality Toolkit and plans to solicit feedback on the Toolkit's 
usefulness before wider dissemination to state and local human service 
agencies. 

In its technical comments, OMB noted that it had already taken some 
steps to encourage data sharing while protecting privacy. We think 
that such encouragement would be more effective if accompanied by the 
dissemination of concrete tools, such as model data sharing 
agreements, that ultimately could be leveraged by state and local 
agencies. As a result, we have clarified some information in the 
report and the recommendation to emphasize this point. 

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies of this report 
to appropriate congressional committees and the Secretaries of 
Agriculture, Education, and Health and Human Services, the Deputy 
Director for Management and other interested parties. The report also 
will be available at no charge on the GAO website at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-7215 or brownke@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. Key contributors to this report are 
listed in appendix VI. 

Signed by: 

Kay E. Brown: 
Director, Education, Workforce, and Income Security Issue: 

[End of section] 

Appendix I: Additional Information On Selected Sites: 

This information was provided by state and local officials. GAO did 
not independently evaluate the data sharing systems described in this 
report, including their compliance with any applicable laws or 
regulations. 

Michigan: Enterprise Data Warehouse: 

System Characteristics: 

System owner or administrator: 
Michigan Department of Technology, Management and Budget, a 
centralized IT department for the various state departments and
agencies. 

System name and description: 
Michigan’s Enterprise Data Warehouse provides a common platform to 
allow users to connect disparate data elements on a single client or 
family across different agencies’ data systems. Data from the various 
systems feed into the warehouse, are updated on a regular basis, and 
are stored over time. 

Start date: 
The warehouse was developed in the mid-1990s to monitor Medicaid 
claims data. It has since expanded to other government departments and 
now supports about 10,000 government users statewide. 

Goals of the system include: 
* Reducing improper payments of public benefits (e.g., by identifying
potential payment errors or detecting fraud).
* Improving program efficiencies, such as by analyzing and managing 
worker caseloads, as well as streamlining eligibility redetermination 
processes. 
* Improving client outcomes, such as by locating non-custodial parents 
to provide child support payments or increasing the rate of 
reunification for foster care children. 

Access to Data from Various Sources: 

Michigan’s Enterprise Data Warehouse stores a breadth of client 
information including data on federal and state income taxes, benefit 
eligibility, vital statistics, Medicaid claims, as well as criminal 
and civil court cases. Officials said that the common architecture of 
the warehouse allows state users to make connections across data 
systems that were previously not possible. The Enterprise Data 
Warehouse also collects client’s data over a longer time period. Thus, 
unlike some of the source data systems which primarily capture current
client information, the warehouse also serves as a central repository 
for historic client information across departments and programs. 

[Refer to PDF for image: illustration] 

Michigan Enterprise Data Warehouse: 

Examples of types of data shared: 

Michigan Department of Human Services systems: 

Public Assistance Eligibility[A]: 
* TANF, SNAP, Medicaid eligibility, information; 
* Child care payment information; 
* Wage and unemployment data; 
* Service provided payments. 

Child Support Enforcement[A]: 
* Non-custodial parent location and status; 
* Child support payment information. 

Children's Services: 
* Children in foster care; 
* Children and family services data. 

Other state department systems: 

Department of Community Health[A]: 
* Medicaid provider data; 
* Medicaid beneficiary data; 
* Birth and death records; 
* Immunization records for newborns. 

Department of Treasury[A]: 
* Employer provided data (e.g., employer name, income amount); 
* State and federal tax return data. 

Michigan State Courts[A]: 
* Case information (e.g., filing date, case number, judge of record, 
next hearing date) on: 
- Criminal cases; 
- Civil cases; 
- Juvenile justice cases. 

Department of Natural Resources: 
* Hunting and fishing licenses. 

[A] Data exchange is two way and source agencies also use certain data 
shared through the system. The graphic shows examples of data provided 
by agencies but does not depict what data each agency receives or how 
data are used. 

Source: GAO analysis based on information collected from Michigan 
officials. 

Note: Officials we interviewed noted that not all data sharing between 
departments occurs through the data warehouse. Some departments share 
data directly between systems without accessing the warehouse. 

[End of figure] 

System Users: 

Similar to other sites we visited, agencies that provide data to the 
warehouse also have staff who access data from the warehouse for 
certain job functions. Some of the state departments that use the 
Enterprise Data Warehouse include: 

* The Department of Human Services, which includes a number of 
different programs, including TANF, SNAP, child care, child welfare, 
and child support enforcement. 

* The Department of Community Health, which administers a range of 
medical programs, including Medicaid, mental health and substance 
abuse treatment, as well as services to at-risk pregnant women, 
infants, and children. 

* Michigan Courts consist of over 200 courts which preside over a 
range of cases including civil, criminal, juvenile justice, and 
traffic. 

Example of Data Sharing Use: Human Services Eligibility Caseworker: 

Job function: Eligibility workers in the Department of Human Services 
determine eligibility for several programs, including TANF, SNAP, and 
Medicaid. Since 2010, local offices have used a data sharing 
management tool -- the Bridges Information Management Mart (BRIMM) – 
to access data from the state’s Enterprise Data Warehouse. The 
warehouse stores client data from various state systems. Eligibility 
workers can then access this data, which is refreshed on a nightly 
basis, to determine eligibility and monthly benefit amounts for public 
assistance programs. 

Type of data used: Data used to determine benefits include payroll or 
unemployment data, income sources such as receipt of other benefits 
and lottery winnings, family composition information, and client 
demographics. 

Stated benefits: Officials reported that BRIMM has helped: 

* Improve the speed of eligibility determinations, as all case history 
and demographic information are available online in one place. Before 
BRIMM, caseworkers needed to review both printed and electronic 
information from multiple data sources. In particular, 
redeterminations are done more quickly since summary information 
across multiple benefit programs is consolidated. A report from 
Michigan’s Department of Technology, Management, and Budget noted that 
since local offices of the Department of Human Services began using 
BRIMM, benefit redeterminations are 50 percent faster for each 
individual case. 

* Streamline client service. Clients now deal with one caseworker 
across programs and can complete redeterminations after a single 
interview instead of multiple interviews. 

Example of Data Sharing Use: Child Support Enforcement Caseworker: 

Job function: Michigan’s Office of Child Support also has a separate 
system called Michigan Child Support Enforcement System (MiCSES) that 
shares with and uses data from the common Enterprise Data Warehouse 
platform and links to certain data through the warehouse. As one key 
responsibility, staff try to locate non-custodial parents in order to 
obtain child support payments. 

Types of data used: Client information tapped through the state’s data 
warehouse expands the possible sources of information to locate a non-
custodial parent. In addition to various federal and state sources for 
income and employment information, child support staff are also able 
to access data on state motor vehicle licenses, hunting and fishing 
licenses, and police protection or incarceration status. 

Stated benefits: Workers we interviewed said that the system has 
helped them expand the ways that they can try to locate a non-
custodial parent and do so more efficiently. According to a report 
from the state’s technology department, the Office of Child Support 
has been able to recover millions of dollars in child support 
payments, due in part to data sharing and the state’s data warehouse. 

[End of Michigan site data] 

Utah: Department of Workforce Services’ eFind: 

System Characteristics: 

System owner or administrator: 
Utah’s Department of Workforce Services (DWS)—the agency that 
administers public assistance programs, including TANF, SNAP, 
Medicaid, and child care assistance programs. 

