Child Support Report

Vol. XXVI, No. 7, Jul 2004

Child Support Report is a publication of the Office of Child Support Enforcement, Division of Consumer Services. CSR is published for information purposes only. No official endorsement of any practice, publication, or individual by the Department of Health and Human Services or the Office of Child Support Enforcement is intended or should be inferred.

Avoiding and Collecting Arrears: Good Ideas from the Commonwealth of Puerto Rico Best Practice Series: Texas Employer Initiative ACF/State Information Systems Meeting Census Bureau Data Offers Customer Base Profile Health Providers May Disclose Health Information "Reunion Call" Reveals Tales of Contempt OCSE Welomes the New New York City IV-D Director Frances Pardus-Abbadessa

Avoiding and Collecting Arrears: Good Ideas from the Commonwealth of Puerto Rico

By: Jens Feck

Avoiding arrears through immediate and proactive intervention triggered by the prospect of substantial changes in economic circumstances has been a standard procedure in Puerto Rico since early 2001. For the last three years, a multi-agency Rapid Response Task Force, which includes an Administration for Child Support (ASUME - the Spanish acronym for the IV-D Agency) component, has been sent to every employer announcing mass layoffs or permanent closures of facilities. The visits are conducted before the date of the announced event, and they take place at the site of employment, during working hours and at the employer's expense.

Rapid Response Task Force activities are coordinated by the Commonwealth Department of Labor's "Unit for Dislocated Workers and Employers" in accordance with Workforce Investment Act provisions. The Task Force's ASUME component identifies and assists both custodial and non-custodial parents by providing information and services via wireless ACSES-connected laptops with respect to modifications, income withholdings and payment plans. Employers in turn are advised of the applicability of income withholding orders to severance and other payments owed to displaced workers.

Additional services provided by the Task Force include resume-writing skills and information about local job and training opportunities. At over 112 employment sites, 3,131 employees have benefited from IV-D related services as of March 2004; and ASUME's pro-active order modification service has most likely prevented the potential accumulation of an incalculable amount of "unwarranted" arrears.

What about IV-D cases where arrears are "justifiable" because they accumulated due to the willful failure to comply with the order? ASUME has found that the most efficient and cost-effective way to identify delinquent obligors who fall into this "able but unwilling to pay" category is to identify delinquent obligors with liquid assets. This is an especially effective strategy with respect to obligors who have developed an expertise in concealing sources of income but who still prefer to invest that income over hiding it in the cookie jar.

The Financial Institution Data Match (FIDM) process is the tool of choice when it comes to finding these financial assets that legally and morally belong to children; but it often produces tremendous amounts of data that the receiving IV-D jurisdiction must analyze and act upon. When action is deemed appropriate, each individual "freeze and seize" action may require the exchange of a number of hardcopy documents. The entire process may therefore be time-consuming, labor-intensive and subject to human error.

Not so in Puerto Rico! ASUME and Puerto Rico's largest financial institution, Banco Popular, have developed a fully automated, paperless data match and levy process to effectively address the volume of data created through the quarterly match process. No other IV-D jurisdiction can boast of a fully automated process - one reason why ASUME received this year's Annual Information Technology award from Puerto Rico's IT Professional Association (ADSEI - its Spanish acronym.)

ASUME is fortunate in that Banco Popular is also its SDU vendor, and the bank is familiar with, and committed, to the goals of child support programs. But in the end, a cost-benefit analysis - based on expectations of 2,000 to 4,000 quarterly levies - and the bank's strict policy to process levies received before 2:30pm by the end of that day pointed to automation as the only sensible solution.

The first fully automated match and levy process in a production environment occurred in December of 2003, with the initial hold file identifying 2,592 cases for $1,239,164 and the final payment file transferring $695,338 for 1,989 cases. Outstanding ATM and check transactions are cleared, and automatically generated bank exception files are eliminated, before the ASSUME holds are effected. This accounts for the difference between identified and actual cases and collections.

ASUME is actively working to increase the scope of the match (currently limited to checking and savings accounts), and other PR financial institutions, such as Banco Santander, are in line to automate the process as well. ASUME has presented details of this pioneering practice to IV-D Directors, multi-state financial institution representatives and Federal staff at a recent MSFIDM Federal Levy Process meeting in Washington DC., where it was favorably received and being considered for national application.

So the next time you think of the Caribbean, don't just think of sunshine. Think automation! (Special thanks to Pedro Dohnert, PR IV-D system manager, Rebeca Dorna Pesquera, PR IV-D press liaison, and Sherri Grigsby, OCSE MSFIDM liaison, for their contributions to this article.)

