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The Father Of Today s Child Support Public Policy


THE FATHER OF TODAY S CHILD SUPPORT PUBLIC POLICY, HIS PERSONAL EXPLOITATION OF THE SYSTEM, AND THE FALLACY OF HIS "INCOME SHARES" MODEL

by

James R. Johnston*

(August 1998)

INTRODUCTION

Part 1 presents an overview of Dr. Robert Williams influence over the development of the child support system across the United States, and his concurrent start up and operation of a company while a key consultant with the government working exclusively in the creation of public policy. A chronology of activity during this time (1983-1990) is included. Williams has been and continues to consult with States regarding child support policy and enforcement.

Part 2 focuses on the "Income Shares" model originated by Williams in the 1980 s, and the underlying national economic data sources that he uses to feed it. As of this writing at least 31 states use this model and the underlying economics. Many of the presumptions used in states using other models come philosophically from the same thinking advocated by him. This section will discuss the fundamental flaws of the model, as well as the failure of the underlying economics that ultimately lead to support obligation numbers.

As you will see, Williams clearly drove the elements of today s child support system, concurrently creating a company that could exploit the very programs he was helping to establish. The company, Policy Studies, Incorporated of Denver, essentially brags about this in their company promotional material. His model and the underlying economics fall far short in trying to result in equitable and reasonable child support for our nation s children. Financial considerations are given total weight based on a flawed process, while emotional child support is ignored. The latter is not a "free good", and by ignoring the reality that there are two parents now in two households, our children suffer.

I want to thank Roger Gay and Greg Palumbo for their contributions and advice on the content of this paper.

*Jim Johnston is a joint custodial parent of two children in Wichita, Kansas. He s the Chair of a local group called KIDSVIEW, working to maximize dual parent involvement in their children s lives outside the intact family. They are working hard at changing legislation in Kansas regarding custody and support, and nationally by lobbying their Congressional delegation on the need for gender neutrality in legislation dealing with children. In February of this year Johnston was appointed by the Chief Justice of the Kansas Supreme Court to serve on the Child Support Guidelines Advisory Committee. He can be contacted at (316) 685-6297, or via e-mail at jjohns1043@aol.com.


PART 1: DR. ROBERT WILLIAMS AND HIS INFLUENCE ON TODAY S CHILD SUPPORT SYSTEM. A QUESTION OF ETHICS?

As anyone familiar with domestic law would know, child support in the United States is a growing multi-billion dollar public policy issue. Much controversy surrounds it, from determination of the amounts owed and by whom, as well as the punitive enforcement measures being undertaken at local, state, and federal levels. Below I detail information about one man s efforts at influencing, establishing, and ultimately exploiting this lucrative "industry". Dr. Robert Williams, founder and primary owner of a privately held business in Denver, Policy Studies, Inc., has cleverly manipulated and in effect, set up the child support mechanisms throughout the US, working within the federal and various state governments, creating a market from which he has been and continues to profit. He clearly is the "father" of current US child support public policy. His efforts have cost federal and state taxpayers billions of dollars, without appreciably improving the lot of children in spite of the rhetoric to the contrary. In fact, many would argue that in the process, he is harming children through establishment of an overall approach that is out of control, disables noncustodial parents from meaningful involvement with their children, and overall, misses the reality of what child support should truly be.

  1. Williams consulted with the US Health and Human Services (HHS) agency s Office of Child Support Enforcement from 1983-1990, directing research and technical assistance for the federally funded Child Support Guidelines Project. During this time, a federally-driven approach was developed in Washington that has lead to significantly increased child support obligations owed. (Dramatic new legislation was passed in Washington in 1984 and in 1988 that he clearly influenced). He consulted with many States as well, and continues to do so today.
  2. In 1984, one year after establishing his influence with the government, Williams started Policy Studies, Incorporated in Denver with 3 employees.
  3. In 1987, for use in consulting with HHS and the various States, Williams developed and introduced a model for child support guidelines called "Income Shares", now used in some form in at least 31 states. It has lead to significantly increased child support obligations (using extremely flawed expenditure data gathered from intact families - SEE PART 2) while providing no built in consideration for "credits" for the expenses related to a child s time spent with their involved other (noncustodial) parent.
  4. Policy Studies two biggest lines of business is in general guidelines development consulting with States based upon the Williams model, and the other is to provide child support collections. In mid-1997, his company had some 500 employees, with over $21 million in revenues. While consulting he urges adoption of a model (costing large consulting fees in the process,
  5. reimbursed at least 67% by federal tax dollars to the state per US public policy) that leads to dramatically increased child support with little or no credits, thereby creating a hardship on noncustodial parents struggling to remain involved with their children. This results in an increased pool of potential child support obligation owed, and increased arrearage for his collection division to exploit.

