Audit Report

Department of Human Services

Child Support Administration

April 2025

OFFICE OF LEGISLATIVE AUDITS

DEPARTMENT OF LEGISLATIVE SERVICES
MARYLAND GENERAL ASSEMBLY
 Joint Audit and Evaluation Committee
Senator Shelly L. Hettleman (Senate Chair) Delegate Jared Solomon (House Chair)
Senator Joanne C. Benson Delegate Steven J. Arentz
Senator Benjamin T. Brooks, Sr. Delegate Andrea Fletcher Harrison
Senator Paul D. Corderman Delegate Steven C. Johnson
Senator Katie Fry Hester Delegate Mary A. Lehman
Senator Cheryl C. Kagan Delegate David H. Moon
Senator Clarence K. Lam, M.D. Delegate Julie Palakovich Carr
Senator Cory V. McCray Delegate Emily K. Shetty
Senator Justin D. Ready Delegate Stephanie M. Smith
Senator Bryan W. Simonaire Delegate M. Courtney Watson

To Obtain Further Information

Office of Legislative Audits
The Warehouse at Camden Yards
351 West Camden Street, Suite 400
Baltimore, Maryland 21201
Phone: 410-946-5900
Maryland Relay: 711
TTY: 410-946-5401 ꞏ 301-970-5401
E-mail: [email protected]
Website: www.ola.state.md.us

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Information Officer at 410-946-5400 or 410-970-5400.
 April 3, 2025

Senator Shelly L. Hettleman, Senate Chair, Joint Audit and Evaluation Committee
Delegate Jared Solomon, House Chair, Joint Audit and Evaluation Committee
Members of Joint Audit and Evaluation Committee
Annapolis, Maryland

Ladies and Gentlemen:

We have conducted a fiscal compliance audit of the Department of Human

Services (DHS) – Child Support Administration (CSA) for the period beginning
September 1, 2020 and ending December 31, 2023. CSA is responsible for
operating the Statewide child support program, which includes the establishment
of paternity and child support orders, and the collection and distribution of child
support payments. For the federal fiscal year ended September 30, 2023, child
support collections totaled $457.8 million and unpaid child support due from
obligors/non-custodial parents totaled $1.4 billion at that date.

Our audit disclosed that CSA did not have sufficient procedures to ensure that the
Motor Vehicle Administration (MVA) suspended driver’s licenses of non-
custodial parents who were delinquent in their child support payments.
Specifically, CSA does not require caseworkers to record the non-custodial
parent’s driver’s license number in the case management system even though its
agreement with MVA required this information for the match. This resulted in
numerous referrals being rejected by MVA, which were not investigated and
resolved. A similar condition regarding CSA not investigating referral rejections
was commented upon in our preceding audit report.

DHS’ response to this audit, on behalf of CSA, is included as an appendix to this

report. In accordance with State law, we have reviewed the response and, while
CSA agrees with the recommendations in this report, it has disagreed with our
assessment that the condition described above represents a repeat finding from the
preceding report. After reviewing CSA’s response, we continue to believe that
this condition is accurate. In accordance with generally accepted government
auditing standards, we have included an “auditor’s comment” within DHS’
response to explain our position. We will advise the Joint Audit and Evaluation
Committee of any outstanding issues that we cannot resolve with CSA.

We wish to acknowledge the cooperation extended to us during the audit by CSA.

Respectfully submitted,

Brian S. Tanen
Brian S. Tanen, CPA, CFE
Legislative Auditor

2
 Background Information

Agency Responsibilities

The Child Support Administration (CSA) is a unit within the Department of

Human Services (DHS) and is responsible for operating the Statewide child
support program. CSA provides services to both the non-custodial and custodial
parents, which include the establishment of paternity and child support orders, the
collection of child support payments, and the distribution of such funds.
According to the State’s records, CSA’s operating expenditures for State fiscal
year 2023 totaled approximately $45.3 million (see Figure 1 on the following
page).1

During the period July 1, 2019 through June 30, 2023, CSA had vacancy rates
that ranged from 4.8 percent to 11.5 percent. As of June 30, 2023, approximately
11.5 percent of the total 61 positions were vacant. These vacancies may have
contributed, at least in part, to the findings in this report.