Best Practice Series: Texas Employer Initiative

By: Honi Canon

The Texas Office of the Attorney General's Child Support Division initiated four projects to achieve several goals.

These goals are:

• To improve communication and the exchange of information with employers
• Increase child support collections from income withholding by employers
• Improve customer service to employers

Description of the Four Projects

1. Improve Timeliness of Quarterly Wage Data: In Texas, quarterly wage data come to the Child Support Division (CSD) via an interface with the Texas Workforce Commission. The data are used to update our employer records.

Previously, the Texas Workforce Commission waited to provide wage information until all wages from employers for the quarter were reported and entered. This process delayed receipt of the data from four to five months after the wages were earned. Because of the age of the data, we issued verification of employment letters before sending a wage withholding order to ensure the non-custodial parent was still employed. This resulted in missed collections. Also, the non-custodial parents had often changed jobs by the time the income withholding order was received.

The CSD implemented new procedures with the Texas Workforce Commission to provide more timely data. The new process sends wage data to CSD monthly as it is reported. This has resulted in CSD issuing an average of 8,000 wage withholding notices per month in the second and third months after a quarter ends. In addition, verification of employment letters are no longer sent prior to issuing a wage withholding order since the data are now current.

As part of this effort, CSD obtained employers' payroll address information to ensure that wage withholding notices were sent to the proper place. Employer records were closed automatically on cases where wages were not reported within the previous two quarters.

Results: During fiscal year 2003, Texas collected over $22 million due to improvements in quarterly wage data. Ongoing collections average $3 million per month.

2. Employer Data Match: Texas entered into a contract with the largest provider of human resource payroll and benefits verification services to obtain access to 2,200 employers' payroll records via an electronic interface. This interface produced 6,530 wage withholding orders for the four months between September 4, 2003 and December 31, 2003 and yielded $1,904,498 for that time period. The percentage of paying cases is considerably higher compared to some of the other interfaces. This is due to the timely reporting of wages and data on the interface allowing CSD to only accept recent wages.

Results: Almost all verification of employment letters are eliminated for employers who use this employment and verification service. Major effort was expended to clean up records to ensure wage withholding orders were sent to the proper place. In addition, there was a reduction in correspondence that employers received from us after an employee terminated as a result of regular payroll data submissions by employers which closed out employment records.

3. Income Order/Notice Improvements: Several system edits were implemented to increase the accuracy and timeliness of issuance of wage withholding notices. Changes were put in place to reduce the mailing of duplicate notices, the number of notices sent to deceased parties, and the number of notices sent on cases that are flagged for closure. These edits prevented issuance of 17,422 erroneous wage withholding notices between August 28, 2003 and November 12, 2003, and provided a cost savings of $365,862 for postage and filing fees.

Results: The system edits reduced the number of wage withholding notices sent in error, the number of complaints from employers due to erroneous payment amounts, and the amount of time employers spent with CSD staff to identify errors.

4. Employer File Enhancements: Texas implemented commercial software in September 2003 that performed address validation for adding employer information. The automated screens for employer updates were changed to increase search capabilities so staff could search for payroll addresses. These payroll addresses were verified by CSD staff to ensure accurate payroll information for issuing wage withholding orders.

A Federal Employer Identification Number (FEIN) data correction updated Texas' automated employer file for cases where the master records and the member records did not match. This resulted in the correction of two million records by enhancing successful matches from incoming interfaces to prevent duplicate employer records from being added.

Employer interface table changes route each of the main employer interfaces through the same employer table to ensure each is choosing the same employer record. This interface also allows a separate medical benefits address for an employer record to issue the medical support notice to the correct location.

In addition, over 900,000 duplicate, invalid and incomplete employer records were deleted to ensure field staffs no longer select an invalid employer from an automated search. Removal of the bad employer records from our automated system increases the response time for employer searches.

Results: Wage withholding orders got to employers at the right location. Users reduced the amount of time spent researching employer records. Also, by matching employer federal identification numbers to employer records on the system, duplicate notices were not sent.

Funding: Regular IV-D funds were used.

ACF/State Information Systems Meeting

By: Robin Rushton

An ACF/State Information Systems Meeting (previously called the ACF Users Group Meeting) was scheduled in Portland, Oregon on August 18-19, 2004.

