Child Support Enforcement: Strong Leadership Required to Maximize Benefits of Automated Systems

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

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

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

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

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

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

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