State Monitoring of Program Standards Implementation
April 27, 1993
State Monitoring of Program Standards Implementation
(April 27, 1993)
TO:STATE AGENCIES ADMINISTERING CHILD SUPPORT ENFORCEMENT PLANS APPROVED UNDER TITLE IV-D OF THE SOCIAL SECURITY ACT AND OTHER INTERESTED INDIVIDUALS
SUBJECT:State Monitoring of Program Standards Implementation
PURPOSE:The purpose of this IM is to share information about how some States have approached implementation and monitoring of Federal standards for program operations. Recognizing the value of these timeframe standards as a management tool for improving program efficiency and service to clients, States have adopted a variety of approaches to implementing them. States are encouraged to modify these approaches and tailor them to their own child support enforcement programs. However, highlighting a particular approach does not imply that it fully complies with Federal requirements.
BACKGROUND:The Family Support Act of 1988 (P.L. 100-485) required that timelimits be established within which States must accept and respond to requests for assistance in establishing and enforcing child support orders. This included requests to locate absent parents, establish paternity, initiate proceedings to establish and collect support awards, and distribute amounts collected as child support. Final regulations specifying standards for processing IV-D cases and timeframes for distributing collections were issued on August 4, 1989. Effective October 1, 1990, States were required to comply with these new requirements. The standards were established to ensure appropriate and expeditious processing of IV-D cases.
To help States improve their performance and achieve compliance with Federal program standards requirements, OCSE has identified a number of States that have developed internal systems to actively review and monitor their own activities in this area. These state-specific descriptions contain a variety of exemplary practices that may be helpful to other States.
ATTACHMENTS: The following discussion highlights seven States (California, Connecticut, Delaware, Mississippi, Missouri, Montana, and Washington) and describes their efforts in working with program standards timeframes. These States are at varying stages of completing the development/modification of their
automated systems to meet the 1988 Family Support Act automation requirements. A contact person and phone number is given for each State so that States may exchange information directly. Samples of forms and other materials developed by these States are included as illustrations.
INQUIRIES TO: ACF Regional Administrators
Robert C. Harris
Acting Deputy Director
Office of Child Support
STATE MONITORING OF
PROGRAM STANDARDS IMPLEMENTATION
U.S. Department of Health and Human Services
Administration for Children and Families
Office of Child Support Enforcement
STATE MONITORING OF
PROGRAM STANDARDS IMPLEMENTATION
TABLE OF CONTENTS
Introduction. . . . . . . . . . . . . . . . . . . 1
State Review and Monitoring Efforts . . . . . . . . . 2
California . . . . . . . . . . . . . . . . . . . 2
Connecticut . . . . . . . . . . . . . . . . . . . 7
Delaware . . . . . . . . . . . . . . . . . . .10
Mississippi . . . . . . . . . . . . . . . . . . .17
Missouri . . . . . . . . . . . . . . . . . . .24
Montana . . . . . . . . . . . . . . . . . . .26
Washington . . . . . . . . . . . . . . . . . . .29
Conclusion . . . . . . . . . . . . . . . . . . .30
The purpose of this document is to share information about how some States have approached implementation and monitoring of Federal standards for program operations. Recognizing the value of these timeframe standards as a management tool for improving program efficiency and service to clients, States have adopted a variety of approaches to implementing them. States are encouraged to modify these approaches and tailor them to their own child support enforcement programs. However, highlighting a particular approach does not imply that it fully complies with Federal requirements.
The Family Support Act of 1988 (P.L. 100-485) required that time limits be established within which States must accept and respond to requests for assistance in establishing and enforcing child support orders. This included requests to locate absent parents, establish paternity, initiate proceedings to establish and collect support awards, and distribute amounts collected as child support. Final regulations specifying standards for processing IV-D cases and timeframes for distributing collections were issued on August 4, 1989. Effective October 1, 1990, States were required to comply with these new requirements. The standards were established to ensure appropriate and expeditious processing of IV-D cases.
To help States improve their performance and achieve compliance with Federal program standards requirements, OCSE has identified a number of States that have developed systems to actively review and monitor their own activities in this area. The following discussion highlights seven States (California, Connecticut, Delaware, Mississippi, Missouri, Montana, and Washington.) These States are at varying stages of completing the development/modification of their automated systems to meet the 1988 Family Support Act's automation requirements. We hope that these state-specific descriptions contain a variety of exemplary practices that my be helpful to other States. Samples of forms and other materials developed by these States are included as illustrations.