This meeting has been held semi-annually for over 22 years and was frequently cited by State systems staff as the most rewarding and informative meeting they attend. It began with a small group of people interested in sharing knowledge and experiences regarding development of FAMIS systems. It later was expanded to include child welfare, child support and child care systems. Information shared at these meetings results in cost savings for states. The format has always focused on individual participation instead of presentations. Each state is able to contribute as well as bring back new approaches, new technology solutions, and technical clarifications. Successes and failures are shared.

There has been a long history of state sponsorship at these meetings, and many states have devoted extensive resources to hosting their colleagues at this valuable meeting. However, state budgets are tight, and ACF/SIS has not been able to find a state to host the 2004 meetings. An ACF State Systems Summit was hosted in May 2004 and our colleagues from the APHSA-ISM have graciously requested a user's group meeting following their APHSA-ISM meeting.

The ACF State Information Systems Meetings are geared for project managers, IT managers, user support staff and program-policy administrators to assist state/county operations to successfully establish and maintain IV-A, IV-D, IVB/E or business application systems and to meet Federal fund ing and system requirements. The past ACF State Information Systems meetings attended by state I.T. staff have yielded many enhancements and cost savings to the IV-A, IV-D, IV-B/IV-E and Child Care systems. States that have implemented system enhancements based on information obtained from the meeting increased on-line response time for users and reduced the access time required by batch application programs. States attending past ACF State Information Systems meetings have also obtained innovative system enhancements from other states leading to improved worker productivity and efficiency.

It is now mission critical to re-think, re-evaluate or even re-engineer certain components within our current environment to meet the new technical challenges to be ever more responsive to the dynamic health and human service arena. New technologies with existing hardware and software resources are being discussed and states need to participate in those discussions to avoid negative impacts such as fiscal sanctions or program cost overruns.

Some of the sessions scheduled included: imaging, IMS to DB conversion, outbound Interactive Voice Response, using data warehousing for self assessment, Call Centers, updating legacy systems, and graphic user interfaces.

ACF posts general information about ACF/State Information Systems Meetings, as well as other information, such as Systems Project Status Updates, on the ACF/OCSE home page at ww.acf.dhhs.gov/programs/cse/stsys/!cse.htm

Census Bureau Data Offers Customer Base Profile

By: Frank Fajardo

Our article in the February 2004 issue illustrated that OCSE is continuously seeking to optimize program goals while working with a customer base affected by enormous changes in our communities (see "Program Leadership and Our Changing Customer Base" www.acf.dhhs.gov/programs/cse/pubs/2004/csr/csr0402.html ).

According to new estimates released in June by the Census Bureau, the Hispanic and Asian populations continued to grow at much faster rates than the U.S. population as a whole; see www.census. gov/Press-Release/www/releases/archives/race/001839.html

Hispanics accounted for about one-half of the nearly ten million residents added to the nation's population. In a little over three years, from after the 2000 Census through July 2003, the Hispanic population increased by 13% - four times the growth rate of the total population (3.3%). The Asian population increased by 12.5%, and native Hawaiians and other Pacific islanders by 5.8%.

Please note that the population of Hispanics may be of any race, since the U.S. Census treats "Hispanic origin" and "race" as separate and distinct concepts. The question on Hispanic origin asks respondents if they are Spanish, Hispanic or Latino; and starting with Census 2000, the question on race asks respondents to report the race or races they consider themselves to be (See U.S. Census Bureau Guidance on the Presentation and Comparison of Race and Hispanic Origin Data ).

For conducting your own local demographic analysis, you may try the steps below. You will need to decide what geographic area to search for demographic data (state, county, etc.):

Step 1: Census website: www.census.gov
Step 2: Click on "American Fact Finder" from menu on the left;
Step 3: Click on "Data Sets" from menu on the left;
Step 4: Select data set you want, e.g. Census 2000 Summary File 3 (SF3)
Step 5: From the options on the pop up menu on the right side, select "Detailed Tables"
Step 6: Select your "geographic type", "state", then click "Add", then "Next"
Step 7: Select one or more tables (hundreds to choose from), and click "Add"
Step 8: Click on "Show Result" to show detailed tables, with Links for additional searches.

United States Hispanic Population
Fast Growing		Largest
1. Georgia	435,227	1. California	10,966,556
2. Nevada	386386,504	2. Texas	6,669,666
3. North Carolina	378,963	3. New York	2,867,583
4. Tennessee	123,838	4. Florida	2,682,715
5. South Carolina	95,076	5. Illinois	1,530,262
6. Arkansas	86,866	6. Arizona	1,295,617
7. Alabama	75,830	7. New Jersey	1,117,191

Health Providers May Disclose Health Information

By: Elaine Blackman

Some people may wonder how to utter the acronym for the Health Insurance Portability and Accountability Act, known as HIPAA (commonly pronounced "hippa").