System name and description: 
eFind is a single web application that provides eligibility workers 
with information from many different sources for the purposes of 
determining eligibility for a variety of public assistance programs. 
eFind searches 21 federal, state, and local databases to obtain 
relevant applicant information, such as changes in address, income, 
and household composition. 

Start date: 
eFind was launched in January 2004 as a result of sanctions received 
for high payment error rates in the food assistance program. Utah was 
authorized to reinvest the sanctioned funds to improve the program, 
which it used in part to build eFind. 

Goals of the system include: 

* Improving accuracy and timeliness across all programs by searching 
alternate systems for pertinent client eligibility information and 
pulling up all relevant application data at once. 

* According to officials, the process of checking other data sources 
to verify eligibility information was reduced from 17 minutes to 3 
minutes, allowing staff to manage higher caseloads. Officials also 
said that the accuracy rates of payments improved with the system. 

Access to Data from Various Sources: 

Prior to eFind, eligibility workers had to search multiple systems 
involving multiple usernames and passwords and search separately for 
individual family members. eFind streamlined the process greatly by 
consolidating the various systems and automating searches. In 
addition, to improve accuracy and speed up processing times, DWS 
officials told us that they are starting to integrate certain eFind 
elements into their application system in order to “prepopulate” data 
fields determined to be highly reliable that do not require worker 
interpretation (e.g., immigration status information from the 
Department of Homeland Security). In these cases clients do not need 
to submit any documentation unless they disagree with the prepopulated 
information. 

Utah eFind: 

[Refer to PDF for image: illustration] 

DWS eligibility worker logs into a single system to verify eligibility. 

Examples of types of data shared: 

Federal: 

Social Security Administration: 
* Verification of client Social Security numbers; 
* Wage data. 

Internal Revenue Service: 
* Federal tax return data including earned and unearned income. 

Food and Nutrition Service Electronic Disqualified Recipient System: 
* Whether a client has received public benefits in certain programs 
(including SNAP, TANF, and Medicaid) in another state. 

State: 

Unemployment Insurance Division[A]: 
* Clients receiving unemployment benefits; 
* Quarterly wage data. 

Department of Human Services: (Provides foster care, child support and 
disability services); 
* Uses portal but does not provide data. 

Division of Motor Vehicles: 
* Driver's license and registration information; 
* Make and model of current vehicle; 
* Verification of client's address. 

Office of Recovery Services: 
* Child support payments; 
* Third party health insurance payments. 

Private: 

Employment Verification Vendors: 
* Current wage information such as hire date, client's earning per pay 
period and pay dates. 

[A] Data exchange is two way and source agencies also use certain data 
shared through the system. The graphic shows examples of data provided 
by agencies but does not depict what data each agency receives or how 
data are used. 

Source: GAO analysis based on information collected from Utah 
officials. 

Note: DWS eligibility workers have full access to the data in eFind. 
Other users in DWS and other departments have varying access to the 
data in the system based on data sharing agreements. 

[End of figure] 

System Users: 

Users of the system include eligibility workers from several different 
agencies both internal to DWS and outside of the agency. External 
agency users (as well as some DWS staff who do not have full access to 
eFind) access certain data elements in eFind to determine eligibility 
for their own programs. Access is determined by data sharing 
agreements that stipulate how the source data can be shared with other 
agencies. For instance, users from the state’s Board of Education 
access certain data elements in the system to determine which students 
are eligible for free or reduced lunch. Users of the system include: 

Inside DWS: 

* Eligibility Services Division; 
* Unemployment Insurance Division; 
* Case managers for assistance programs, such as TANF. 

Outside of DWS: 

* Department of Community Housing; 
* Board of Education; 
* Department of Health; 
* Department of Human Services (includes child welfare); 
* Office of Recovery Services. 

Example of Data Sharing Use: DWS Eligibility Caseworker: 

Job function: 
DWS eligibility workers must access multiple data sources through 
eFind to verify information on a client’s benefit application. People 
seeking benefits, such as SNAP, Medicaid, TANF, or child care 
assistance often submit applications online, which may include 
incomplete information. 

Type of data used: 
Eligibility workers access links to: vital records, including birth 
certificates or death records, from the Department of Vital 
Statistics; real-time wage information captured by private vendors; 
car registration and lien information from the state Division of Motor 
Vehicles; and possible sources of other income, including child 
support payments or income as a child care provider. 

Stated benefits: 
Eligibility workers and officials we interviewed said that the system 
has helped to: 

* Reduce the amount of documentation the client must submit. For 
example, clients may not have to submit pay stubs if eFind has timely 
wage and employment information. 

* Make the eligibility verification process more uniform and user 
friendly. It has consolidated data from disconnected systems to 
provide useful eligibility information. For example, a worker is able 
to assess a client’s assets by looking to see if he or she has a 
registered vehicle, the value of that vehicle, and the likelihood that 
the vehicle is actually the client’s based on other demographic 
information, in one screen. 

* Reduce the chance of improper payments because eligibility 
verification using external data sources is easier and more automated. 
With eFind and DWS’s more recent move to “prepopulate” applications 
with externally validated data, there is less need to rely on self-
reported information from the client and fewer chances for staff to 
make manual transcription errors. 

Example of Data Sharing Use: Other program eligibility workers: 

Job function: 
Other department eligibility workers outside of DWS are allowed to 
access custom views on eFind to perform their job functions – called 
‘eSHARE’ when viewed by other departments. For instance, program 
directors we interviewed from the Low-Income Home Energy Assistance 
Program told us that they have access to certain elements in eFind to 
assist in determining eligibility for energy assistance programs. 

Types of data used: 
Workers are able to access customized views to verify certain client 
identification information (e.g., date of birth, citizenship and 
income information such as quarterly wages and unemployment payments). 

Stated benefits: 

* Energy assistance program officials we interviewed told us that 
eSHARE was more automated and consolidated than the prior eligibility 
system they used, which made the work easier for their eligibility 
workers. 

* DWS program officials said that providing custom access to their 
eligibility system through eSHARE reduces the amount of time DWS 
workers spend responding to outside data requests from other 
departments. 

[End of Utah site data] 

Allegheny County, PA: Department of Human Services’ Data Warehouse: 

System Characteristics: 

System owner or administrator: 
Allegheny County’s Department of Human Services (DHS). 

System name and description: 
DHS operates a data warehouse that is a central repository of human 
service and other client data. The warehouse allows DHS to 
electronically track demographic and service data for each of its 
clients across multiple program offices. The warehouse draws from 
existing program case management systems that serve specific 
populations (e.g., child welfare, mental health) to compile the 
information centrally. 

Start date: 
DHS launched the data warehouse in 2001, consolidating a few of its 
own internal data systems, such as those for behavioral health and 
homeless services. It then expanded over time to include other data 
sources, including the state’s Department of Public Welfare. 

Goals of the system include: 
* Improving services to clients. 

* Improving the ability of workers to perform their jobs. 

* Improving the ability to manage and administer DHS programs and 
operations. 

Officials said the system has helped with coordinating services for 
clients because workers have a better understanding of families with 
multiple needs across multiple programs. 

Access to Data from Various Sources: 

Over the years, DHS’s data warehouse has expanded to include various 
other data sources, including those from other state and local 
government departments. Most recently it formulated an agreement with 
Pittsburgh Public Schools to include certain student data in its 
warehouse. According to officials, as of November 2012, more than 15 
million client records were stored in the data warehouse. Information 
stored and exchanged include client demographics (e.g., name, SSN, 
date of birth, address), services received by clients and family 
members (current and historic) and provider information (e.g., name, 
location, type of providers, and cost of treatment). Through 
negotiations between officials and, in certain cases, specific data 
sharing agreements, agencies determine exactly what data will be 
provided to the warehouse and how they will be used. Agencies may act 
as contributors to the warehouse, users, or both. 