1
This excludes local child support office expenditures, which are included in a separate DHS
budgetary unit.

3
 Figure 1
CSA Positions, Expenditures, and Funding Sources
Full-Time Equivalent Positions as of June 30, 2023
Positions Percent
Filled 54 88.5%
Vacant 7 11.5%
Total 61

Fiscal Year 2023 Expenditures

Expenditures Percent
Salaries, Wages, and Fringe Benefits $ 6,971,439 15.4%
Operating Expenses 38,317,043 84.6%
Total $45,288,482

Fiscal Year 2023 Funding Sources

Funding Percent
General Fund $ 2,222,591 4.9%
Special Fund 12,212,379 27.0%
Federal Fund 30,853,512 68.1%
Total $45,288,482

Source: State financial and personnel records

Local child support offices, under CSA’s oversight, and other state and local
government agencies (such as State’s Attorneys’ Offices) perform various child
support services. Furthermore, a private vendor, under contract to CSA, provides
child support functions in Baltimore City, which handles approximately 20
percent of the State’s child support cases. In addition, CSA uses the services of
two additional private vendors—one vendor maintains the Maryland State
Directory of New Hires which is used to identify obligor/non-custodial parent2
(NCP) wages on a statewide basis, and the other vendor centrally receives,
processes, and distributes child support payments.

According to CSA’s records, during federal fiscal year 2023 (October 1, 2022
through September 30, 2023), Statewide child support collections related to
approximately 162,000 open cases totaled $457.8 million. As of September 30,

2
While the obligor (individual legally required to make child support payments) may not always
be the non-custodial parent, for purposes of this report reference to the NCP is considered the
obligor.

4
2023, the cumulative unpaid child support due from obligors totaled
approximately $1.4 billion. As reflected in Figure 2, the unpaid child support
balance has remained consistent between federal fiscal years 2020 and 2023,
while current child support collections and the number of open cases has
decreased by $125 million (21 percent) and 18,000 (10 percent),3 respectively,
over this period.

Figure 2
Child Support Data
Child Support Collections Unpaid Child Support Open Cases

$1,600 180,000 200,000

169,000 162,000

Open Child Support Cases

$1,400 160,000
$1,200 150,000
$ in Millions

$1,000
$800 100,000
$600
$400 50,000
$200
$0 0
2020 2021 2022 2023
Federal Fiscal Year

Source: CSA records

Child Support Management System

In September 2022, CSA fully implemented the Child Support Management

System (CSMS) which replaced CSA’s legacy Child Support Enforcement
System. CSMS is a web-based application that is part of the Maryland Total
Human-Services Integrated Network (MD THINK) which is a cloud-based
platform that allows multiple State health and human services agencies to share
and manage data in one place. CSMS is used primarily for case management
including maintaining case information, documenting enforcement efforts, and
recording information about collection and distribution of support payments.
CSA has faced significant system challenges with CSMS including receiving and
disbursing child support payments and technological problems.4

3
The quantity of cases is dependent on the court systems and not under CSA control. Per a July
2023 University of Maryland School of Social Work Public Policy Research paper, Maryland’s
Child Support Caseload Trends Among Cases, 2016 to 2022, child support caseloads have been
declining for decades across the country, though the reduction in Maryland has outpaced national
trends.
4
Our audit report of the Department of Information Technology (DoIT) dated March 29, 2024,
identified numerous concerns with the implementation and oversight of the MD THINK project.

5
Enforcement Action Overview

Child support services are generally performed by local offices throughout the
State, including the Baltimore City office where a vendor provides the services,
with oversight and administration provided by CSA central office personnel.
CSA uses several enforcement tools to pursue court-ordered child support when
an obligor does not pay fully or on time. These tools include withholding wages
and intercepting federal and State payments (such as, tax refunds).

The primary source to facilitate the identification of wages for withholding is the
Maryland State Directory of New Hires which is an automated system for
collecting, storing, and extracting employer-reported information on new hires,
mandated by federal law. The system is maintained by a vendor under contract to
DHS. Other enforcement tools provided for in State law include driver’s license
and occupational license suspensions.5 For example, State law permits the
suspension of driver’s licenses by the Motor Vehicle Administration when an
obligor is at least 60 days delinquent in child support payments.

Status of Findings From Preceding Audit Report

Our audit included a review to determine the status of the two findings contained
in our preceding audit report dated May 13, 2021. As disclosed in Figure 3, we
determined that CSA satisfactorily addressed one of these findings. The
remaining finding is repeated in this report.

Figure 3
Status of Preceding Findings
Preceding Implementation
Finding Description
Finding Status
CSA did not obtain and investigate driver’s
Repeated
Finding 1 license suspension referrals rejected by the
(Current Finding 1)
Motor Vehicle Administration (MVA).
CSA did not obtain adequate assurance that the
vendor responsible for distributing child
support payments had sufficient security over
Finding 2 Not Repeated
its information system to protect sensitive data
such as personally identifiable information
(PII) for custodial and noncustodial parents.

