NCSCSEA Resolution on Reengineering Federal Requirements Related to Information Systems May 1999

The National Council of State Child Support Enforcement Administrators resolves that:

NCSCSEA support OCSE's effort to reengineer the certification process to review only the changes required under PRWORA and to offer incremental reviews. NCSCSEA also recommends continued reengineering and streamlining the process by considering state self-assessments combined with review of the test deck and performance measures in lieu of on-site visits and interviews.

OCSE work with states to reengineer the Advanced Planning Document (APD) process to allow states flexibility and to reduce the administrative burden at both the state and federal level. Just as the APD is a work in progress, so are state systems. Therefore, OCSE should eliminate the requirement for approval over change orders and contract extensions. In addition, since certification requirements are not a state option, OCSE should eliminate the requirement for cost/benefit analyses.

OCSE recognize that operating the new national data bases puts OCSE in a position of possibly impacting all states with any minor and major changes. OCSE should seek advice from states, who have considerable experience, in the areas of evaluating the impact of changes on 54 different operations and systems, keeping the state user community informed and other operational issues.

OCSE recognize that states need relief from the demands of PRWORA system requirement deadlines at the same time that Y2K is the national top priority. OCSE should examine all the demands and postpone implementation where possible. Areas for relief include but are not limited to:

1) Allow states to stop spending resources on CSENET until direct file transfer is available and all CSENET usage and transaction requirements are clearly defined.

2) Postpone the implementation of AEI until after 1/1/2000 while OCSE considers alternatives to this cumbersome process.

3) Allow flexibility on a state by state basis on meeting the deadlines for implementation of a state disbursement unit. Meeting the deadline for this requirement, in particular, could put low income families in jeopardy.

Background

The child support enforcement program is increasingly dependent on technology to continue the record of improvements in the program. Increasing caseloads and changing federal requirements combined with a static and in some cases a decreasing workforce make automation the only option for keeping up with the demands of the child support program. States are constantly reevaluating and reengineering business practices to incorporate technology and to streamline processes. Each state is unique and the solutions for successful automation vary from state to state. Federal government processes however tend to view all states in the same way. The Advanced Planning Document approval requirements and the system certification process perpetuate the "all states are alike" model. While NCSCSEA recognizes that the significant amounts of federal money that fund state child support systems necessitate some federal oversight, the existing requirements are cumbersome, burdensome and create barriers to states' successful use of technology.

A critical issue facing the entire country is the Year 2000 (Y2K) crisis. All states have made ensuring uninterrupted service delivery in the next millennium a priority. Attending to the Y2K priority has usurped resources in the child support program that would ordinarily be dedicated to other automation initiatives. Although the federal government has made Y2K a priority, as well, OCSE has not yet addressed the issue of how it can assist states in meeting the Y2K problem by waiving or extending deadlines imposed by the Personal Responsibility Work Opportunity and Reconciliation Act of 1996.