Streamlining Feasibility Studies

DEAR COLLEAGUE LETTER

DCL-19-05

DATE: July 23, 2019

TO: State IV-D Directors

SUBJECT: Streamlining Feasibility Studies

Dear Colleague:

The federal Office of Child Support Enforcement is streamlining requirements for conducting feasibility studies associated with modernization of statewide child support enforcement systems. This is an initial guidance on how states may proceed during the interim period until the full guidance is rolled out. As state child support enforcement systems reach the end of their useful life, many states are embarking on system modernization projects. Federal guidance issued in July 1993 (and further clarified with AT-06-03) required states to conduct a rigorous feasibility study. This guidance was issued during a time when web technologies and modern platforms were either non-existent or in the nascent stages.

On average, states are spending $2 million to $5 million on each feasibility study, and with the rapid pace of technological advances, the length of time required to conduct the study may cause the choice to become obsolete by the time the project is initiated. Hence, two major goals of OCSE’s State Systems Symposium in February 2019 were to better appreciate states’ pain points associated with feasibility studies and begin developing a solution that accounts for states’ modernization lessons learned.

Next steps

As part of the analysis effort for any system modernization, a state’s program and technical teams will always be evaluating the need, suitability, pros and cons, cost, efficiency, and sustainability of alternatives. OCSE’s goals for the revised guidance will be to recognize the analysis work that states are already performing and simplify documentation submitted to OCSE. We intend to achieve this simplification by eliminating many of the feasibility study steps, as you currently know them. Instead, we’ll ask states to summarize their business case, including their funding commitment, a ’very light or state defined’ alternatives analysis, and a cost-benefit analysis, into a single document that may be less than 50 pages in length. This process may be defined as a “business case analysis” rather than a “feasibility study.” After the new guidance is fully developed, OCSE will request feedback from the National Council of Child Support Directors (NCCSD) and state child support directors.

Interim guidance

In general, states may consider the following approaches (not in any order or preference) when considering system modernization. Note that replatforming or refactoring does not trigger any “feasibility study” requirement, while the other approaches do.

• Replatforming or refactoring: Replatforming includes moving to a new environment (platform and/or operating system) and is often augmented with software refactoring (code translation) to a different language. Alaska, Arkansas, Colorado, Idaho, Kansas, Ohio, Rhode Island, Tennessee, and Utah have chosen this path of modernization. Note that this approach needs only a revised Annual Advance Planning Document Update (AAPDU) or Operational Advance Planning Document Update (OAPDU).
• Transfer systems from another state: State systems that are popular transfer candidates include Delaware, New Jersey, and Florida. Additional transfer candidates becoming available in 2019 and 2020 include Massachusetts, Oregon, South Carolina, and Texas.
• Build your own: As the name indicates, a state may opt to build their own unique child support enforcement system with the help of contractors. Maryland has chosen this alternative.
• Commercial off the shelf (COTS): Several vendors in the child support community offer COTS products that states may consider implementing for their modernization. Florida chose the COTS alternative.

During this interim timeframe, states are not expected to comply specifically with the lengthy 1993 Feasibility Study document requirements. If a state is starting their analysis at this time, contact the DSTS Director so that we can work with you on what should be submitted.

Given the widespread need for modernization of child support systems, we encourage you to share this communication with your agency heads as appropriate for your state. If you have questions, send them to the Division of State and Tribal Systems at OCSE.DSTS@acf.hhs.gov.

Sincerely,

Scott M. Lekan
Commissioner
Office of Child Support Enforcement