5
The Driver’s License Suspension program was paused between July 2022 and April 2023 due to
errors interfacing the new CSMS system with the MVA.

6
 Findings and Recommendations

Driver’s License Suspension

Finding 1
The Child Support Administration (CSA) did not have sufficient procedures
to ensure that the Maryland Department of Transportation Motor Vehicle
Administration (MVA) suspended the driver’s licenses of non-custodial
parents (NCPs) who were delinquent in their child support payments.

Analysis
CSA did not have sufficient procedures to ensure that the MVA suspended the
driver’s licenses of NCPs who were delinquent in their child support payments.
In accordance with State law, CSA sends a listing to the MVA of NCPs whose
payments are at least 60 days out of compliance. The MVA performs automated
matches between the CSA listing and its licensing system and either suspends the
licenses of NCPs that match its records or rejects the referral. Per MVA records,
between September 2023 and February 2024, CSA submitted 13,636 unique
NCPs for suspension of which 5,070 (37 percent) were rejected by the MVA. Our
review disclosed that CSA did not have sufficient procedures to address these
rejected claims.

 Although one of the data points MVA matches to CSA’s listing is the NCP’s
driver’s license number, CSA procedures do not require caseworkers to record
the NCP’s driver’s license number in CSMS. Our analysis of the 5,070
rejected referrals disclosed that 865 (or 17 percent) were caused solely by a
driver’s license number mismatch or omission. We were advised by CSA that
while a driver’s license number is not necessary to identify an individual when
initiating a child support case, it agreed to MVA’s terms for the match which
requires an exact match of 4 data elements including the driver’s license
number.

 CSA did not investigate and resolve rejected referrals that may be the result of
data entry errors. For example, the MVA would reject a referral for which
two or more NCP data elements matched MVA records but there was a
difference of one day between the CSA and MVA’s records for the NCP’s
date of birth. CSA did not research any rejected claims to determine and
correct errors in the data.

A similar condition regarding CSA not investigating referral rejections was

commented upon in our preceding audit report. The Department of Human
Services, on behalf of CSA, disagreed with our recommendation but in follow-up

7
correspondence, dated June 23, 2021, agreed to consult with the MVA following
the implementation of the new Child Support Management System to ensure the
suspension program was effective. During our current audit, CSA management
was unable to explain the result of their consultation with MVA and still was not
investigating rejected referrals.

Recommendation 1
We recommend that CSA develop procedures to ensure that driver’s licenses
are being properly suspended, including the review of rejections by the
MVA, and to provide corrected information to the MVA to process driver’s
license suspensions (repeat).

Audit Scope, Objectives, and Methodology

We have conducted a fiscal compliance audit of the Department of Human
Services (DHS) – Child Support Administration (CSA) for the period beginning
September 1, 2020 and ending December 31, 2023. The audit was conducted in
accordance with generally accepted government auditing standards. Those
standards require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence obtained
provides a reasonable basis for our findings and conclusions based on our audit
objectives.

As prescribed by the State Government Article, Section 2-1221 of the Annotated

Code of Maryland, the objectives of this audit were to examine CSA’s financial
transactions, records, and internal control, and to evaluate its compliance with
applicable State laws, rules, and regulations.

In planning and conducting our audit, we focused on the major financial-related

areas of operations based on assessments of significance and risk. The areas
addressed by the audit included enforcement procedures (for example,
occupational and driver’s license suspensions and wage withholding), access and
controls over CSA’s Child Support Management System (CSMS), monitoring of
local child support offices, and contracts. We also determined the status of the
findings contained in our preceding audit report.

Our audit did not include various support services provided by DHS’ Office of the
Secretary. These support services (such as payroll, purchasing, maintenance of
accounting records, and related fiscal functions) are included within the scope of
our audit of the DHS Office of the Secretary and Related Units. In addition, our

8
audit did not include an evaluation of internal controls over compliance with
federal laws and regulations for federal financial assistance programs and an
assessment of the CSA’s compliance with those laws and regulations because the
State of Maryland engages an independent accounting firm to annually audit such
programs administered by State agencies, including the CSA.

Our assessment of internal controls was based on agency procedures and controls
in place at the time of our fieldwork. Our tests of transactions and other auditing
procedures were generally focused on the transactions occurring during our audit
period of September 1, 2020 to December 31, 2023, but may include transactions
before or after this period as we considered necessary to achieve our audit
objectives.

