Undistributed Collections: What challenges do we face? CSDA 2nd Annual Training Conference & Expo Anaheim, CA September 19, 2007 Today’s Presenters • Elizabeth Morgan, Center for Support of Families • Larry Satter, CA DCSS • Diann Fithian, CA DCSS • Avi DeTurenne, Los Angeles LCSA • Laura Roth, El Dorado LCSA UDC: The Picture at the National Level • From FFY 2001 to FFY 2004, levels of UDC steadily declined • In FFY 2001, net UDC was $738 million • For FFY 2006, net UDC was reported as $485 million, a 37% decrease from FFY 2001. Net UDC $800,000,000 $700,000,000 $600,000,000 $500,000,000 $400,000,000 $300,000,000 $200,000,000 $100,000,000 $0 2000 2001 2002 2003 2004 2005 2006 UDC Pending Distribution • Received within past 2 business days • Tax Offset holds • Future Support • Pending Legal Dispute • Transfer to Other Agency UDC “Unresolved” • • • • • Unidentified Collections Pending Locate Uncashed or Stale-Dated Inaccurate/Missing Information Other Collections Undistributed UDC Unresolved • Federal government began tracking beginning with FFY 2005 • FFY 2005 UDC Unresolved: $200.7 million, or 40.4% of net UDC • FFY 2006 UDC Unresolved: $191.1 million, or 39.4% of net UDC Net UDC FY 2005 and FY 2006 for States with Top Six Caseloads $90,000,000 $80,000,000 $78.1M $70,000,000 $66.7M $60,000,000 $53.1K $50,000,000 $47.5K $40,000,000 $30,000,000 $32.5K $26.2K $20,000,000 $30.7K $27.1K $26.2K $22.3K $14.8K $13.0K $10,000,000 $0 CA TX MI Net UDC 2005 OH Net UDC 2006 NY FL Percentage of Unresolved UDC FY 2005 and FY 2006 for States with Top Six Caseloads 90.0% 80.0% 83.8% 70.0% 70.4% 69.7% 64.8% 60.0% 62.7% 50.0% 45.1% 40.0% 30.0% 32.9% 27.2% 24.7% 20.0% 21.1% 18.5% 18.9% 10.0% 0.0% CA TX MI % Unresolved FY05 OH % Unresolved FY06 NY FL California Quarterly UDC by Category CHILD SUPPORT ENFORCEMENT PROGRAM ITEMIZED UNDISTRIBUTED COLLECTIONS Quarterly UDC by Category Collections Received Within The Past Two Business Days 6/05 9/05 12/05 3/06 6/06 9/06 12/06 3/07 356,695 0 0 0 0 0 652,139 553,496 0 0 0 0 0 0 0 3,018,820 Collections Received and Being Held for Future Support 1,389,650 1,393,669 3,749,739 4,001,822 5,034,936 4,885,851 4,989,276 5,359,522 Collections Being Held Pending the Resolution of Legal Disputes 4,146,203 2,012,205 2,220,548 2,935,940 2,876,399 2,562,524 2,811,098 3,887,380 432,450 211,373 243,783 369,836 486,887 317,726 263,920 310,299 4,334,795 4,455,259 3,774,632 3,254,016 1,828,333 1,490,931 1,274,132 1,528,857 11,531,497 10,086,048 7,087,418 8,639,619 9,597,793 8,867,690 9,487,934 11,122,166 1,511,515 2,222,070 2,393,584 2,658,037 4,705,688 5,877,346 5,942,372 5,785,059 0 28,632 2,855 4,772 6,768 225,438 124,551 175,294 1,874,837 1,865,095 1,869,586 1,841,143 1,809,998 1,983,520 3,784,905 2,133,507 22,274,351 21,342,145 23,705,185 26,346,802 26,211,026 29,330,327 33,874,400 -12.91% -4.19% 11.07% 11.14% -0.52% 11.90% 15.49% Collections From Tax Offsets Being Held for Up to Six Months Collections Being Held Pending Transfer to Other State or Federal Agency Unidentified Collections Collections Being Held Pending the Location of the Custodial or Non-Custodial Parent Collections Disbursed but Uncashed and Stale-Dated Collections With Inaccurate or Missing Information Other Collections Remaining Undistributed TOTAL UDC % change since 6/2005 25,577,642 California Annual UDC by Category CHILD SUPPORT ENFORCEMENT PROGRAM ITEMIZED UNDISTRIBUTED COLLECTIONS Annual UDC by Category FFY 2001 9/01 FFY 2002 9/02 FFY 2003 9/03 Collections Received Within The Past Two Business Days FFY 2004 9/04 FFY 2005 9/05 784,861 Collections From Tax Offsets Being Held for Up to Six Months - FFY 2006 9/06 FFY 2007 3/07 - - 553,496 - - 3,018,820 Collections Received and Being Held for Future Support 1,758,694 1,393,669 4,885,851 5,359,522 Collections Being Held Pending the