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Is Pre-Audit for Paternity and Establishment Caseworkers?

Background

Each year the federal Office of Child Support Enforcement (OCSE) auditors select a random sample of 50 cases that Oklahoma has reported as Paternity Being Established on the OCSE-157 Report, also known as the Data Reliability Audit. The audit is part of the incentive program that evaluates states’ performance in establishing paternity, establishing child support orders, and other indicators of performance. The intent of this incentive program is to determine the amount of funds each state is allocated.

The Federal Office of Audit evaluates 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. Electronic files from each state are used that contain the complete, unduplicated child support case universe as of September 30th of a particular year, 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. Only two mistakes out of 50 data points are allowed to pass the audit.

Oklahoma’s Child Support Pre-Audit assists with meeting the stringent data accuracy requirements of the federal government, and is conducted once each calendar year. The Paternity and Establishment related data that are reviewed include the Statewide Paternity Establishment Percentage (Statewide PEP) and the Child Support Order Establishment Percentage.

For the federal 157 report, Oklahoma has 9 months, until September 30th of the current year to change or update legal status for children with paternity being reported as established or support orders established during the previous calendar year.

OSIS has built in screens that are used to monitor and manage cases that meet the criteria. The Document Direct report (CS370M01) lists all cases from the previous calendar year that OSIS reads as paternity and establishment. Child support offices have until September 30th of the current year to review the cases and ensure that they are coded correctly.

OSIS looks for obligation information, the child’s legal status history, the progression of the child’s legal status, how the case came into the system, and the out of wedlock indicator.

What Paternity and Establishment Codes to be Aware of

Three OSIS OBL Legal Types Statuses

In OSIS OBL, there are three legal type statuses: divorces (D); other support (S) which are often mother NCP cases or separated cases; and paternity cases (P). These codes show how the obligation was built. These case types need to be verified to ensure they were coded correctly.

The following are a couple of examples of incorrectly coded data:

If there is not a divorce between the parties but the code indicates divorce, then it is coded incorrectly;

If an S case does not have paternity established, but the data indicate that paternity was established, then it is coded incorrectly.

These examples show how incorrect coding can cause a data reliability problem. Caseworkers are encouraged to check S, D and P cases to make sure there is the correct documentation and paternity establishment processes to show how paternity was established. For mother NCP cases the paternity establishment process must also be shown.

OSIS OBLU screen indicating the location of Legal Type data field.

OSIS CSPI and Child Information

The OSIS CSPI screen is used to look at the child(ren)’s legal status and status history. The child(ren)’s information is shown even if the child has been removed. The status date is the date when the legal action occurred and the effective date is when the information was entered into OSIS.

OSIS CSPI screen showing data is read chronologically from bottom to top.

The status date is found to the left of the screen, and the effective date is just to the right of the status date. As the status date is when some action was taken and the effective date is when the OSIS data was entered and updated, these dates may be different.

To read the CSPI screen chronologically, read it from bottom to top to check for status going from P to N to A (see attached image).

AOP vs Legal Finding

An acknowledgment of paternity does not count as a legal finding, so caseworkers must be certain OSIS is coded correctly. Unless a valid Acknowledgment of Paternity (03PA209E) has been signed and on file with the Oklahoma State Department of Health (OSDH), the case must be built as M to A because legal status P is reserved for cases with actual AOPs. If there is not a valid AOP, the OSIS OBL legal type must be built as a P code, and the appropriate petition is a NOPSO (Notice of Paternity and Support Obligation).

Modification and Paternity

The proper legal type need to be tied to the appropriate legal status. If the child was born of the marriage, the legal status would progress from I to A.  The OBL legal type would be S and a NOCSO (previously NOSD) petition is appropriate. If the child is born out-of-wedlock and paternity was not previously established the legal status progression would be M to A. The OBL legal type would be P and a NOPSO petition is appropriate. If there is an AOP, the legal status progression would be P to A. The OBL legal type is an S and the appropriate petition is a NOCSO (previously NOSO).

Legal Status H

The H code status indicates that paternity was established but no child support was ordered. If the child is verifiably legal status M and a NOPSO is entered, the legal status should progress from M to A. Progressing from M to H to A is done only if paternity is ordered for the child prior to support being ordered. H legal status is seldom seen because rarely is paternity established without a child support order being established. Code H is so seldom seen that it probably will not be on paternity reports. H status cases are usually with juvenile orders or district court orders.

OSIS CSPTU

The important thing to keep in mind when thinking about pre-audit is that if the Paternity Establishment data field is blank, it will not be reported on the 157 report. The location of this field is near the upper third center of the screen. Whether there are dates for Status Date or Effective Date, if the Paternity Establishment field is not filled in, it does not count.