To accomplish our audit objectives, our audit procedures included inquiries of

appropriate personnel, inspections of documents and records, tests of transactions,
and to the extent practicable, observations of the CSA’s operations. Generally,
transactions were selected for testing based on auditor judgment, which primarily
considers risk, the timing or dollar amount of the transaction, or the significance
of the transaction to the area of operation reviewed. As a matter of course, we do
not normally use sampling in our tests, so unless otherwise specifically indicated,
neither statistical nor non-statistical audit sampling was used to select the
transactions tested. Therefore, unless sampling is specifically indicated in a
finding, the results from any tests conducted or disclosed by us cannot be used to
project those results to the entire population from which the test items were
selected.

We also performed various data extracts of pertinent information from the State’s
Financial Management Information System (such as expenditure data). The
extracts are performed as part of ongoing internal processes established by the
Office of Legislative Audits and were subject to various tests to determine data
reliability. We determined that the data extracted from these sources were
sufficiently reliable for the purposes the data were used during this audit. We also
extracted data from CSMS for the purpose of testing various enforcement efforts.
We performed various tests of the relevant data and determined that the data were
sufficiently reliable for the purposes they were used during the audit. Finally, we
performed other auditing procedures that we considered necessary to achieve our
audit objectives. The reliability of data used in this report for background or
informational purposes was not assessed.

CSA’s management is responsible for establishing and maintaining effective

internal control. Internal control is a process designed to provide reasonable
assurance that objectives pertaining to the reliability of financial records;

9
effectiveness and efficiency of operations, including safeguarding of assets; and
compliance with applicable laws, rules, and regulations are achieved. As
provided in Government Auditing Standards, there are five components of
internal control: control environment, risk assessment, control activities,
information and communication, and monitoring. Each of the five components,
when significant to the audit objectives, and as applicable to CSA, were
considered by us during the course of this audit.

Because of inherent limitations in internal control, errors or fraud may

nevertheless occur and not be detected. Also, projections of any evaluation of
internal control to future periods are subject to the risk that conditions may
change or compliance with policies and procedures may deteriorate.

Our reports are designed to assist the Maryland General Assembly in exercising
its legislative oversight function and to provide constructive recommendations for
improving State operations. As a result, our reports generally do not address
activities we reviewed that are functioning properly.

This report includes a finding relating to a condition that we consider to be a

significant deficiency in the design or operation of internal control that could
adversely affect CSA’s ability to maintain reliable financial records, operate
effectively and efficiently, and/or comply with applicable laws, rules, and
regulations. The finding is also regarded as a significant instance of
noncompliance with applicable laws, rules, or regulations. Other less significant
findings were communicated to CSA that did not warrant inclusion in this report.

The response from DHS, on behalf of CSA, to our finding and recommendations
is included as an appendix to this report. As prescribed in the State Government
Article, Section 21224 of the Annotated Code of Maryland, we will advise DHS
regarding the results of our review of its response.

10
 Exhibit 1
Listing of Most Recent Office of Legislative Audits
Fiscal Compliance Audits of Department of Human Services Units
As of February 2025
Most Recent Number of Repeat
Name of Audit Total Findings
Report Date Findings
Office of the Secretary and
1 2/28/2025 9 1
Related Units
Family Investment
2 10/21/2022 10 5
Administration
3 Local Department Operations 3/30/2022 6 5
4 Social Services Administration U 6/3/2021 8 7
Total 33 18
U - This audit had an unsatisfactory rating.

11
 APPENDIX

Wes Moore, Governor • Aruna Miller, Lt. Governor • Rafael López, Secretary

April 1, 2025

Mr. Brian S. Tanen, CPA, CFE

Legislative Auditor
Office of Legislative Audits
The Warehouse at Camden Yards,
351 West Camden Street, Suite 400
Baltimore, Maryland 21201

Dear Mr. Tanen:

Enclosed is the Department of Human Services’ (DHS) response to the draft

Legislative Audit Report on the Department of Human Services – Child Support
Administration (CSA) for the period beginning September 1, 2020 and ending
December 31, 2023.

The Department takes audit findings seriously and is committed to resolving the
findings identified in the audit report.

We are happy to answer any questions. Please contact Marva Sutherland, Inspector
General, at [email protected] if you would like to continue the
conversation.