It is clear that Williams has not only influenced policy through his involvement with the agency responsible for child support enforcement, but with his inside knowledge has developed a consulting business and collection agency targeting privatization opportunities with those he has consulted. In 1996, his company had the greatest number of child support enforcement contracts, covering numerous counties in seven States, of any of the private companies that held State contracts. Reimbursement to his company for child support enforcement ranges from 10-32% of what the company collects according to the General Accounting Office (HEHS97-4). And according to company promotional literature, they currently operate 31 privatized service locations in 15 states. The conflict of interest between Williams consulting to raise child support guidelines and his company s private Child Support Enforcement activities should be apparent. It should also be apparent that any raises in the child support guideline he obtains in any State can be used as leverage for raising the child support guidelines in another State where he has private child support contracts today, or where he may have them tomorrow. He has continued acting as the pied piper for raising child support guidelines nationally, where he and his company profits.

Adding insult to injury, while the "father" of today s child support public policy continues to profit from his past unique opportunity of influence, the basis of his consulting utilized in most of the Country is statistically, economically, and intellectually flawed. The end result is a much costlier approach to child support enforcement to US taxpayers, but more importantly, it continues to drive an ever-widening wedge between children and the parent obligated to paying financial child support. This will be discussed in substantial detail in Part 2.

A CHRONOLOGY OF WILLIAMS EFFORTS ALONG WITH COINCIDENT AND SIGNIFICANT FEDERAL POLICY CHANGE DURING HIS CONSULTING TENURE WITH HHS (1983-1990):

    1. Mandatory Enforcement Practices
    2. Improved Interstate Enforcement
    3. Equal Services for Welfare and Non-AFDC Families
    4. Other Provisions for the States including:

- Collecting spousal support as well where both are due in a case;

- Establishment of State Commissions to study the operation of the State s child support system and report findings to the State s Governor;

- Formulate guidelines for determining child support obligation amounts and distribute the guidelines to judges and other individuals who possess authority to establish obligation amounts

    1. Guidelines for Child Support Awards - Judges and other officials are required to use state guidelines for child support unless they rebut the guidelines by a written finding that applying them would be unjust or inappropriate in a particular case. States must review the guidelines for awards every four years.
    1. Establishment of Paternity - Federal standards are established by formula. The Federal matching rate for laboratory testing to establish paternity is set at 90%.
    2. Requirement for Automated Tracking and Monitoring System - Each State is required to have a fully operative statewide system in place by October 1, 1995, and states had 90% matching by the Federal government.
    3. Interstate Enforcement - A Commission on Interstate Child Support was created to hold national conferences by October 1, 1990 to make improvement recommendations.

PART 2: A REVIEW OF THE WILLIAMS-INSPIRED "INCOME SHARES" MODEL, AND PROBLEMS INHERENT IN THE UNDERLYING ECONOMICS

My state of residence is Kansas, which is a joint custody preference state by statute (meaning legal decision making, not necessarily shared physical custody). Well over 80% of the cases result in joint custody awards. It is only logical that the most significant reason a judge would order joint custody, or short of that, some degree of visitation, would be a recognition that both parents are going to maintain some degree of involvement with their child post-separation/divorce. In those situations, legislatures and/or courts are stating that it is in the child s best interests to have such involvement with both parents. Yet as will be described below, the financial child support schedules of most state guidelines are derived from data collected from overall expenditures made by intact family households throughout the country, with minimal state-specific participation. According to federal law, all relevant costs of raising the child in that state are to be taken into account by the state model used to develop the support obligation schedules, creating a rebuttable presumption. Without including direct costs incurred by the second involved parent specifically in the guideline economics, such costs have not been considered. (They are in fact, left totally to the discretion of the court, with little guidance on how to consider them in determining an appropriate and just child support award.)

When one fully grasps the economic methodology used in today s guideline development, there becomes a recognition that it is impossible to really know what guideline numbers are appropriate or what assumptions are used to determine state-specific child support obligations. Only through getting at just those things would states be consistent with the tone of the 1996 report from the Office of Child Support Enforcement (OCSE) where they said,

"Surprisingly, few States reviewed their core guideline model or methodology. Rather, guideline reviews focused on issues relating to income, adjustments to income, adjustments to the guideline amount, and deviations from the guideline amount."