A contact person and phone number is given for each State so that States may exchange information directly.
STATE REVIEW AND MONITORING EFFORTS
In 1990 the California legislature passed a law requiring the State Department of Social Services (DSS) to develop a two-tiered, performance-based incentive system for the Child Support Enforcement Program. The objective of this law was to ensure compliance with Federal program standards' case processing timeframe requirements, thereby improving program performance, increasing child support collections, and placing the State in a more favorable position for future Federal audits.
This law requires that each of the 58 county IV-D programs be subject to annual reviews to determine compliance with program performance standards in order to benefit from a complex, but generous two-tier State incentive. The first tier provides a base incentive rate and an additional compliance rate for counties which meet the case processing standards. If a county is found to be out of compliance, it must develop a corrective action plan and submit it to DSS. Counties under a corrective action plan are assessed on a quarterly basis and do not receive the State incentive until compliance is achieved. The second tier provides an additional incentive rate for performance in certain program components (i.e., establishment of paternity, establishment of support orders, etc.) and collection increases.
The tier I base incentive began in January 1992 at 10 percent and will decrease annually each
July 1 by one percent until July 1, 1995 at which time it becomes six percent for that year and thereafter. The tier I compliance rate started at one percent and increased by one percent each July 1 until July 1, 1995 at which time it becomes five percent for that year and thereafter. Thus, the combined tier I incentives always equal 11 percent.
The tier II performance incentive becomes effective July 1, 1993. At that time, the performance incentive rate is a maximum of one percent and increases one percent annually until July 1, 1995 at which time it is a maximum of three percent for that year and thereafter. (These rates are summarized in the chart below.)
Performance Review Bureau
In order to implement this statutory mandate, the California DSS established the Child Support Performance Review Bureau (CSPRB) which has a total of 16 staff. Annual county reviews in the 21 smaller counties are performed directly by CSPRB staff and include a review of an average of 220 case files per county. Annual reviews in the 37 larger counties are performed by State funded county staff who have been trained by CSPRB in the review process; however, their review findings are validated by CSPRB. Typically, 250 to 290 cases would be reviewed in a large county and a subsample of 30 to 40 cases would be sampled for CSPRB validation. As part of
the review methodology for both types of reviews, CSPRB provides the counties with immediate feedback during the onsite review by completing a review form for each case in which there is an error or disagreement. (Copies of these review follow.)
CSPRB staff conduct annual training sessions for all reviewers to ensure that they are up-to-dateon the latest program regulations and review processes. This training, which is conducted in different sites around the State, helps to ensure standardization in the reviews. Training content focuses on use of the review forms, proper documentation, and program changes. In addition, CSPRB conducts periodic "networking" meetings with county staff to discuss the program improvement/corrective action process and to discuss common problems and share best practices.
Program Improvement Bureau
When a county fails a review, the Child Support Program Improvement Bureau (CSPIB), which consists of nine staff, assists in the development and monitoring of corrective action and program improvement plans designed to bring the county into compliance. Once a county has attained compliance, the CSPIB staff validate that appropriate corrective actions have been accomplished and certify that the county is eligible to receive its incentives.
California has recently completed its second year of performance reviews in all 58 counties. An initial comparison of the review results shows marked improvements in county compliance with performance standards' case processing requirements. Several counties have incorporated performance standards timeframe tracking software into their automated systems which greatly assists in tracking individual cases for compliance with the timeframe requirements. The review process has helped both county and State program staff prepare for statewide automation by increasing the uniformity of case management throughout the State. With this increase in uniformity and overall case activity, clients receive better service, child support payments increase, and welfare costs are abated. The State is better able to manage the program and future Federal audit findings will be more favorable.
For the counties individually, this process provides three ways for them to increase their funding base: (1) eligibility for the compliance incentive rate through the attainment of compliance; (2) eligibility for the performance incentive rate by meeting additional requirements; and (3) increased collections which creates a higher total against which the rates are applied.
The State law establishing this performance-based incentive system becomes inoperative on
June 30, 1996, and will be repealed on January 1, 1997 unless another statute extending the system is enacted before that date. Since the statewide, automated system will be in place in 1995, the State legislature intends to reexamine these issues.