In service,

Carnitra White
Principal Deputy Secretary

Enclosures:

cc:
Gloria Brown Burnett, Deputy Secretary for Operations
Daniel Wait, Deputy Secretary for Talent & Customer Service
Webster Ye, Chief of Staff
Jarnice Johnson, Executive Director, CSA
Christina Tabuteau, Deputy Executive Director of Operations, CSA
Samantha Phillips, Acting Deputy Executive Director of Programs, CSA
Marva Sutherland, Inspector General
Shelly-Ann Dyer, Assistant Inspector General for Audits

25 S. Charles Street, Baltimore, MD 21201-3500​

Tel: 1-800-332-6347 | TTY: 1-800-735-2258 | www.dhs.maryland.gov
 Department of Human Services
Child Support Administration
Agency Response Form

Driver’s License Suspension

Finding 1
The Child Support Administration (CSA) did not have sufficient procedures
to ensure that the Maryland Department of Transportation Motor Vehicle
Administration (MVA) suspended the driver’s licenses of non-custodial
parents (NCPs) who were delinquent in their child support payments.

We recommend that CSA develop procedures to ensure that driver’s licenses

are being properly suspended, including the review of rejections by the
MVA, and to provide corrected information to the MVA to process driver’s
license suspensions (repeat).

Agency Response
Analysis
Please provide CSA does not agree that this is a repeat finding. Detailed explanation is
additional comments as provided below.
deemed necessary.

Recommendation 1 Not Factually Accurate Estimated Completion Date: N/A

Please provide details of
corrective action or The Child Support Administration (CSA) respectfully disagrees with this
explain disagreement. finding being categorized as a repeat condition as we have diligently
addressed the primary recommendation of the prior audit, which stated:
We recommend that CSA work with MVA to reestablish the possible
match program, review possible matches identified, and report corrected
information to MVA to process drivers’ license suspensions.
Specifically,

● Collaboration with MVA to Reinstate Possible Match

Reporting: CSA engaged in constructive discussions with the
MVA on August 18, 2022, to explore the possibility of
reinstating the "Possible Match" reporting system.

Under the Possible Match process, CSA would send a list of

offenders to suspend. If the automated matching system was
unable to locate an exact match in the MVA system, the system
was programmed to return to CSA information on the 10 closest
matches including Providing Personally Identifiable Information

Page 1 of 3
 Department of Human Services
Child Support Administration
Agency Response Form

(PII) from the MVA database. Providing PII to a third party for
customers who have nothing to do with a particular transaction
presents a potential privacy exposure that MVA does not view as
an acceptable risk. As such, MVA has decided to discontinue the
match program. We acknowledge MVA's decision not to
reinstate this program, based on their valid concerns regarding
the protection of Personally Identifiable Information (PII) for
individuals who are not CSA clients. MVA’s written explanation
has been shared with the legislative auditors.

● Commitment to Accuracy and Fairness: We are committed to

minimizing potential harm to our customers. CSA will continue
to implement a balanced approach, prioritizing both accuracy and
fairness. We will:
○ Continue to maintain a strong working relationship with
the MVA to ensure the ongoing accuracy and efficiency
of the Driver's License Suspension program. For example,
MVA began providing a return file of matches and non
matches. If a person shows up as a non-match, the
portion of the record that did not match is highlighted in
the returned file. CSA agrees to enhance our procedures
to include a review of the non-match information and
provide corrected information to MVA to process driver’s
license suspensions. Specifically, we are enhancing
existing reports to include a “No Match” report for our
local offices to identify and address data discrepancies.
The aforementioned report will be released for local use
by May of 2025. Training on how to review this report
will be provided. Corrections will be sent to MVA at the
end of each month through the match process.

In essence, CSA has made a concerted effort to address the previous

audit recommendation, including a collaborative approach with the
MVA. We remain dedicated to ensuring the integrity of our processes
and will continue to work diligently to minimize errors and protect the
rights of our customers, while respecting the MVA's policies.

Page 2 of 3
 Department of Human Services
Child Support Administration
Agency Response Form

Auditor’s Comment: CSA disagrees with our determination that this

finding is repeated from our preceding audit report. While we
acknowledge that CSA worked with the MVA to reestablish a match
program, as noted in our current report, CSA was still not investigating
rejected referrals. Therefore, CSA did not provide correct information to
the MVA to process license suspensions. These are the same conditions
that we noted in our preceding audit report and as such, we continue to
consider this a repeat finding.

Page 3 of 3
 AUDIT TEAM
Catherine M. Clarke, CPA, CIA, CFE
Audit Manager

J. Alexander Twigg
Senior Auditor

Jammie A. Brown
Mia W. Foelster
Kareem R. Jackson
Alexandra M. Resney
Staff Auditors