[Refer to PDF for image: illustration] 

Allegheny County Data Warehouse: 

Examples of types of data shared: 

All sources include client demographics, service history, provider 
information, and cost. 

Allegheny County DHS data sources: 

Child Welfare[A]: 
* Children in protective custody; 
* Family services received by the family or household members; 
* Family court activity. 

Behavioral Health and Intellectual Disability[A]: 
* Clients receiving mental health and substance abuse services, and 
information about these services for county and Medicaid funded 
programs; 
* Clients with intellectual disabilities receiving support services. 

Aging Services: 
* Senior clients receiving nursing home prevention, senior center 
services, or elder care. 

Community Services[A]: 
* Clients receiving rental or homeless assistance; 
* Clients receiving jail reentry support; 
* Clients receiving Head Start or family support center services. 

Outside DHS: 

Public Schools[A]: 
* Student directory information; 
* Performance and attendance information for certain students; 
* Four districts: Pittsburgh, Clairton, Woodland Hills, Elizabeth 
Forward. 

State and local correction agencies: 
* Incarceration history of clients; 
* Current status of release or sentencing for a client. 

City and County government housing authorities: 
* Clients currently receiving low income housing assistance. 

Pennsylvania Department of Public Works: 
* Recipients of TANF, SNAP or Social Security Disability Insurance. 

[A] Data exchange is two way and source agencies also use certain data 
shared through the system. The graphic shows examples of data provided 
by agencies but does not depict what data each agency receives or how 
data are used. 

Source: GAO analysis based on information collected from Allegheny 
County officials. 

Note: GAO did not evaluate this system for compliance with any 
applicable laws or regulations. 

[End of figure] 

System Users: 

According to officials, many of the government entities that provide 
data into the warehouse also benefit from access to the data for 
routine staff work. Access to the data by staff occurs at several 
levels, ranging from de-identified and aggregated data to direct 
access to client level records. In general, officials said that DHS’ 
program office staff (Child Welfare, Behavioral Health) have access to 
more detailed client-level data, while entities outside DHS (including 
the public schools and jails) access aggregate data for planning 
purposes, or more specific client-level data upon request. 

Example of Data Sharing Use: Child Welfare Intake Worker: 

Job function: 
When responding to a call regarding potential maltreatment, a child 
protective services (CPS) intake worker may look up information on a 
person, child, or family in the data warehouse system. 

Type of data used: 
According to officials, the data warehouse has increased the amount of 
client-level information intake workers have at their disposal. This 
information can help them identify whether the reported person or 
another member of the family or household receives other government 
services, such as behavioral health, or has a criminal history. Intake 
workers are able to access demographic information collected by other 
departments, such as the state Department of Public Welfare that 
administers the TANF and SNAP programs. Such information may include 
the exact address or alternative addresses or names and information on 
other household members, relatives, or noncustodial parents. 

Stated benefits: 
Intake workers we interviewed said that the system has helped to: 

* Speed up their ability to get information on a family when limited 
or inaccurate information is provided at intake, including the 
location of reported maltreatment or the full name of the reported 
person. 

* Probe in their questioning with a client who may not always be 
forthcoming. 

* Manage their time, such as by knowing who else is living in the 
house and who they need to interview before conducting a home visit. 

* Ensure their own safety because they have better background 
information on household members before making the home visit (e.g., 
information on criminal history or mental health status of household 
members). 

* Search for and contact potential relative caregivers. 

Example of Data Sharing Use: Behavioral Health Caseworker: 

Job function/process: 
When dealing with new or returning clients, frontline workers in 
homeless shelters or substance abuse treatment centers look up client 
information stored in the data warehouse. 

Types of data used: 
Caseworkers are able to access a client history and current service 
involvement, including provider claims data. Community health care 
providers can obtain background information on a patient (e.g., number 
of therapy sessions or psychiatric evaluations performed). 

Stated benefits: Caseworkers we interviewed said that the system 
helped them to: 

* Conduct coordinated screenings, referrals, and service plans across 
multiple programs serving the same client. 

* Know what services have been provided when, which reduces the 
possibility of providing duplicative services. 

* Make faster connections between program offices with less effort. 

[End of Allegheny County site data] 

New York City: Worker Connect: 

System Characteristics: 

System owner or administrator: 
New York City Office of the Deputy Mayor for Health and Human Services 
and Partner Agencies. 

System name and description: 
Worker Connect is a read-only web-based portal that enables users to 
view limited data from other city departments’ systems. Worker Connect 
is one part of a larger city initiative called HHS Connect, which is 
aimed at improving the city’s delivery of health and human services 
through enhanced technology. Workers with access to Worker Connect 
view data through a common portal. Data ownership is maintained by the 
source agencies and data that is shared is not copied or stored in 
another system. 

Start date: 
Worker Connect began in 2010 and currently has approximately 6,800 
authorized city users across 34 different user groups. 

Goals of the system include: 

* Giving workers real-time access to data across programs that can 
help them make more informed case management decisions, better 
identify client needs, and provide more integrated service delivery. 

* Reducing clients’ and workers’ time to process cases and provide or 
collect documents. 

Access to Data from Various Sources: 

Worker Connect links data on a single individual, family, or household 
across city agencies and programs. This is done by matching client 
records from different source systems based on select demographic data 
(e.g., name, address, SSN, date of birth, or gender). Based on 
agreements between agencies, certain specified workers have access to 
certain client data, such as household composition, services provided 
by other agencies, or client case status. The system is able to 
provide customized views of information, down to what data elements 
are shown on a single screen for one worker versus another. The 
graphic below identifies the source agencies and how information is 
shared. 

New York City: Worker Connect: 

[Refer to PDF for image: illustration] 

Examples of types of data shared: 

Workers can only see client information relevant to their job function. 
Worker A: 
Worker B: 
Worker C: 
Worker Connect Portal to read only data sharing system. 

Administration for Children's Services[A]: (Child welfare, protective 
services): 
* Family demographic information (address, date of birth, full name); 
* Number of families currently receiving subsidized child care. 

Health and Hospitals Corporation: (Provides medical, mental health and 
substance abuse services): 
* Uses portal but does not provide data, 

Department of Homeless Services[A]: 
* Families and singles in the city's shelters; 
* Families and singles diverted from homelessness. 

City Housing Authority: 
* Residents currently in city housing. 

Department of Finance[A]: 
* Clients enrolled in the senior rent increase exemption program. 

Human Resources Administration: 
* Status of client's public assistance application; 
* Amount of a family's cash assistance benefits; 
* Copies of documents provided by client (e.g., birth certificates, 
pay stubs, utility bills). 

[A] Data exchange is two way and source agencies also use certain data 
shared through the system. The graphic shows examples of data provided 
by agencies but does not depict what data each agency receives or how 
data are used. 

Source: GAO analysis based on information collected from New York City 
officials. 

[End of figure] 

Many of the agencies that provide data also have staff who are users 
of Worker Connect. According to officials, some of the agencies that 
use Worker Connect include: 

* Administration for Children’s Services (child welfare, child 
protective services). 

* Department of Juvenile Justice. 

* Department for the Aging. 

* Department of Health and Mental Hygiene. 

* Department of Correction. 

* Department of Probation. 