For More Information, Contact:
Vivianne DuFour, Chief
Child Support Performance Review Bureau
Laura Williams, Chief
Child Support Program Improvement Bureau
CALIFORNIA INCENTIVE RATES
PERFORMANCE STANDARDS PROJECT
TIER I - (Base Rate and Compliance Rate)
Year Base % Rate Compliance % Rate Total Tier I
The tier I incentive is designed so that counties will only receive the maximum rate of 11% if they are in compliance with all review components.
TIER II - (Performance Rate)
Year Highest Incentive Maximum Incentive Rate
Rate Available Tier I and II
The tier II incentive is a bonus for meeting performance standards.
Connecticut's Department of Human Resources (DHR), soon to be consolidated into the Department of Social Services, has the responsibility to determine if the State's child support enforcement program is meeting the 46 performance standards defined in DHR regulations most of which are based on Federal regulations. These standards cover the seven program areas--case establishment, location, paternity establishment, order establishment, enforcement of support, interstate functions, and case closure. DHR is also responsible for helping cooperating agencies to improve their performance.
Connecticut's IV-D Program is state-administered. DHR's Bureau of Child Support Enforcement is the designated single State agency. The IV-D Program is administered through the use of cooperative agreements to assure that the State IV-D Plan is continuously in operation in all appropriate offices or agencies. These include the Office of Attorney General, the Superior Court's Support Enforcement Division, and the Department of Administrative Services' Bureau of Collections. All three of these organizations work closely with IV-D in the Quality Assurance Program.
Quality Assurance Program
Accordingly in July 1992, the Bureau of Child Support Enforcement developed and has been conducting a quality assurance (QA) program which involves:
selecting a random sample of IV-D cases;
reviewing those cases through their automated system:
conducting field reviews of all sampled cases at cooperating agencies and DHR offices; and
reporting the results of sample analysis.
Despite the importance of the automated case review, reviewing case files manually provides an opportunity to validate information on critical legal documents such as court orders and ensure that this information is correctly entered into the computer system. The information in the case files is very important since it is used by IV-D staff in court. In addition, if any patterns of incomplete entries are observed when reviewing case file contents, those areas can be addressed in future training for workers.
Quality Control Form
Staff designed a form called the Quality Control Case Record on which reviewers summarize their findings and conclusions about each sample case. (See attached copy.) The QA worker determines which actions have been taken, if each action was performed on time, and whether or not it is in compliance. The worker reviews all of the cases to determine if all actions required by IV-D policy have been taken. The worker also records any observations about why compliance was not achieved. Originally composed of one and one-half full time staff, QA has recently been increased to two full time employees.
Once both the automated review and the field review have been completed and all forms completed and validated for all sample cases, QA staff computes the efficiency rate for each of the 46 functions using the following formula taken from the Federal OCSE Audit Guide:
Efficiency Rate (p) = Number of Actions Taken
Number of Actions Required (n)
Once the efficiency rate has been computed for each of the 46 functions, the next steps are: computation of the standard error, determination of the confidence level for the case activity standard, and evaluation of whether the performance standard was achieved for each of the 46 functions.
A full schedule of field appointments has been maintained by the QA team. All cooperating agencies have actively participated in the review--the Attorney General's Office, the local offices of the Superior Court Support Enforcement Division, the Bureau of Collection Services office, and DHR district offices. Followup meetings have also been held to address problems and improve performance. The QA Unit plans to target selective areas, such as paternity establishment, opening new cases, and fiscal areas, in their continuing work with program standards.
A very important result of these reviews is the increased communication among the various agencies involved in the child support program. The State reviews provide an opportunity for the different agencies to compare the State's results with their own findings. This is helpful to all components and enhances mutual credibility and trust. It also translates into improved public service.
For More Information, Contact:
William Hurley, Program Supervisor
in charge of IV-D Quality Assurance
Connecticut Child Support Program
Department of Social Services
In accordance with Federal requirements, Delaware began to implement the newly mandated performance standards in October 1990, and also began to develop an internal review system to monitor progress in meeting the new criteria. The quality control system that resulted evaluates both the State's Division of Child Support Enforcement and the IV-D functions that are performed by the Delaware Family Court.
