This document is intended to explore the approaches associated with going “live” with the new IRI model. Regardless of when IRI is implemented in a state, interstate cases will exist in that caseload. Providing guidance on the way these existing cases should be handled will be an important factor in standardizing and successfully operationalizing IRI.

There are two main approaches that seem viable. The first method, called “Point in Time”, leaves existing cases alone and only processes new cases according to the new IRI rules. The second method, called “Conversion”, changes the way existing interstate cases are handled, so that all cases (new and old) are processed in accordance with IRI rules.

Point in Time

Pro	Con
Existing cases will not have a disruption in their current level of service.	Automated systems will need to be able to distinguish between existing and new cases.
Case workers already know how to work pre-IRI cases.	Case workers will need training on two types of interstate case processing.
Gradual transition to new process and rules as new cases are opened and existing cases are closed or transitioned to the new model for other reasons.	Procedures training and systems will need to maintain and support two different kinds of case processing until all existing cases are closed or transitioned.
No special programs will need to be written and tested to convert existing cases.	Existing Responding cases will not have payments proportionately allocated to arrears for all states with assigned arrears.
DCO only needs to be completed as case situation requires it.	“One order world” will be delayed for years.
Delays in implementation, from state to state, will have a limited impact on how cases are processed.	Cases with identical characteristics will be treated differently.

Conversion

Pro	Con
Automated systems will not need to be able to distinguish between existing and new cases.	Potential for existing cases to have a disruption in their current level of service.
Case workers will only need to know one type of interstate case processing.	Case workers will all have to be retrained on how to work IRI cases.
Procedures training and systems will need to maintain and support only one kind of case processing	Immediate transition to new process and rules as new and existing cases are worked using new rules.
All cases and states will be sharing assigned arrears proportionately.	Special programs will need to be written and tested to convert existing cases, including the sharing of assigned arrears and other accounting records.
“One order world” will only take months.	DCOs will need to be completed on all cases prior to implementation, which will require commitment of time and resources.
Cases with identical characteristics will be treated the same.	Delays in implementation, from state to state, will have an immediate impact on how cases are processed.

“Point in time” is the method that the IRI workgroup envisioned and there seems to be a fair amount of consensus around this approach. A way to gain the benefits of the IRI model would be to develop a transition approach. A brief description of how this might work follows.

Do not convert or change data or processing on existing interstate cases to force them out or in a particular remedy for closure/modification. Each enforcement remedy would be modified based on IRI rules. Each program would have logic that says if a case is already at an enforcement remedy, before updating or sending it with additional information, interrogate it to see if it should stay there. This will also take care of cases that are legitimately at an enforcement remedy but the case structure changes e.g., intrastate case becomes an interstate case and should be viewed through the IRI model, or a DCO changes the landscape.

As interstate cases go through their enforcement remedies, send or stop them per the IRI model. For example, a responding case that has Lottery, States Tax intercept, Federal Tax intercept Credit Bureau Reporting, license suspension and a wage withholding all ongoing in a 1992 interstate case. IRI is implemented. Everything stays "status quo", however, as time marches on, for each enforcement remedy do the following:

State Lottery - continue submitting - it's that State's remedy

State Tax intercept - continue submitting - it's that State's remedy

State License suspension - continue submitting - it's that State's remedy

Federal Tax intercept - leave the existing case at Tax Offset UNTIL the next time it has to be processed for updating or submission (e.g., weekly, monthly, yearly updating). At that time the program should see it's an interstate case, apply the IRI "rules" realize that Federal Tax intercept is NOT an appropriate remedy and delete it.

Credit Bureau Reporting - Same as Federal Tax Offset - When it comes time to update the information reported to the Credit Bureau (usually monthly), if the IRI "rules" sees that it's a case which should not be submitted the system should process it for deletion. Again, it gets deleted in the normal run with all other legitimate deletes sent during the month.

Wage withholding - same as Federal Tax + Credit Reporting - if there is an income withholding in place it should be left alone. However, if he/she stops paying, and it comes time to enforce or issue a new withholding notice the system should probably send a notice to the other State advising them of the situation asking if they should continue to enforce or will they pick up the ball and issue the next withholding notice. The problem with these cases is the order was probably issued out of the responding State and it's not going to be that easy to just turn it around. This is much less clear-cut than the others.

Again, this discussion focuses on the case management side of limited services, especially enforcement issues. This will still leave two systems in place for years with the associated issues surrounding training and programming for two systems, but it addresses the customer service and “fairness” aspects of the “point in time” approach.

I would appreciate everyone's careful review of this document. Agreement or disagreement with the pros and cons, additional Ps & Cs, assessment of the 'transition' approach and any other ideas about implementing IRI that address the systems, training, customer service and fairness issues are welcome.