* Health and Hospitals Corporation (provides medical, mental health 
and substance abuse services). 

* Human Resources Administration (public assistance agency). 

* Department of Homeless Services. 

* Department of Finance. 

According to officials, the largest groups of users are child 
protective service workers. 

Example of Data Sharing Use: Department of Homeless Services’ Intake 
Worker: 

Job function: 
When homeless clients arrive at intake facilities, they are often in 
crisis and do not have the necessary documentation to process their 
application. Intake workers often have to obtain documents they are 
unable to retrieve from the client, or help clients identify other 
housing resources that may be available to them, such as low income 
housing programs. 

Type of data used: 
Intake workers have access to sources of information, such as previous 
shelter placements and dates, work history, pay stubs, leases, and 
other basic demographic information, such as prior addresses, birth 
certificates, and names of family members. 

Stated benefits: 
Officials we interviewed said that the system has helped their intake 
workers: 

* Save time on interviews and processing of applications. With 
information from Worker Connect, intake workers are able to process a 
client with one interview instead of two and in fewer minutes. Given 
the high volume of clients, the time savings add up to a significant 
amount time saved. 

* Expedite placements and meet the city’s established 10 day mandatory 
decision for homeless cases.  

* Allowed intake workers to spend more time on coordination of care. 

Example of Data Sharing Use: Health and Hospital Corporation (HHC) 
Financial Counselors: 

Job function: 
HHC financial counselors often work with patients visiting the 
corporation’s facilities (e.g., hospitals, acute care facilities) that 
come in without any proof of identification, residence, or 
citizenship. Counselors must work with them to determine if they are 
eligible for Medicaid or other health insurance programs. 

Types of data used: 
Counselors are able to access basic information through Worker Connect 
like the most recent address, birth date, previous Medicaid status, 
and family composition. 

Stated benefits: 
Officials we interviewed said that the system has helped their workers: 

* Save time that they would otherwise spend with the client or with 
other agencies tracking down information (e.g., obtaining a birth 
certificate or determining Medicaid status). 

* Better serve a transient population that often has behavioral health 
issues and precarious housing situations. Clients do not always have 
needed documentation on them, nor are they always able to clearly 
describe their history or situation. 

[End of New York City site data] 

[End of section] 

Appendix II: Scope and Methodology: 

To address the objectives of this study, we used a variety of methods. 
Specifically, we: 

* Conducted four site visits to state or local human services agencies 
that were repeatedly identified during our exploratory research and 
interviews as having promising data sharing efforts; 

* Conducted "Delphi method" surveys of stakeholders from state and 
local human services agencies, information technology providers, and 
research and advocacy organizations; and: 

* Conducted interviews with federal agencies; reviewed relevant 
federal laws, regulations, and policy guidance; and reviewed 
information related to federal initiatives to support data sharing. 
[Footnote 34] 

Site visits: 

To gather information on how selected sites share data to improve the 
administration of human services programs, we conducted site visits to 
four state or local human services agencies repeatedly identified as 
sharing data in promising ways: Allegheny County, Pennsylvania; 
Michigan; New York City; and Utah. To identify potential promising 
examples, we relied on recommendations from external parties, 
including federal agencies and key national associations knowledgeable 
about these issues, as well as published research and articles. We 
then gathered initial information on the data sharing efforts of 
approximately 10 sites that were mentioned repeatedly, including 
through preliminary phone interviews with state or local officials, 
and a preliminary visit to Montgomery County, Maryland. Ultimately, we 
selected four sites to obtain a mix of functional areas (e.g., whether 
data sharing was used to improve eligibility verification or case 
management processes) and targeted populations and programs. 
Secondarily, we selected sites for a mix of state and local level 
agencies and geographic location. 

For each site, we gathered in-depth information on key data sharing 
initiatives, goals of increased data sharing, target populations and 
programs, organizational structure of data sharing (such as which 
agencies are involved and "own" the data), and anecdotal information 
on outcomes.[Footnote 35] During our site visits, we spoke with 
relevant program and policy officials, including program 
administrators, information technology officials, and attorneys. At 
each site, we also spoke with frontline staff to help us obtain 
concrete examples of data sharing related to day-to-day work of 
eligibility determination and case management. We also observed 
demonstrations of computer systems. On two visits, we also spoke with 
organizations representing service providers or community groups. 

On the basis of our site visit information, we cannot generalize our 
findings beyond the states or localities we visited. Information we 
gathered on our site visits represents only the conditions present in 
the states and local areas at the time of our site visits. 

Delphi Survey: 

To gather the opinions of stakeholders on challenges faced by state 
and local human services agencies in balancing data sharing and 
privacy, and federal actions to address these challenges, we employed 
a modified version of the Delphi method, which follows a structured 
process for collecting and distilling knowledge from a group through a 
series of questionnaires. For our purposes, we employed two iterative 
surveys. 

We selected stakeholders to cover a broad range of perspectives and 
sectors, including: (1) state and local human service agency officials 
in program administration, technology, and legal positions as well as 
associations representing these agencies;[Footnote 36] (2) private and 
non-profit sector information technology providers; and (3) 
representatives from advocacy and research organizations. For a list 
of the names and organizations of stakeholders who responded to our 
surveys, see appendix IV. Through preliminary interviews and 
background research, we identified approximately 30 potential 
stakeholders to participate in our survey as a starting point. We then 
vetted our initial list of potential respondents with representatives 
from the American Public Human Services Association (APHSA) and the 
Collaborative Forum, a group established by the Office of Management 
and Budget (OMB) that draws on federal, state, and other stakeholder 
expertise to help develop pilot projects to improve how states 
administer federally-funded assistance programs. Then, using the 
snowball approach, we contacted our initial list of respondents to 
explain our research, inquire about their interest in participating in 
our survey, and ask for the names of other potential respondents who 
may have expertise in this area. This allowed us to both expand our 
initial list of potential respondents and to validate the relevance of 
the respondents we had already identified. We originally invited 42 
stakeholders to participate in our survey, with participation from 
each of the sectors we identified above. We later determined that two 
of the 42 stakeholders were out of scope because they told us they 
were not in a position to answer our questions; therefore, we did not 
include them in the surveys which were sent to 40 stakeholders. Our 
survey was not intended to be representative of a wider population, 
but rather to solicit a broad range of expertise. 

We first surveyed the stakeholders with open-ended questions and asked 
them to identify challenges that state and local agencies face 
balancing increased data sharing with the need to protect personal 
information, actions that the federal government could take to address 
challenges, and current relevant federal initiatives. We received 
completed surveys from 35 of the 40 stakeholders for a response rate 
of 88 percent. This survey was administered from May 14, 2012, to June 
15, 2012. 

Based on the 35 completed surveys, we performed a content analysis to 
identify key themes. Two analysts independently reviewed and coded 
survey responses and reached consensus on a group of key challenges 
and federal actions. When providing illustrative examples using 
stakeholders' views throughout this report, we defined modifiers 
(e.g., "several") to quantify stakeholders' views as follows: 

* "Most" stakeholders represents more than 25; 

* "A majority" of stakeholders represents 18-25; 

* "Many" stakeholders represents 10-17; 

* "Several" stakeholders represents 4-9; 

* "A few" stakeholders represents 2-3. 