Quality Control System
The quality control system was reformatted in 1992 to enhance its utility. Two major features of the present system are:
A modular format that permits the reviewers to target cases in any of the eight program areas--application/intake, locate, expedited process, paternity establishment, enforcement, interstate/initiating, interstate/responding, and case closure; and
Citations from both the Code of Federal Regulations and the Family Court's State Administrative Plan are included to enable reviewers to research specific issues.
The automated sampling process ensures that cases selected had activity in a specified program area during a specified time period. Other cases are selected on a random basis and are reviewed for general activity within the previous 6 months. The total sample size represents 1 percent of the State's IV-D caseload.
Reviews are conducted quarterly by a senior support specialist from each of the State's three counties. Each item on the review instrument is assigned a performance status:
C - in compliance, action taken and within the timeframe;
E - action taken but not within the timeframe;
O - out of compliance, action not taken at all.
Negative findings are documented on a form that is then used for immediate correction and, as appropriate, for broader corrective action planning. (Copy attached.)
Supervisors receive a statistical analysis of the review findings in addition to the descriptive summary prepared by the reviewer. The supervisors then meet with their respective operations manager to propose corrective action. The final corrective action plan is developed and then
monitored and tracked by the operations manager. Periodic meetings are convened with the reviewers to discuss relevant cases and issues. The purpose of these meetings is to promote uniformity among the reviewers so that review procedures are as consistent as possible.
For More Information, Contact:
Barbara Corrozi, Deputy Director
Division of Child Support Enforcement
Prior to the October 1, 1990 effective date of the Federal regulations that mandated timeframes for processing IV-D cases, the Mississippi Division of Child Support Enforcement issued policy and procedures to instruct and assist staff in case management. Because Mississippi does not yet have a statewide automated system, manual case management and control tools and procedures were designed. A combination of case control cards and tickler systems was developed. The case control cards are used to provide a uniform and accurate system for showing the program code and action status of a case. They are completed in duplicate and the original is placed in a central child support case control file and the duplicate is filed in the worker's case control file. The tickler system includes both daily and monthly ticklers. (Samples attached.)
The State child support training unit incorporated the timeframes into a mandatory training module on enforcement that redefined case processing and management. Training staff also developed a flow chart that tracks actions and cites the time requirement for each. This valuable tool was distributed to all IV-D staff. (Copy attached.)
The State has a team of eight program audit analysts who review county IV-D programs full time. Each analyst is assigned to review 10 to 17 counties. When the timeframe requirements had been in effect for a year, the Program Compliance Review Unit began conducting reviews targeting compliance with timeframes for cases opened after January 1, 1991. Within 8 months, reviews were conducted for all 84 county child support programs. Case samples were pulled and reviewers identified the number of cases with actions required and determined whether the actions were timely. To determine the efficiency rate for a specific function, the number of cases with timely action was divided by the number of cases that required the action. Although submission of corrective action plans was not required, program administrators and senior attorneys were instructed to use the report to work with their staff to correct the weak areas and to compliment staff on strong areas. Followup reviews have been performed in some counties and indicate improvement in some areas that were found to be deficient in the first review. Consistently statewide, the fewest deficiencies were found in case opening requirements.
In addition to monitoring the timeframes, workers' use of the manual control and tracking systems was monitored to see if they were being used appropriately. Areas such as use of the central administrative tickler file, use of the worker case control file, and receipt of referrals by an attorney were examined.
Although these reviews only targeted the timeframes, comments were made in the reports regarding additional areas of concern. In addition, the timeframe reviews also monitored the use of control and tracking systems to determine if they were being appropriately used. Other areas of compliance are thoroughly addressed in separate reviews which focus on enforcement and fiscal activity.
An example of results from a timeframe review was revealed in a March 1992 report. Thirty-two cases in one county were reviewed for compliance with timeframes in ten programmatic areas:
assessment interview; initiate location; FPLS submission; all locate sources in 75 days; quarterly resubmission to the FPLS; establishment activity; documentation of service; enforcement activity within 30 days; enforcement activity within 90 days; and outgoing URESA within 20 days. An overall efficiency rate of 76 percent was computed. In addition, the same county's collections increased 27 percent in 1991 as compared to 1990. However, county efficiency rates and increased collections are not always related.
For More Information, Contact:
Kathy Gibson, Program Manager
Division of Child Support Enforcement
The Missouri Quality Assurance (QA) Unit was established within the Division of Child Support Enforcement on February 22, 1988. At this time, Missouri was one of the very first States to establish such a unit and based its efforts on discussions with Federal auditors.
