DCL-08-37, Data Reliability Audit Requirements for the Fiscal Year 2008 Reporting Period

DEAR COLLEAGUE LETTER

DCL-08-37

ATTACHMENT: Data Submission Requirements for the Fiscal Year 2008 Data Reliability Audits

DATE: September 30, 2008

TO: ALL STATE IV-D DIRECTORS

RE: Data Reliability Audit Requirements for the Fiscal Year 2008 Reporting Period

Dear Colleague:

Enclosed with this letter are the data submission requirements for the Federal fiscal year (FY) 2008 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 not due until January 15, 2009, we are providing the specifications as early as possible to assist States that may need the extra time to coordinate and schedule these needs with their information technology departments.

These data submission requirements continue to address medical support-related data that States are required to report on Lines 2e, 21, and 21a of the OCSE-157, as required by OCSE-AT-05-09, "The Office of Child Support Enforcement (OCSE) Annual Data Report: Form OCSE 157," dated September 6, 2005. These data will be used in the development of the proposed medical support establishment and enforcement performance indicators addressed in the National Child Support Enforcement Strategic Plan for Federal Fiscal Years 2005 through 2009. Since medical support performance indicators are not currently part of the incentive payment system, we will continue to audit medical support data for management purposes only.

Because of the extensive medical support requirements resulting from the implementation of the revised OCSE-157, we will continue to audit the medical support data for each State. This will cause States that would normally be subject to a Data Reliability Review (DRR), as addressed in DCL 04-02, dated January 21, 2004, to undergo a "Modified Data Reliability Audit" (MDR). Under the MDR, we will audit Lines 1 and 2, as well as the medical support Lines 2e, 21, and 21a. We will also conduct the analytical procedures on Lines 5 and 6, or 8 and 9, 24, 25, 28 and 29 that we would normally do in a DRR.

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 have determined that Social Security numbers are necessary in order for us to perform required analytical audit procedures. Therefore, we are requesting the last four digits of the Social Security number for the custodial parent, non-custodial parent, and child. The data specifications have been revised to include this information.

As in prior years, the OCSE Office of Audit will continue to evaluate the completeness, reliability, security, and accuracy of performance indicator data reported by the States. This requires electronic files from each State that contain the complete child support case universe as of September 30, 2008, 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 as well as the medical support lines. The specifications for these files are attached. 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 MDRs. 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 31 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.

As in prior years, we are requesting that States that elect the Statewide Paternity Establishment Percentage (PEP) measured by Lines 8 and 9 also submit audit trails for Lines 5 and 6, and that States that elect the IV-D PEP measured by Lines 5 and 6 also submit audit trails for Lines 8 and 9. The audit trails that you did not choose to report for incentive purposes will not be audited as part of the DRA.

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, 2008, to submit the FY 2008 OCSE 157 report, and January 15, 2009, to provide the associated audit trails. Additionally, corrected OCSE-157 reports for prior periods must also be received by December 31, 2008, and the associated audit trails by January 15, 2009. States that are submitting corrected data from prior periods may want to refer to DCL-07-41, "Submittal of the OCSE-157 Report for FY 2007 and the Resubmission of FY 2006 Data Found to be Incomplete or Unreliable," dated December 7, 2007, 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.

Sincerely,

Margot Bean
Commissioner
Office of Child Support Enforcement