Resolution of Legal Disputes 5,509,155 2,012,205 2,562,524 3,887,380 Collections Being Held Pending Transfer to Other State or Federal Agency 1,044,345 211,373 317,726 310,299 Unidentified Collections Collections Being Held Pending the Location of the Custodial or Non-Custodial Parent 3,254,182 4,455,259 1,490,931 1,528,857 6,833,002 10,086,048 8,867,690 11,122,166 Collections Disbursed but Uncashed and Stale-Dated 1,456,205 2,222,070 5,877,346 5,785,059 28,632 225,438 175,294 1,873,278 1,865,095 1,983,520 2,133,507 22,513,723 22,274,351 26,211,026 33,874,400 Collections With Inaccurate or Missing Information - Other Collections Remaining Undistributed TOTAL UDC % change since 9/2001 27,345,689 23,449,063 -14.25% 28,800,483 22.82% -21.83% -1.06% 17.67% 29.24% OCSE 34a and Schedule UDC Preparation (Current) Current Process • Consortia systems upload collections, disbursements and UDC to CADS • LCSA director approves monthly CADS reports (Not required for transitioned LCSAs) • CADS validates data between CS34, CS35 and Schedule UDC reports • DCSS uploads CADS data to CSE • CSE combines transitioned LCSAs, Non IV-D and CADS data • DCSS produces OCSE 34A and Schedule UDC reports within CSE • DCSS performs additional validations with by reviewing the CSE audit extract file OCSE 34a and Schedule UDC Preparation (Future) Future Process • • • • • CSE will contain all collections, disbursements and UDC data CSE will validate data between CS34, CS35 and Schedule UDC reports DCSS produces OCSE 34A and Schedule UDC reports within CSE DCSS performs additional validations with by reviewing the CSE audit extract file LCSAs will have access to CS34 and CS35 data within CSE Escheatment (Local Process) • • • LCSAs are encouraged to escheat pre-SDU UDC that meet the requirements in CSS letter (04-22) and local policy/procedures. An emphasis shall be placed on escheating UDC that will not convert to CSE (e.g., CASES LGE or “X” data). LCSAs who cannot escheat these types of UDC prior to conversion must perform the following: – CASES counties: Prior to CSE conversion, must create manual receipts (a.k.a. “R” receipts), using the guidelines provided to the conversion managers by Mary Clesi. – ARS counties: A procedure to address UDC that is not in the ARS application is not available. Please work with conversion manger to resolve any outstanding issues DCSS will transfer funds to LCSAs to complete the escheatment process, if necessary Note: It is important to escheat and/or ensure these funds convert to CSE. If valid UDC does not transfer to CSE, financial reports will not be accurate! Escheatment (State Process) • A process to escheat funds at the State level is currently under development. • It is anticipated that the State escheatment process will utilize the State Controller’s Unclaimed Property Fund and supporting processes. • DCSS will utilize CSE to manage the escheatment process. • Changes to CSE may be necessary in order to comply with recent changes to the Unclaimed Property Law • Additional information on the State escheatment process will be relayed in a future CSS letter UDC Task Force DCSS has been working with the CSDA Finance Committee to establish a task force to monitor UDC issues. CFW - Ds • Resolve issues related to Non IV-D cases and/or cases with a combination of Non IV-D and IV-D. • Unit started 1/1/07 • Consists of 9 staff members • No enforcement actions Non public ph# 916-845-7747 Email address: CFWD@ftb.ca.gov Flow of requests to the CFW-D SDU CFW-D State DCSS Call Center CFW-L (County Requests) What We Do • Research and resolve escalated customer service financial inquiries • Adjust statewide collections • Research and release designated suspended collections • Manage Non IV-D disbursements • Maintain Non IV-D participant information • Manage Non IV-D receivables