The Unit's purpose is to examine IV-D case records in the district offices and the prosecuting attorneys' offices to determine if mandated procedures are being followed and properly documented. The Unit is composed of a supervisor, five case reviewers, a technician, and a secretary.
Missouri's IV-D Program is state-administered and has 13 district offices. In addition, the Program is administered through cooperative agreements with 115 prosecuting attorneys. For two and a half years, QA staff performed reviews in all of the State's district offices to assess compliance with Federal timeframe requirements and accuracy of case file documentation. In
July 1990, QA staff began to review IV-D cases handled by the State's prosecuting attorneys.
The district office reviews cover all State and Federal requirements for six types of cases: AFDC, non-AFDC, interstate, foster care, third party liability/medical support, and expedited/administrative process. If a case is transferred from AFDC to non-AFDC and back to AFDC during the review period, it is counted only one time as a IV-D case and is considered the same type of case for the entire audit period. The prosecuting attorneys' reviews only look at Federal timeframes for IV-D cases.
Each case is classified into one of the following categories:
Action case--case in which the required actions have been taken.
No action case--case in which all of the required actions have not been taken.
Excluded case--case which required no action during the review period.
Unlocated case--case which cannot be found at the local district or subdistrict office.
All of the procedures necessary to conduct these reviews were set up in lap top computers for mobility and convenience. Random samples were drawn using procedures adapted from Federal audits.
Three problems that emerged from the prosecuting attorneys' reviews were the numbers of unlocated cases, which could not be found; the numbers of URESA cases which were not in compliance with timeframe requirements; and the identification of cases which had been closed inappropriately. However, when placed under corrective action plans, most prosecutors' offices were able to bring most of their cases into compliance.
Missouri has received numerous requests from other States to share their QA work. At present, the QA supervisor and deputy director are working with Federal auditors to implement a review process which will be very similar to the OCSE audits.
One of the benefits of this work has been to built a closer working relationship between the IV-D offices and the prosecuting attorneys. This has resulted in more expeditious case processing and enhanced public service.
For More Information, Contact:
Supervisor, Quality Assurance Unit
Since November 1990, Montana has formally monitored its efforts to meet Federal program standards requirements every 6 months. The State employs a full-time internal program auditor who regularly conducts case file reviews in each of Montana's five regional offices. Statewide, 500 cases are randomly selected using a sampling technique similar to that used by OCSE audit staff. The number of actual cases pulled for internal review in each regional office generally falls between 75 and 125. These reviews include monitoring the implementation of timeframe requirements as well as examining the case work processes associated with completing all program functions. The reviews identify problem areas. For example, timeframes for interstate processing appear to be the State's biggest problem. The reviews also provide management with the information necessary to make recommendations for addressing the problems and for improving program effectiveness and efficiency.
Corrective Action Plan
The reviews also serve as an early warning system, which allows the State to take preventive measures so that substantial compliance can be achieved. If a review shows that a regional office has fallen below the State's desired 80 percent performance level in reviewed cases, the regional manager must develop and submit a corrective action plan to State management staff. After an approved corrective action plan has been in place for 6 months, the internal auditor conducts a followup review to determine how effective the plan has been. In addition, the internal auditor examines cases to ensure that other program areas have not suffered because of implementation of the corrective action plan.
Montana's training for child support workers focuses on required actions and activity sequences instead of on required timeframes. Emphasis is on complete and accurate casework with all necessary actions and activity sequences being performed. Thus Montana's case processing requirements are sometimes more stringent than Federal program standards requirements. Montana staff are instructed to take appropriate actions on a case when information or documentation is received instead of calendaring for a date of action solely to meet Federal timeframe requirements. As an example, the State issues an "Order to Withhold" form that is, among other things, used to notify an employer of the amount to withhold from the obligor's earnings. As one of the necessary case actions related to income withholding, staff are instructed to issue this form when employment is discovered after the occurrence of any one of the following:
The obligor fails to respond to a "Notice of Intent" and 10 days have expired; or
The obligor's request for a hearing is denied and 10 days have expired; or
The obligor enters into a voluntary withholding agreement; or
The obligor fails to appear at a scheduled hearing and the hearing officer enters a default order; or
The hearing officer issues an order permitting the Child Support Enforcement Division to send this form to the obligor's employer; or
The obligor changes employers.