But a different sort of issue has surfaced since the Department of Health and Human Services issued, in 1996, HIPAA's privacy provisions for reporting health insurance information to child support agencies. Some employers and health insurance plan administrators have shown concern about disclosing, or have refused to disclose, health information required on the National Medical Support Notice (NMSN)-the form that state child support agencies must use to aid in enforcing health care coverage in a child support order. They cited HIPAA as the reason.

Now the HHS Office of Civil Rights-the staff responsible for oversight and guidance on the "accountability" portion of HIPAA-has cleared the air: The privacy rule permits a "covered entity to disclose protected health information to a 'law enforcement official' for law enforcement purposes in compliance with court orders, grand jury subpoenas, or certain written administrative requests."

Further, employees of IV-D child support agencies meet the definition of a law enforcement official since they are "empowered to investigate or conduct an official inquiry into a potential violation of law or to prosecute or otherwise conduct a criminal, civil, or administrative proceeding arising from an alleged violation of law."

To get the word out, OCSE included the entire explanation in a PIQ (Policy Interpretation Question) to state child support agencies in June, also posted at www.acf.hhs.gov/programs/cse.

"Reunion Call" Reveals Tales of Contempt

By: Elaine Blackman

In 1996, with 4,000 open child support cases, each with debts over $500, Washington State Division of Child Support embarked on a project to improve collections. It's a project that State IV-D program manager Jan Hentze said has revealed "a lot about the characteristics of hard-to-collect cases and the approaches that are most effective."

The state agency set up a special collections unit of three workers to focus on half the cases; the other half remained within regular field offices. None of the 4,000 had made payments for the preceding six months (except IRS offsets).

The three workers "aggressively" applied locate and collection methods including telephoning non-custodial parents, which proved the most effective means of communication, to discover reasons for nonpayment and to negotiate payment of even minimal amounts.

The results-"significantly" higher payments from the group randomly assigned to the special unit, said Hentze, with collections greatest in arrears-only cases and in non-assistance cases. Some field offices have since followed suit with the special unit approach. Field office workers post best practices on the agency's Web site, and monthly tele-talks offer a forum to exchange ideas.

Representatives from ten jurisdictions and Federal staff from Regions I, IV, V, VII, and IX, and OCSE listened to Washington State's experience in a conference call last March about "Contempt and Its Alternatives." The "reunion call" was one in a series designed for participants from large urban areas to discuss common problems and helpful interventions. The participating jurisdictions included Alameda, CA.; Allegheny, PA.; Cook, ILL.; Dallas, TX.; Essex, NJ.; Fulton, GA.; Hennepin, MN.; Milwaukee, WI.; Orange, FL.; and Wayne, MI.

Bill Schwartz and Lorraine Cain reported on the process of the Criminal Prosecution Division of the Los Angeles Child Support Services Department that focuses on prosecuting failure-to-pay child support crimes with the objective of securing payment. The division targets non-custodial parents who have sufficient means to fulfill their obligations but choose not to.

Pat Brady and Maureen Leif explained that Arapahoe County, CO., began using civil contempt proceedings four years ago and handle some 1,500 contempt actions per year which generate $130,000-$150,000 in collections per month.

The two noted that a key to successful processing of contempt matters is to keep the case open with the court for as long as possible to avoid having to repeatedly serve [non-custodial parents] who pay sporadically.

Mary Brennan described the growth of Michigan's efforts to generate child support revenues through bank liens. The Financial Institution Data Matches (FIDM) have provided: substantial increases in collections; dramatic reductions in arrears, identification of addresses of noncustodial parents at the time they engaged in their last banking transaction; generation of a good deal of satisfaction among custodial parents, and reduction in the number of court proceedings required.

The next Child Support Report article in this series will summarize a reunion call about simplifying and automating review and adjustment. For further information about reunion calls sponsored by the Urban Academy, contact Bob Clifford at 215-861-4047.

OCSE Welomes the New New York City IV-D Director Frances Pardus-Abbadessa

OCSE Welomes the New New York City IV-D Director Frances Pardus-Abbadessa

Child Support Report is a publication of the Office of Child Support Enforcement, Division of Consumer Services. CSR is published for information purposes only. No official endorsement of any practice, publication, or individual by the Department of Health and Human Services or the Office of Child Support Enforcement is intended or should be inferred. Internet: http://www.acf.dhhs.gov/programs/cse/ Permission to reprint articles is granted Acknowledging CSR is appreciated

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