The open-ended comments from the first survey were the basis for our 
second survey of stakeholders, which asked them to rate items in terms 
of the level of challenge they presented for state and local agencies 
(on 5-point scale from "extreme challenge" to "not a challenge") and 
the degree of usefulness of potential federal actions (on a 5-point 
scale from "extremely useful" to "not at all useful"). In addition, we 
asked a limited number of open-ended questions to collect more 
information on specific challenges and actions. We sent this survey to 
the same 40 stakeholders and received completed surveys from 35 for a 
response rate of 88 percent. The second survey was administered from 
July 23, 2012, to August 27, 2012. For the full results of the second 
survey, see appendix III. 

Both surveys were web-based. For both rounds, we sent stakeholders an 
email invitation to complete the survey on a GAO web server using a 
unique username and password. Nonrespondents received reminder emails 
asking them to complete the survey. 

Because the two surveys were not sample surveys, but rather surveys of 
the universe of respondents we identified, they have no sampling 
errors. However, the practical difficulties of conducting any survey 
may introduce nonsampling errors, such as difficulties interpreting a 
particular question, which can introduce unwanted variability into the 
survey results. We took steps to minimize nonsampling errors by 
pretesting the first questionnaire with two stakeholders in May 2012 
and the second questionnaire with three stakeholders in July 2012. We 
conducted pretests to make sure that the questions were clear and 
unbiased and that the questionnaire did not place an undue burden on 
respondents. An independent reviewer within GAO also reviewed a draft 
of both questionnaires prior to their administration to ensure 
questions were understandable to a cold reader. We made appropriate 
revisions to the content and format of the questionnaires after the 
pretests and independent reviews. 

[End of section] 

Appendix III: Delphi Survey Results: 

Using the Delphi method, we distributed two surveys to 40 individuals 
from state and local human services agencies, IT providers, and 
research and advocacy organizations to determine their views on 
challenges that state and local agencies face in balancing increased 
data sharing with the need to protect personal information, and the 
actions that the federal government could take to address these 
challenges. For both surveys, we received completed responses from 35 
of 40 individuals, for a response rate of 88 percent. Tables 7-11 
below show responses to questions from the second survey; these 
questions were developed based on our analysis of stakeholders' 
responses to the first survey, which asked open-ended questions about 
relevant challenges and potential actions. For more information about 
our survey methodology, see appendix II. 

Table 7: Challenges Identified by Stakeholders Related to Federal 
Privacy Requirements (Including Federal Laws, Regulations, and Other 
Requirements): 

Question: In your opinion, how much of a challenge is each of the 
following items for state and local human services agencies as they 
balance the need to protect personal information while increasing the 
use of data sharing?. 

Responses: 

Confusion or misperceptions around what agencies are or are not 
allowed to share; 
Extreme challenge: 17; 
Great challenge: 15; 
Moderate challenge: 1; 
Somewhat of a challenge: 0; 
Not a challenge: 0; 
Not applicable/don't know: 2; 
Total responses: 35. 

Agencies may be overly cautious and interpret federal privacy 
requirements more narrowly than necessary; 
Extreme challenge: 17; 
Great challenge: 12; 
Moderate challenge: 3; 
Somewhat of a challenge: 2; 
Not a challenge: 0; 
Not applicable/don't know: 1; 
Total responses: 35. 

Federal privacy requirements that govern data sharing are inconsistent 
across multiple programs; 
Extreme challenge: 12; 
Great challenge: 12; 
Moderate challenge: 10; 
Somewhat of a challenge: 0; 
Not a challenge: 0; 
Not applicable/don't know: 1; 
Total responses: 35. 

Agencies are not always sure when client consent is required to share 
data; 
Extreme challenge: 7; 
Great challenge: 13; 
Moderate challenge: 5; 
Somewhat of a challenge: 5; 
Not a challenge: 2; 
Not applicable/don't know: 3; 
Total responses: 35. 

Federal privacy requirements about sharing data with third parties 
(e.g., non-profit service providers) are overly restrictive; 
Extreme challenge: 7; 
Great challenge: 11; 
Moderate challenge: 6; 
Somewhat of a challenge: 7; 
Not a challenge: 1; 
Not applicable/don't know: 3; 
Total responses: 35. 

Security standards for sharing and storing data are inconsistent; 
Extreme challenge: 7; 
Great challenge: 8; 
Moderate challenge: 10; 
Somewhat of a challenge: 4; 
Not a challenge: 0; 
Not applicable/don't know: 5; 
Total responses: 34. 

Source: GAO analysis of responses from the second of two surveys to 
the same group of stakeholders. 

Note: Totals may not add to 35 because not all respondents answered 
every question. 

[End of table] 

Table 8: Organizational and Implementation Challenges Identified by 
Stakeholders: 

Question: In your opinion, how much of a challenge is each of the 
following items for state and local human services agencies as they 
balance the need to protect personal information while increasing the 
use of data sharing?. 

Responses: 

Agencies may not trust that other agencies will sufficiently protect 
shared data; 
Extreme challenge: 7; 
Great challenge: 11; 
Moderate challenge: 13; 
Somewhat of a challenge: 1; 
Not a challenge: 0; 
Not applicable/don't know: 2; 
Total responses: 34. 

Agencies may not always be aware of the capacity of technology to 
protect personal information; 
Extreme challenge: 7; 
Great challenge: 13; 
Moderate challenge: 11; 
Somewhat of a challenge: 1; 
Not a challenge: 1; 
Not applicable/don't know: 1; 
Total responses: 34. 

Data sharing agreements between agencies are cumbersome to establish; 
Extreme challenge: 8; 
Great challenge: 13; 
Moderate challenge: 9; 
Somewhat of a challenge: 2; 
Not a challenge: 1; 
Not applicable/don't know: 1; 
Total responses: 34. 

Agencies tend to adopt data sharing agreements that are too specific 
and do not allow for flexibility; 
Extreme challenge: 5; 
Great challenge: 10; 
Moderate challenge: 8; 
Somewhat of a challenge: 7; 
Not a challenge: 1; 
Not applicable/don't know: 3; 
Total responses: 34. 

Public perception regarding sharing personal information deters 
agencies from sharing data; 
Extreme challenge: 3; 
Great challenge: 11; 
Moderate challenge: 10; 
Somewhat of a challenge: 5; 
Not a challenge: 4; 
Not applicable/don't know: 1; 
Total responses: 34. 

Agencies are hesitant to use clients' Social Security numbers to match 
data across systems; 
Extreme challenge: 5; 
Great challenge: 8; 
Moderate challenge: 10; 
Somewhat of a challenge: 2; 
Not a challenge: 6; 
Not applicable/don't know: 4; 
Total responses: 35. 

Past practice has created a mindset or culture that agencies should 
not share data; 
Extreme challenge: 9; 
Great challenge: 11; 
Moderate challenge: 9; 
Somewhat of a challenge: 5; 
Not a challenge: 0; 
Not applicable/don't know: 1; 
Total responses: 35. 

Agencies do not provide sufficient training to workers on allowable 
sharing; 
Extreme challenge: 9; 
Great challenge: 11; 
Moderate challenge: 9; 
Somewhat of a challenge: 3; 
Not a challenge: 0; 
Not applicable/don't know: 3; 
Total responses: 35. 

Agencies are concerned about the accuracy of data from other agencies; 
Extreme challenge: 5; 
Great challenge: 6; 
Moderate challenge: 14; 
Somewhat of a challenge: 6; 
Not a challenge: 1; 
Not applicable/don't know: 2; 
Total responses: 34. 

Agencies have outdated technology systems that are unable to share 
data securely; 
Extreme challenge: 16; 
Great challenge: 7; 
Moderate challenge: 5; 
Somewhat of a challenge: 4; 
Not a challenge: 2; 
Not applicable/don't know: 1; 
Total responses: 35. 

