FFP for Computer Hardware Acquisitions and Development of Income Withholding and Other Provisions of P.L. 98-378 Relating to Design, Development, Implementation, Enhancement and Operation of Comprehensive Statewide Automated Child Support Enforcement Systems.
December 26, 1984
TO:STATE AGENCIES ADMINISTERING CHILD SUPPORT ENFORCEMENT PLANS APPROVED UNDER TITLE IV-D OF THE SOCIAL SECURITY ACT AND OTHER INTERESTED INDIVIDUALS.
SUBJECT: Instructions for Obtaining 90 Percent Federal Financial Participation (FFP) for Computer Hardware Acquisitions and Development of Income Withholding and Other Provisions of P.L. 98-378 Relating to the Design, Development, Implementation, Enhancement and Operation of Comprehensive Statewide Automated Child Support Enforcement Systems.
BACKGROUND: The recent passage of the Child Support Enforcement Amendments of 1984 (P.L. 98-378) has placed additional requirements on States for the administration of the Child Support Enforcement Program. In recognizing that these requirements will place an added administrative burden on States, the new law authorizes Federal funding to automate the new requirements at the 90 percent rate under certain conditions. The new law also makes FFP available at the 90 percent rate for expenditures for the rental or purchase of computer hardware used for the operation of a computerized support enforcement system if the system meets the requirements specified in 45 CFR 307.10(b) or the new section 454(16)(D) of the Social Security Act in addition to the requirements of 45 CFR 307.10(b).
Advance Planning Documents (APDs) and updates to APDs requesting FFP to automate the new functions described in P.L. 98-378 or to acquire computer hardware at the 90 percent FFP rate will continue to be submitted in accordance with the submission process specified in 45 CFR Part 95, Subpart F.
CONTENT: This action transmittal outlines the conditions under which OCSE will approve 90 percent FFP to automate the additional program functions resulting from the passage of P.L. 98-378. It also describes conditions for FFP reimbursement at the 90 percent rate for computer hardware.
EFFECTIVE DATE: October 1, 1984
INQUIRIES TO: OCSE Regional Representatives and Systems Administration Branch, OCSE
Office of Child Support Enforcement
The Child Support enforcement Amendments of 1984, Public Law 98-378 amended title IV-D of the Social Security act (the Act) to require all States to enact laws requiring the use of certain procedures in their child support enforcement programs. The procedures are: income withholding; expedited process for establishing and enforcing child support obligations; State income tax refund offset; liens against the real and personal property of absent parents who owe overdue support; security bond or some other guarantee for support; provision of information to consumer reporting agencies regarding the amount of overdue support owed by absent parents.
Effective October 1, 1984, the new law requires the Office of Child Support Enforcement (OCSE) to make ninety (90) percent Federal Financial Participation (FFP) available to States to enhance statewide comprehensive computerized Child Support Enforcement (CSE) systems that meet the requirements of 45 CFR 307.10(b) to include the mandatory new procedures referred to in Section 454(16)(D) of the Act.
This funding is also available for comprehensive statewide CSE systems planned or currently under development. Federal funding at the 90 percent rate will facilitate the development and improvement of income withholding and other procedures referred to in Section 466(a) of the Act through the monitoring of support payments, maintenance of accurate records of support payments and providing of prompt notice to appropriate officials of any support arrearages. We, therefore, encourage States to develop or enhance comprehensive statewide CSE systems that encompass the procedures referenced above because the automation of such procedures will contribute to efficient and effective program operations.
Effective on October 1, 1984, the new law also revised section 455(a)(1)(B) of the Act to authorize FFP at the 90 percent rate for the rental or purchase of computer hardware for computerized CSE systems that meet the requirements for statewide comprehensive systems described in 45 CFR 307.10(b) or section 464(16)(0) of the Act in addition to 45 CFR 307.10(b).
II. OBTAINING APPROVAL FOR 90 PERCENT FUNDING
A. In order for a State to be eligible for 90 percent Federal funding to automate the procedures described above and to obtain the higher match rate for hardware lease and/or purchase cost, the State must be able to demonstrate that its automated CSE system is statewide, comprehensive and meets the requirements in 45 CFR 307.10(b).
This may be accomplished in two ways:
(1)If the CSE system is operational and the development of such system was funded at the 90 percent rate, the requesting State should reference the final APD compliance review that was performed by OCSE, or
(2)If the CSE system is operational and the development was not funded at the 90 percent rate, the State should provide a complete description of the current system that shows, conclusively, that the system meets the requirements for 90 percent systems prescribed in 307.10(b) and that it is statewide in application. This complete system description document may be submitted as a stand-alone document in anticipation of a request for 90 percent funding to automate the new procedures prescribed by the law and/or a request for change in the FFP rate for computer hardware, or in conjunction with a request for 90 percent funding.
B. To obtain approval of 90 percent funding for the optional enhancement of operational statewide CSE systems or systems under development to reflect the mandatory procedures prescribed in the new law, a State must meet the requirements in subsection A and must submit an APD or APD update to the Assistant Secretary for Management and Budget.
C. To obtain 90 percent funding for the cost of leased or purchased computer hardware utilized for the operation of comprehensive statewide CSE systems that are operational, States in addition to meeting requirements in subsection A must submit a request for change in the FFP rate from 70 percent to 90 percent to the Deputy Director, Office of Child Support Enforcement, for review and approval. The Request for Change must include a configuration plan as described in section III below. For CSE systems currently under development with 90 percent funding, States need to submit the computer hardware configuration plan 60 days prior to the scheduled date of the system becoming operational.
In the request for 90 percent funding, States may include the types of hardware defined in 45 CFR 95.605, proprietary software that is necessary for the hardware operation, hardware maintenance, and delivery and installation cost. Not eligible for 90 percent funding are utility costs, supplies, renovations to house computer hardware, special desks for terminals, etc.
OCSE's percentage of cost for shared hardware will be based on the actual lease or purchase cost of the hardware at the time of acquisition as determined by an approved cost allocation methodology. It will not include costs of personnel or any other overhead costs, either direct or indirect, that may be included in approved cost allocation plans.
III. EQUIPMENT CONFIGURATION PLAN
In lieu of an annually updated APD, when requesting 90 percent funding of the hardware currently used in the operation of the CSE system, a State must submit a three-year configuration plan showing the hardware and proprietary software which will be claimed at the 90 percent expenditure rate. This three-year plan may also include a one-year growth estimate for minor configuration adjustments, e.g. acquisition of several (3-4) terminals or modems.
On a yearly basis, the State must update the configuration plan to reflect the installation of the hardware, and to estimate minor growth for another year.
If a State plans to deviate from its approved configuration plan the State must submit an APD update as required under 45 CFR Part 307. Since the APD may be requesting funding approval at both the 70 and 90 percent rates, the State must also submit a new three-year configuration plan which details only that hardware which will be claimed at the 90 percent rate.
The configuration plan should include:
1) a description of hardware used in operation of the CSE system, the method of acquisition (e.g. purchase, lease, lease purchase), time period of acquisition agreement or capitalization and depreciation schedule, component cost, delivery, installation or maintenance costs if applicable, hardware location, and a description and cost-breakout of the proprietary software needed for operation of the hardware;
2) a statement supporting minor configuration adjustments planned to accommodate anticipated system growth within the current year and a description of how the hardware will augment the configuration; and,
3) a cost allocation methodology for identifying specific charges to the IV-D program. This methodology must be included in the State's approved cost allocation plan.