How to minimize UDCs Educate remitters (employers) If Non IV-D case – advise to put case number on check If IV-D case – advise to put participant number on check Ensure cases have complete information If submitting a request to allocate payment always verify CP address exists and current wage assignment is entered in CSE If requesting a duplicate Non IVD case be closed IV-D case has all the needed information Must have current valid IV-D wage assignment UDC Challenges • Employers not responding • Employers not providing correct information with payments • Case information not current • Converted UDCs from counties • Increasing communication between CFWDs and CFWLs – Our goal is to prevent or resolve UDCs as efficiently as possible! LCSA Level: Root Causes and Reduction Strategies • Why payments go on hold • Collection Hold vs. Distribution Hold • CDRT – Collection and Distribution Research Team • Organized along the structure of the State UDC Report • Reduction Strategies State UDC Hold Categories • Collections From Tax Offsets Being Held for Up to Six Months • Collections Received and Being Held for Future Support • Collections Being Held Pending the Resolution of Legal Disputes • Collections Being Held Pending Transfer to Other State or Federal Agency • Unidentified Collections • Collections Being Held Pending the Location of the Custodial or Non-Custodial Parent • Collections Disbursed but Uncashed and Stale-Dated • Collections With Inaccurate or Missing Information • Other Collections Remaining Undistributed Collections From Tax Offsets Being Held for Up to Six Months Distribution Holds •Injured Spouse Collection Holds •Overage of Injured Spouse Claim IRS intercepts Collections Received and Being Held for Future Support Collection Holds •Future Payment •Voluntary Payment Collections Being Held Pending the Resolution of Legal Disputes Collection Holds • AP Files Bankruptcy • Financial Dispute • FTB Intercept • Court Ordered Impound • IRS Intercept • Legal Dispute • Current Spouse Filed Tax Protest • Trust Fund Hold • UIFSA Responding Case • Writ Distribution Holds • Dispute • Pending Legal Collections Being Held Pending Transfer to Other State or Federal Agency • System Processed Unidentified Collections Collection Holds • Court Order Required Collections Being Held Pending the Location of the Custodial or Non-Custodial Parent Collection Holds • Account(s) Closed • AP Address Unknown • AP Return • Arrears Paid In Full • Misidentified (MID) • Overpayment • System Hold • Warrant Cancelled Distribution Holds • CP Address Unknown • Agency Disbursement Method Unknown • Manual Distribution Hold • CP Request • Overdisbursement • KinGap • Stop Payment • Return Receipt • DPSS Return • Warrant Cancelled Collections Disbursed but Uncashed / StaleDated Collection Holds • Uncashed / Stale-Dated Collections With Inaccurate or Missing Information Collection Holds • Inaccurate / Missing Information Other Collections Remaining Undistributed Collection Holds • Collection Date Required • Bad Check Recovery THREE-PRONGED REDUCTION STRATEGY CLEAR IMMEDIATE PRIORITY HOLDS – Priority Hold Codes – Cases brought to our attention through CP/NCP calls, complaints to OMBUDS, State Hearing cases – Dollar amounts over $5,000 or repeating payments REVIEW HOLD DATES TO CLEAR BACKLOG – Review oldest holds and determine if they can be resolved – Follow up on referrals to divisions for operational work PREVENT UNNECESSARY HOLDS – Supervisor Approval – End dates on holds Conversion Preparation • Work pre-SDU stale-dated checks prior to conversion! • Understand procedures for releasing money in CASES – and do it! UDC and CSE • UDC will most likely increase after an LCSA transitions • IRS hold times • Refund hold times • DCT & held payments • Automatic system refunds Your comments & questions