Source: GAO analysis of responses from the second of two surveys to 
the same group of stakeholders. 

Note: Totals may not add to 35 because not all respondents answered 
every question. 

[End of table] 

Table 9: Challenges Related to Income/Wage Data Sources: 

Question: In your opinion, how much of a challenge is each of the 
following items for state and local human services agencies as they 
balance the need to protect personal information while increasing the 
use of data sharing?. 

Responses: 

Existing data sources of income and wage information are not 
sufficiently timely; 
Extreme challenge: 8; 
Great challenge: 8; 
Moderate challenge: 7; 
Somewhat of a challenge: 2; 
Not a challenge: 0; 
Not applicable/don't know: 10; 
Total responses: 35. 

Agencies do not have sufficient access to existing federal data 
sources of income and wage information; 
Extreme challenge: 6; 
Great challenge: 6; 
Moderate challenge: 9; 
Somewhat of a challenge: 2; 
Not a challenge: 0; 
Not applicable/don't know: 12; 
Total responses: 35. 

Agencies do not have sufficient access to other states' income and 
wage information; 
Extreme challenge: 4; 
Great challenge: 8; 
Moderate challenge: 7; 
Somewhat of a challenge: 3; 
Not a challenge: 1; 
Not applicable/don't know: 12; 
Total responses: 35. 

Source: GAO analysis of responses from the second of two surveys to 
the same group of stakeholders. 

[End of table] 

Table 10: Potential Federal Agency Actions Suggested by Stakeholders 
to Address Challenges: Guidance and Models: 

Question: In your opinion, how useful would each of the following 
actions be if taken by federal agencies to address challenges that 
state and local human services agencies face in balancing the need to 
protect personal information while increasing the use of data sharing?. 

Responses: 

Provide coordinated multi-agency guidance that clarifies what data 
sharing is permissible; 
Extremely useful: 30; 
Very useful: 2; 
Moderately useful: 2; 
Somewhat useful: 1; 
Not at all useful: 0; 
Not applicable/don't know: 0; 
Total responses: 35. 

Provide guidance from individual federal agencies that clarifies what 
data sharing is permissible for the program the agency administers; 
Extremely useful: 21; 
Very useful: 9; 
Moderately useful: 2; 
Somewhat useful: 3; 
Not at all useful: 0; 
Not applicable/don't know: 0; 
Total responses: 35. 

Develop a model or provide existing examples of data sharing 
agreements that comply with federal privacy requirements; 
Extremely useful: 27; 
Very useful: 5; 
Moderately useful: 3; 
Somewhat useful: 0; 
Not at all useful: 0; 
Not applicable/don't know: 0; 
Total responses: 35. 

Develop model or provide existing examples of informed consent 
language (including possibilities for "opt out" provisions) that 
complies with federal privacy requirements; 
Extremely useful: 23; 
Very useful: 9; 
Moderately useful: 2; 
Somewhat useful: 1; 
Not at all useful: 0; 
Not applicable/don't know: 0; 
Total responses: 35. 

Identify and publicize examples of state and local agencies that have 
successfully addressed privacy-related challenges to data sharing; 
Extremely useful: 19; 
Very useful: 9; 
Moderately useful: 5; 
Somewhat useful: 2; 
Not at all useful: 0; 
Not applicable/don't know: 0; 
Total responses: 35. 

Communicate that the federal agency views data sharing as beneficial 
to the administration of human services programs; 
Extremely useful: 20; 
Very useful: 8; 
Moderately useful: 2; 
Somewhat useful: 4; 
Not at all useful: 0; 
Not applicable/don't know: 1; 
Total responses: 35. 

Provide technical assistance and training on relevant federal privacy 
requirements; 
Extremely useful: 14; 
Very useful: 13; 
Moderately useful: 7; 
Somewhat useful: 0; 
Not at all useful: 0; 
Not applicable/don't know: 1; 
Total responses: 35. 

Continue or increase the provision of funds for pilots and 
demonstration projects for data sharing, including those that address 
privacy-related challenges; 
Extremely useful: 23; 
Very useful: 9; 
Moderately useful: 3; 
Somewhat useful: 0; 
Not at all useful: 0; 
Not applicable/don't know: 0; 
Total responses: 35. 

Source: GAO analysis of responses from the second of two surveys to 
the same group of stakeholders. 

[End of table] 

Table 11: Potential Federal Agency Actions Suggested by Stakeholders 
to Address Challenges: Federal Requirements: 

Question: In your opinion, how useful would each of the following 
actions be if taken by federal agencies to address challenges that 
state and local human services agencies face in balancing the need to 
protect personal information while increasing the use of data sharing?. 

Responses: 

Identify statutory limits to data sharing that Congress should 
consider changing; 
Extremely useful: 16; 
Very useful: 11; 
Moderately useful: 4; 
Somewhat useful: 1; 
Not at all useful: 1; 
Not applicable/don't know: 1; 
Total responses: 34. 

Review and harmonize non-statutory requirements to ensure more 
standardized privacy rules for data sharing across human services 
programs and agencies; 
Extremely useful: 22; 
Very useful: 10; 
Moderately useful: 1; 
Somewhat useful: 2; 
Not at all useful: 0; 
Not applicable/don't know: 0; 
Total responses: 35. 

Review non-statutory privacy requirements across human services 
programs to ensure rules are appropriate for current available 
technologies; 
Extremely useful: 20; 
Very useful: 12; 
Moderately useful: 2; 
Somewhat useful: 1; 
Not at all useful: 0; 
Not applicable/don't know: 0; 
Total responses: 35. 

Revise the Family Educational Rights and Privacy Act (FERPA) to ensure 
child welfare agencies have access to education records (or recommend 
congressional action if necessary); 
Extremely useful: 25; 
Very useful: 4; 
Moderately useful: 1; 
Somewhat useful: 1; 
Not at all useful: 0; 
Not applicable/don't know: 4; 
Total responses: 35. 

Create consistent standards for data security across programs and 
agencies; 
Extremely useful: 22; 
Very useful: 6; 
Moderately useful: 5; 
Somewhat useful: 1; 
Not at all useful: 0; 
Not applicable/don't know: 0; 
Total responses: 34. 

Explore ways to expand access to federal sources of income and wage 
information; 
Extremely useful: 15; 
Very useful: 6; 
Moderately useful: 5; 
Somewhat useful: 1; 
Not at all useful: 1; 
Not applicable/don't know: 7; 
Total responses: 35. 

Source: GAO analysis of responses from the second of two surveys to 
the same group of stakeholders. 

Note: Totals may not add to 35 because not all respondents answered 
every question. 

[End of table] 

[End of section] 

Appendix IV: Delphi Survey Respondents: 

We asked 40 individuals from state and local human services agencies, 
IT providers, and research and advocacy organizations to complete two 
surveys about privacy and data sharing. For more information on our 
survey and selection methodologies, see appendix II. The following 
table lists the individuals from whom we received completed survey 
responses. 

Table 12: List of Individuals That Completed Survey Responses: 

Andrew Stettner: Seedco. 

Barbara Needell: University of California-Berkeley Center for Social 
Services Research. 

Beth Morrow: The Children's Partnership. 

Brenna Isman: National Academy of Public Administration. 

Carolyn Daffron: Solutions for Progress, Inc. 

Charles Simon: Case Commons, Inc. 

Cheryl Smithgall: Chapin Hall at the University of Chicago. 

Claudia Page: Social Interest Solutions. 

