DATE: September 17, 2009
TO: ALL STATE IV-D DIRECTORS
RE: Data Reliability Audit Requirements for the Fiscal Year 2009 Reporting Period
Enclosed with this letter are the data submission requirements for the Federal fiscal year (FY) 2009 Office of Child Support Enforcement (OCSE) Data Reliability Audits (DRAs), as required by Section 452(a)(4)(C)(i) of the Social Security Act. Although the required submissions are due by the end of 10 business days after the beginning of calendar year 2010, we are providing the specifications as early as possible to assist States that may need extra time to coordinate and schedule these requirements with their information technology departments.
Because of the evolving Health Care Reform initiative, we will not review the proposed Medical Support performance indicator lines (Lines 2e, 21 and 21a) for the FY 2009 audit cycle. However, States are still required to report data for these lines on the OCSE 157. As a result, when a State is not subject to a Data Reliability Audit, a Data Reliability Review (DRR) will be conducted. The Office of Audit will follow the DRR process as outlined in DCL-04-02, “Data Reliability Audit Process for Auditing States Less Frequently than Annually,” dated January 21, 2004. Under the DRR, we will conduct analytical procedures on Lines 1, 2, 5 and 6, or 8 and 9, 24, 25, 28 and 29. To review the Cost-Effectiveness performance indicator, we will evaluate whether selected amounts reported on the OCSE-34A and the OCSE-396A could be verified to the first level of State documentation. States that have passed three consecutive DRA audits, met all performance standards and have not made major systems changes will undergo a DRA once every three years. States that have passed two consecutive DRA audits, met all performance standards and have not made major systems changes will undergo a DRA in two years. For more specific information regarding the States that qualify for a DRR and those that do not, please refer to DCL-04-02.
For the FY 2006 audit process, we revised the data submission requirements for the Child Support System Universe to delete the “CP SSN” and “NCP SSN” fields from the audit trails based on a determination that the custodial parents’ and non-custodial parents’ Social Security numbers were not essential to conduct the DRA. After assessing two years of experience without Social Security numbers, we determined that Social Security numbers are necessary in order for us to perform required analytical audit procedures for detecting duplicated cases. Therefore, for FY 2008, we began requesting the last four digits of the Social Security number for the custodial parent, non-custodial parent and child. We are continuing to request this data for FY 2009. The data specifications include this information.
As in prior years, the OCSE Office of Audit will continue to evaluate the completeness, reliability and security of performance indicator data reported by the States and the accuracy of the reporting systems used in calculating the performance indicators. This requires electronic files from each State that contain the complete, unduplicated child support case universe as of September 30, 2009, including all open IV-D cases, closed cases and non IV-D cases and the audit trails for each line on the OCSE-157 used in the computation of performance indicators. The specifications for these files are enclosed.
We encourage States to comply as closely as possible with these standard specifications because, like early submission, getting the data in a standard format expedites the audit work. We also request that you ensure that the audit trails are in accordance with the OCSE-157 reporting instructions and our audit specifications. Time spent validating data, querying, sampling and matching sampled records will be shortened considerably if the audit trails supporting the performance indicator data are submitted uniformly by all 54 States and Territories.
We encourage you to compile and submit your data to the appropriate Area Audit Office as soon as possible. Submissions are required for both DRAs and DRRs. To provide assurance about the integrity of the audit trails and in order to safeguard your State’s data, the universe and audit trails must be encrypted in a self-extracting file and sent to the Area Audit Office on a read-only CD and/or DVD. Please note that this is different from a read only database file. As an additional safety measure, we strongly suggest that you send the password under a separate correspondence. Early submission has a number of important benefits. It affords you the opportunity to review and make corrections to the OCSE-157 at any time prior to the December 31st final reporting deadline. Any inconsistencies between the audit trails and the OCSE-157 that can be identified and corrected prior to the audit should not only expedite the audit but also result in fewer reportable audit findings. Early submission also helps expedite the detailed audit work because many preliminary steps can be completed prior to January. Ultimately, an early start should result in more timely incentive payments and more time to correct data reliability problems for the subsequent audit period.
I urge all States not yet providing read-only systems access to the auditors to do so as soon as possible. Please have your systems staff contact the auditors to ensure that read-only system access is being provided and functioning properly. Read-only remote access to a State’s child support system allows the Office of Audit to review sample cases in the data-testing phase of the audit more efficiently and effectively. It enables a better allocation of scarce resources and results in less disruption of State and local child support operations. Read-only access is a requirement detailed in the OCSE “Certification Review Guide” issued under Action Transmittal OCSE AT-00-07, dated August 28, 2000.
We trust that you will be able to provide us with the audit trails in the suggested format as early as possible and before the deadlines for data submission for the reasons previously identified. Again, you have until December 31, 2009, to submit the final FY 2009 OCSE-157 report and up to 10 business days after the beginning of calendar year 2010 to provide the associated audit trails. Additionally, corrected OCSE-157 reports for prior periods must also be received within the deadlines stated above. States that are submitting corrected data from prior periods may want to refer to DCL 08 35, “Reminder to begin collecting data for the new lines on the OCSE-157 for FFY 2009 and resubmit data found to be incomplete or unreliable for previous years,” dated September 19, 2008, for more information on this topic. OCSE-157 reports for both the current and prior periods must be submitted to the OCSE Division of Planning, Research and Evaluation, while the audit trails must be provided to your appropriate Area Audit Office.
Because of the technical nature of the data specifications, it is important that this DCL and the Enclosure be forwarded to the staff that will be developing the programming that will produce the audit trails. The process used by the auditors to validate the audit trails is dependent on the table names, field names and data type agreeing with these specifications. Any deviation can affect the acceptance of the audit trails and the prompt initiation and completion of the audit.
Your timely cooperation is greatly appreciated. Please feel free to consult with our audit staff if you have any questions or need our technical assistance as you work with systems staff to develop the audit trail file in the suggested format.
Office of Child Support Enforcement
Enclosure: Data Submission Requirements for the Fiscal Year 2009 Data Reliability Audits