How to Review and Correct Cases

Review

Use the CMOD report CS370M01 to help you review cases. This report will be sent out on a quarterly basis. You can contact the PFRs (OCSS.PFRS@okdhs.org) at any time to obtain a copy of this report. The codes are color-coded based on the OSIS OBL legal type.

The green tab is legal type P cases. These cases will pass audit and do not need to be reviewed.

There are two yellow tabs: A legal type S tab; and a miscellaneous tab. These cases are generally fine but should be reviewed for accuracy. Depending on how your office interprets the use of S reviewing the legal type S cases will ensure that they are not paternity cases. The miscellaneous tabbed cases are usually cases with multiple obligations with the first obligation not active as it has pended or is in history. This confuses analyzer. Most likely these cases are fine but should be reviewed to verify coding is correct.

The red tabs contain the legal type D cases and female NCP cases. The red color means “must review” because legal status D indicates there is a divorce decree but reported as paternity being established on the 157 report. Ascertain why paternity is established when there is a divorce decree, or whether there is a presumption of paternity. If there is an AOP and/or a denial of Paternity (03PA210E), then the acknowledged father must be found. The female NCP tab indicates paternity was established. However, paternity cannot be established against a female in Oklahoma. The purpose of reviewing these cases is to be certain the cases are coded correctly.

Fix the codes

When reviewing the OSIS CSPI screen, if the legal status sequence shows paternity, review the out-of-wedlock indicator to be sure it is coded Y, and that it shows establishment of paternity. Make necessary changes on the CSPU screen.

Example:

The mother was married, the husband signed a denial, the biological father signed the AOP, and the OOW Indicator is a Y as the child was not born of the marriage even though the mother is married. On presumptions of paternity if the couple was married and there was a denial signed, then it is most likely accurately coded. Plus, caseworkers are to make sure there is an out of wedlock indicator on those cases, even though the mother is married.

The following table shows the legal status sequences and OSIS outcomes of whether credit will be assigned for establishing paternity. Notice that with I to A codes, there is no credit. But, B to A codes, H to A, and H always gains credit.

Legal Status Sequences and OSIS Outcomes
Original Legal Status Current Legal Status (first time legal status changed) Paternity Establishment Credit?
M A Yes
M H Yes
M P Yes
P Always P Yes
P A No – credit was given when P originally recorded
A A No – credit might have been given when A originally recorded
A Always an A Yes, but only if child(ren) is(are) born OOW
I A No
B A No
H A No – credit was given when H was originally given
H Always an H Yes

Children born of the marriage but coded for Paternity Establishment

It is important for caseworkers to research cases in which a judge has made a ruling that a child was born of the marriage but the out-of-wedlock indicator is coded Y. If the out-of-wedlock indicator is coded Y the case will report as paternity established and could cause an error. In these situations the out-of-wedlock indicator will need to be updated to N. It should be noted that if a previous CSS order established paternity the Y coded out-of-wedlock indicator may be correct.

When OBL Coding and Child Legal History Do Not Match

Update the coding on the OBLU screen when the codes do not match accurately. This will not alter the outcome of the obligation because it is the legal type that is being updated.

Example:

If a case was coded as a D legal type but should be coded as S, use the OBLU screen to update.

If a case is coded with an S and should be coded P, that can be updated on OBLU.

Use CHU to change a child’s legal status sequence if needed.

Use the CSPTD screen to delete any incorrect or unnecessary legal statuses. Enter D adjacent to the incorrect status IF the effective date is within the current fiscal year (FY). (If the year is within the previous FY the data cannot be altered). Legal Status is FGN specific. If the update was done at the DCN level, make sure changes only happen to the correct FGN. As much as possible, make changes through the FGN and not the DCN.

Once the legal status is updated from M to I the case will no longer be reported as paternity establishment. There is no need to delete the legal status M on CSPTD.

Final Tips

Caseworkers may need to look at the actual order and not rely solely on OSIS, especially regarding divorced decrees.

There are female NCPs. A child cannot have a legal status of M on a female NCP case, barring exigent circumstances. These cases should always be built as I to A.

Some divorce obligations are truly paternity establishments based on the wording. If it is coded as paternity establishment CSS can get credit for it, especially if the divorce obligation is coded properly.

Anytime you come across a case that is confusing or you get hung up or just need a little more extra one-on-one time to talk about those cases, do not hesitate to contact your PFR at *PFRs@okdhs.org.