David Hansell: KPMG LLP. 

Dennis Culhane: University of Pennsylvania. 

Deven McGraw: Center for Democracy & Technology. 

Donna Younkin: New Jersey Department of Children and Families. 

Doug Robinson: National Association of State Chief Information 
Officers. 

Elizabeth Lower-Basch: Center for Law and Social Policy. 

Emily Putnam-Hornstein: University of Southern California. 

Ginger Zielinskie: Benefits Data Trust. 

Jerry Friedman: Accenture Human Services. 

Jim Jones: Sellers Dorsey. 

Jody Becker-Green: Washington Department of Social and Health Services. 

John Petraborg: Hewlett Packard. 

John Petrila: University of South Florida. 

Larry Bolton: California Department of Social Services. 

Larry Goolsby: American Public Human Services Association. 

Laurie O'Connor: Montgomery County (PA) Office of Children and Youth. 

Maura McInerney: Education Law Center. 

Matt Salo: National Association of Medicaid Directors. 

Patricia Martin: Circuit Court of Cook County (IL). 

Rebecca Gudeman: National Center for Youth Law. 

Richard Gold: Stewards of Change. 

Stan Dorn: Urban Institute. 

Steve Aragón: Texas Health & Human Services Commission. 

Sundhar Sekhar: Deloitte Consulting LLP. 

Susan Kinnevy: Philadelphia Department of Human Services. 

Tim Day: Teredata Corporation. 

Uma Ahluwalia: Montgomery County (MD) Department of Health & Human 
Services. 

Will Sanson: California Administrative Office of the Courts. 

William Travis, Jr.: New York State Office of Children and Family 
Services. 

Source: GAO. 

[End of table] 

[End of section] 

Appendix V: Comments from the Department of Health and Human Services: 

Department of Health & Human Services: 
Office of The Secretary: 
Assistant Secretary for Legislation: 
Washington, DC 20201: 

December 20, 2012: 

Kay E. Brown: 
Director, Health Care: 
U.S. Government Accountability Office: 
441 G Street NW: 
Washington, DC 20548: 

Dear Ms. Brown: 

Attached are comments on the U.S. Government Accountability Office's 
(GAO) report entitled, "Human Services: Sustained and Coordinated 
Efforts Could Facilities Data Sharing While Protecting Privacy" (GA0-
13-106). 

The Department appreciates the opportunity to review this report prior 
to publication. 

Sincerely, 

Signed by: 

Jim R. Esquea: 
Assistant Secretary for Legislation: 

Attachment: 

General Comments Of The Department Of Health And Human Services (HHS) 
On The Government Accountability Office's (GAO) Draft Report Entitled, 
"Sustained And Coordinated Efforts Could Facilitate Data Sharing While 
Protecting Privacy" (GAO-13106): 

The Department appreciates the opportunity to review and comment on 
this draft report. 

GAO Recommendation: 

To ensure that state and local human services agencies have additional 
information to help facilitate useful data sharing, we recommend that 
the Secretary of HHS ensure timely completion of the department's 
planned activities to clarify what data sharing is permissible under 
federal privacy requirements and consider other ways to bolster the 
efficacy of its efforts. For example, HHS could develop a strategy for 
the effective dissemination of its Confidentiality Toolkit and 
consider ways to solicit and incorporate feedback on the information's 
usefulness from a range of users. 

HHS Response: 

HHS concurs with GAO's recommendation and is in the process of 
refining the Confidentiality Toolkit. Once that process is completed, 
we will engage interested stakeholders in providing feedback on the 
Toolkit's usefulness. Based on their recommendations, further 
refinement may be made and then it will be disseminated to state and 
local human service agencies. 

[End of section] 

Appendix VI: GAO Contacts and Staff Acknowledgments: 

GAO Contact: 

Kay E. Brown, (202) 512-7215 or brownke@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Gale Harris, Theresa Lo, 
Michael Pahr, and Vernette Shaw made significant contributions to all 
aspects of this report. Also contributing to this report were David 
Chrisinger, Sarah Cornetto, Jean McSween, Mimi Nguyen, Nhi Nguyen, and 
Almeta Spencer. 

[End of section] 

Footnotes: 

[1] We have reported on other challenges to data sharing; see for 
example GAO, Human Services Integration: Results of a GAO Cosponsored 
Conference on Modernizing Information Systems, [hyperlink, 
http://www.gao.gov/products/GAO-02-121] (Washington, D.C.: Jan. 31, 
2002). Also see GAO, Means-Tested Programs: Determining Financial 
Eligibility Is Cumbersome and Can Be Simplified, [hyperlink, 
http://www.gao.gov/products/GAO-02-58] (Washington, D.C., Nov. 2, 
2001) for information on challenges involved in improving the 
administration of human services programs. 

[2] The term "privacy" has multiple definitions, and in some 
circumstances, certain aspects of privacy may be specifically defined 
in statutes or regulations. For purposes of this report, we are using 
the term broadly to refer to the appropriate protection of personal 
information that is individually identifiable, which may involve 
restrictions on who may access the information and for what purposes. 
This definition includes information that is considered confidential 
under program statutes. 

[3] Pub. L. No. 93-579, 88 Stat. 1896 (1974), codified as amended at 5 
U.S.C. § 552a. 

[4] Pub. L. No. 104-191, §§ 262, 264, 110 Stat. 1936, 2021-30 (1996), 
codified as amended at 42 U.S.C. §§ 1320d to 1320d-9; and Pub. L. No. 
93-380, § 513, 88 Stat. 484, 571 (1974), codified as amended at 20 
U.S.C. § 1232g. 

[5] Although we solicited feedback from state and local officials on 
the challenges and benefits they experienced, we did not independently 
evaluate these efforts. 

[6] Officials selected in this sector were not from any of our four 
sites. 

[7] The Delphi method follows a structured process for collecting and 
distilling knowledge from a group through a series of questionnaires. 
For our purposes, we employed two iterative web-based surveys. 

[8] We also vetted our initial list of stakeholders with key 
representatives from the American Public Human Services Association 
and the Collaborative Forum, a group established by the Office of 
Management and Budget (OMB) that draws on federal, state, and other 
stakeholder expertise to help develop pilot projects to improve how 
states administer federally-funded assistance programs. 

[9] Specific processes of applying for human services may differ 
across states and programs. 

[10] GAO has reported in prior work that human services programs, 
which can suffer from siloed and inefficient service delivery, could 
benefit from greater data sharing. For example, see Human Services 
Programs: Opportunities to Reduce Inefficiencies, [hyperlink, 
http://www.gao.gov/products/GAO-11-531T], (Washington, D.C.: April 5, 
2011) and GAO, Benefit and Loan Programs: Improved Data Sharing Could 
Enhance Program Integrity, [hyperlink, 
http://www.gao.gov/products/GAO/HEHS-00-119] (Washington, D.C.: Sept. 
13, 2000). 

[11] GAO, Child Care and Development Fund: Undercover Tests Show Five 
State Programs Are Vulnerable to Fraud and Abuse, [hyperlink, 
http://www.gao.gov/products/GAO-10-1062] (Washington, D.C.: Sept. 22, 
2010). 