Another method Montana will use to ensure that the timeframe requirements are met will be incorporated into their automated IV-D system. The System for the Enforcement and Recovery of Child Support (SEARCHS) is expected to be fully implemented and operational during the summer of 1993. It will track timeframes and flag action items for workers.
For More Information, Contact:
Bob Wallace, Management Analyst
Montana Child Support Enforcement Division
Washington State has developed an automated Event Tracking Program (ETP) to assist IV-D managers and workers in meeting Federal timeframe requirements. This Program is critical to meeting the requirements because it targets cases for review when the time period is near expiration. The ETP was installed in the Support Enforcement Management System (SEMS), Washington's certified statewide automated system, on July 1, 1992.
The ETP categorizes and maintains cases in ten different statuses:
Case setup (CS)--setup case and determine appropriate action within 20 calendar days of application or referral.
Locate (LO)--access all appropriate location sources within 75 calendar days.
Paternity service (PS)--establish paternity or complete service of process within 90 calendar days of location.
Paternity establishment/exclusion (PE)--establish paternity or exclude the alleged father within one year of successful service of process or the child reaching six months of age.
Establishment service (ES)--establish an order for support or complete service of process within 90 calendar days of location.
Establishment order (EO)--establish a order for support or complete service of process within 90 calendar days of location or within 90 calendar days of service of process (expedited processes).
Enforcement (EF)--take appropriate action to enforce order within 30 calendar days of identifying a delinquency.
Maintenance (MP) -- Obligor is paying in accordance with support order or agreement. No review set.
Interstate (IN)--refer the case to the responding State's central registry within 20 calendar days of determining that the noncustodial parent is in another State.
Closed (CL)--date case was closed. No review set.
Attached, as an example, is a copy of an ETP screen.
The ETP automatically notifies IV-D staff seven days prior to the end of the Federal timeframe requirement. It also documents the begin and end dates that a case moves into and out of the ten statuses and tracks the number of times a case has been in a particular status.
Currently, ETP requires designation of status of case and initial input by the IV-D worker. Whenever the IV-D staff change a status, the ETP automatically changes the case review to conform to the timeframe for the new status. Automatic assignment of case status and movement between statuses by ETP is being considered for later implementation. It would be a relatively simple program to develop and integrate into ETP.
Management information system reports are also available from the ETP. These reports target cases which are not in compliance with the timeframes. They also provide managers with information that is helpful in identifying problem areas and training needs as well as in allocating resources, and in the overall management of their operation.
The primary object in the development of the ETP was to meet the Federal systems requirement of the mandated timeframes. However, the use and maintenance of the ETP will become the basic framework in the further development of automated case processing as enhancements are made to SEMS to meet all of the Federal systems requirements of the 1988 amendments.
The SEMS system is based upon a client-server architecture. The host database resides on a Unisys mainframe. SEMS is an online system with over 1500 workstations. The SEMS database contains over 3 million individuals and 621,000 child support enforcement cases. There are over 260,000 open child support enforcement cases. There are also over 4 million inquiry and/or update transactions per month. The workstation programs are written in Clipper and are resident on each personal computer (PC) running under MS-DOS. Underlaying the Clipper programs are "C" communications routines which allow Clipper to talk to the network interface card in a PC which, in turn, allows communication with the host.
For More Information, Contact:
Jon Conine, Project Manager
Office of Support Enforcement
In addition to those States highlighted above, numerous other States are also working to monitor their own compliance with Federal timeframe requirements as well as other State and Federal requirements. These include:
Most States have also incorporated program standards requirements into their training for staff working in the IV-D program as well as into their policy and procedures manuals.
Effective October 1, 1990, States were required to operate their Child Support Enforcement Programs in accordance with Federal program standards regulations. Program standards timeframes are intended to improve service to IV-D clients. The standards also serve as a management tool to enhance program efficiency and effectiveness. These improvements should result in increased collections both for non-AFDC families and in savings for our nation's taxpayers.
Many States reported that working with timeframes assisted them in streamlining their procedures and in achieving greater efficiency in case processing. States also reported that ongoing work in automation and program standards requirements compliment one another. States are invited to contact officials in other States for additional information and details about these efforts.
We appreciate the generous assistance of the State contact people and their staffs as well as the ACF Regional Office Specialists in researching and writing this document.