[12] Improper payments include, for example, overpayments and 
underpayments. For the statutory definition of improper payment, see 
31 U.S.C. § 3321 note. The Improper Payments Information Act of 2002 
requires executive branch agencies to annually identify programs and 
activities susceptible to significant improper payments, estimate the 
amount of improper payments for such programs and activities, and 
report these estimates along with actions taken to reduce them. Pub. 
L. No. 107-300, 116 Stat. 2350 (2002). The Improper Payments 
Elimination and Recovery Act of 2010 and the Improper Payments 
Elimination and Recovery Improvement Act of 2012 expanded these and 
other requirements for identifying and recovering overpayments across 
a broad range of federal programs. Pub. L. No. 111-204, 124 Stat. 2224 
(2010), Pub. L. No. 112-248, 126 Stat. 2390 (2013). For an example of 
recent GAO work in this area, see GAO, Improper Payments: Remaining 
Challenges and Strategies for Governmentwide Reduction Efforts, 
[hyperlink, http://www.gao.gov/products/GAO-12-573T] (Washington, 
D.C.: March 28, 2012). 

[13] For example, see Jane Waldfogel, "Reforming Child Protective 
Services," Child Welfare, vol. 79 no. 1 (Jan/Feb. 2000) and HHS, A 
Coordinated Response to Child Abuse and Neglect: The Foundation for 
Practice (Washington, D.C.: 2003). 

[14] The wrongful disclosure or use of personal information could 
result in substantial harm, embarrassment, and inconvenience to 
individuals. GAO has reported on the importance of establishing proper 
privacy protections and security controls for personal information. 
For example, see GAO, Information Security: Protecting Personally 
Identifiable Information, [hyperlink, 
http://www.gao.gov/products/GAO-08-343], (Washington, D.C.: Jan. 5, 
2008). 


[15] 42 U.S.C. § 602(a)(1)(A)(iv). See also 45 C.F.R. § 205.50. 

[16] 42 U.S.C. §§ 654(26), 654a(f)(3). See also 45 C.F.R. §§ 303.21, 
307.11(f), 307.13. 

[17] We have previously reported that SSNs can be useful tools to 
enhance program integrity through data matching. However, government 
agencies need to take steps to prevent the improper disclosure of 
SSNs, including limiting the use and display of SSNs in public records 
as they are a key piece of information that can be used to perpetuate 
identity theft. GAO's prior work has examined the collection, display, 
and protection of SSNs in public and private records. For example, see 
GAO, Social Security Numbers: Use Is Widespread and Protection Could 
Be Improved, [hyperlink, http://www.gao.gov/products/GAO-07-1023T] 
(Washington, D.C.: June 21, 2007). 

[18] We did not conduct any independent legal analysis of the data 
sharing systems developed by our selected sites. 

[19] For example, see GAO, Improper Payments: Moving Forward with 
Governmentwide Strategies, [hyperlink, 
http://www.gao.gov/products/GAO-12-405T] (Washington, D.C.: Feb. 7, 
2012); Child Care and Development Fund: Undercover Tests Show Five 
State Programs Are Vulnerable to Fraud and Abuse, [hyperlink, 
http://www.gao.gov/products/GAO-10-1062] (Washington, D.C.: Sept. 22, 
2010); and Benefit and Loan Programs: Improved Data Sharing Could 
Enhance Program Integrity, [hyperlink, 
http://www.gao.gov/products/GAO-00-119] (Washington, D.C.: Sept. 13, 
2000). 

[20] Under the SNAP program, USDA is required to impose financial 
sanctions on states with high error rates, but is authorized to take 
alternative actions, including waiving all or part of the sanction 
amount and/or requiring that some be reinvested to improve the state 
agency's administration of the SNAP program. 7 U.S.C. § 2025(c)(1). 

[21] A number of stakeholders did identify other specific requirements 
as a challenge. However, with the exception of FERPA, there was little 
consistency on which specific requirements were particularly 
challenging. When there were multiple mentions of a requirement (e.g., 
protections for tax information), stakeholders did not necessarily 
name the same aspect as challenging (e.g., one stakeholder noted that 
the security standards for safeguarding tax data are burdensome, while 
another cited state agencies' inability to access tax data as a 
challenge). 

[22] See appendix II for more information on our methodology. 

[23] Since we surveyed the stakeholders, the Uninterrupted Scholars 
Act was enacted in January 2013, which may address the challenges 
described with respect to FERPA. This law, which amends FERPA, is 
discussed later in this report. 

[24] 42 U.S.C. § 675(1)(C). 

[25] Pub. L. No. 110-351, 122 Stat. 3949 (2008). Among other 
provisions, the act requires that the case plan for each child in 
foster care include "a plan for ensuring the educational stability of 
the child," including assurances that the foster care placement takes 
into account the appropriateness and proximity of the current 
educational setting. 42 U.S.C. § 675(1)(G). 

[26] Prior to the enactment of the Uninterrupted Scholars Act in 
January 2013, child welfare agencies were not one of the specifically 
enumerated entities to whom schools or educational agencies may 
disclose education records without parental consent. FERPA does 
authorize disclosure of records with the parent's written consent or 
to comply with a judicial order or subpoena, provided the parents are 
notified. See 20 U.S.C. §§ 1232g(b)(1)-(2). In some cases, child 
welfare agencies may also access records as a parent. Although FERPA 
does not define "parent," Education's regulations define it to include 
"a natural parent, a guardian, or an individual acting as a parent in 
the absence of a parent or a guardian." 34 C.F.R. § 99.3. Education 
officials explained that if a child welfare agency is the child's 
"guardian" under state law, or the child's legal custodian under state 
law acting in the absence of a parent or guardian, the child welfare 
agency could access records under FERPA as a parent. See 20 U.S.C. § 
1232g(a)(1)(A)-(B). 

[27] See appendix II for more information on our methodology. 

[28] Depending on program requirements, participants may not be 
allowed to opt in or out of disclosure of their data. For instance, 
federal requirements for SNAP do not allow SNAP participants to opt in 
or out of disclosure of their data for specific purposes, including 
the administration or enforcement of SNAP, other federal assistance 
programs, or certain federally-assisted state programs. 

[29] FERPA was amended in January 2013 by the Uninterrupted Scholars 
Act and is discussed later in this report. 

[30] 20 U.S.C. § 1232g(a)(2). 

[31] See 20 U.S.C. §§ 1401(23), 1412(a)(8), 1417(c), 34 C.F.R. §§ 
300.30(a), § 300.622(a). 

[32] Pub. L. No. 112-278, 126 Stat. 2480 (2013). The Uninterrupted 
Scholars Act prohibits redisclosure of the education records or 
personally identifiable information except to an authorized individual 
or entity engaged in addressing the student's education needs, 
consistent with applicable state confidentiality laws. The act further 
provides that education records may be released pursuant to a court 
order issued in the context of a child abuse and neglect or dependency 
matter without additional notice to a parent, when the parent is a 
party to the court proceeding. 

[33] The Middle Class Tax Relief and Job Creation Act of 2012, Pub. L. 
No. 112-96, 126 Stat. 156, and the Child and Family Services 
Improvement and Innovation Act, Pub. L. No. 112-34, 125 Stat. 369 
(2011). 

[34] Specifically, we interviewed officials with the following 
agencies and departments regarding data sharing challenges and 
potential federal actions, including actions already taken or planned 
by the agency: Department of Agriculture's Food and Nutrition Service; 
Department of Education; Department of Health and Human Services' 
(HHS) Administration for Children and Families; HHS's Office of the 
Assistant Secretary for Planning and Evaluation; HHS's Centers for 
Medicare and Medicaid Services; and the Office of Management and 
Budget. 

[35] We did not independently evaluate these efforts. 

[36] Officials selected from this sector were not from any of our four 
sites. 

[End of section] 

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