What is needed is to get outside the paradigm that existing models (using the same "economic studies") are the only way of determining appropriate and just child support awards in each state. The reality is that the base economic studies used in child support schedule development were not planned for nor conducted with child support considerations in mind. Rather, they were designed for significantly different purposes, never intended to be specifically applied to individual situations such as child support. Highlighting this fact is that none of the studies measure what federal law says we need to do in each state, and that is to fully understand the impact on both parents ability to continue to provide for their children in two separate households, fully considering the involved second parent s expenses. The United States Bureau of Labor Statistics which gathers

the base expenditure data used in the "Income-Shares" model espoused by Williams, actually cautions against the use of such generalized data to apply to any individual situation, exactly what is done in the vast majority of the states, including Kansas. Most states have also been reviewing the logic of their child support guidelines based entirely within the bounds of the guideline logic itself. Over time, it is likely in each state that one can t tell for certain what assumptions have truly been included in the model or not, each of which directly affects the child support schedule values. Often, the state review committee has simply gone back to see if the modified guidelines still conform to the original developer s personal preferences. In the 14 years since the federal government mandated development of statewide child support guidelines, additional research has been conducted, including new scientific approaches that solve many of the problems both in the baseline data used in state child support models, as well as in the models themselves. The flaws inherent in the current child support estimate methodologies are being addressed in this research. These should be fully explored consistent with what the OCSE urges be done regarding methodology review.

THE FLAWED INCOME SHARES MODEL

The "Income Shares" model is currently used for child support guidelines development in at least 31 states as of this writing. Additionally, most of the other states utilize the same underlying economics used in this model for their particular state guidelines. This model was developed in 1987 by Williams, and was introduced in his report, "Development of Guidelines for Child Support Orders: Advisory Panel Recommendations and Final Report." for the U.S. Department of Health and Human Services, Office of Child Support Enforcement, where as noted previously, he was a paid consultant driving the development of uniform guidelines throughout the country. The next year, Congress passed The Family Support Act of 1988 (Pub. L. No. 100-485) which mandated that states implement presumptive, rather than advisory, child support guidelines, giving the states only one year to do so. Virtually all states met the congressional deadline with such guidelines in place by October 1989. It appears obvious that due to the short deadline required of the states to comply with this new law, most conveniently opted for the very model being espoused by the agency overlooking the whole program, the Income Shares model.

Williams describes his model in the Health and Human Services publication, "Child Support Guidelines: The Next Generation", published in April 1994:

"The Income Shares model is based on the concept that the child should receive the same proportion of parental income that he or she would have received if the parents lived together. A basic child support obligation is computed based on the combined income of the parents (REPLICATING TOTAL INCOME IN AN INTACT HOUSEHOLD) {emphasis added}. This basic obligation comes from a

table which is derived from economic estimates of child-rearing expenditures, minus average amounts for health insurance, child care, and child s extraordinary medical expenses. The basic child support obligation is divided between the parents in proportion to their relative incomes. Pro-rated shares of child care and extraordinary medical expenses are added to each parent s basic obligation. IF ONE PARENT HAS CUSTODY, THE AMOUNT CALCULATED FOR THAT PARENT IS PRESUMED TO BE SPENT DIRECTLY ON THE CHILD. FOR THE NONCUSTODIAL PARENT, THE CALCULATED AMOUNT ESTABLISHES THE LEVEL OF CHILD SUPPORT {emphasis added}."

He continues, "The Income Shares model was developed by the staff of the Child Support Guidelines Project, which was funded by the U.S. Office of Child Support Enforcement and administered by the National Center for State Courts. It utilizes several concepts from the earlier Washington (State) Uniform Child Support Guidelines, but diverges in basing its numerical parameters explicitly on a different and more recent body of economic analysis."

The reader is urged to keep in mind a few key points from Williams description of his Income Shares model as they will be addressed in the balance of this paper.

    1. The "model is based on the concept that the child should receive the same proportion of parental income that he or she would have "theoretically" received if the parents lived together. It is designed to "theoretically replicate total income in an intact household".
    2. No consideration is provided for the reality of additional expenses that occurs in an involved second parent s household, which is necessitated by the simple and obvious fact that the parents no longer live together. Only one household matters.
    3. Health insurance, child care, and extraordinary medical expenses are typically added on to the obligation after the basic amount is calculated.
    4. The one parent with sole custody, or the one parent with primary residency in states with joint custody, receives the child support payment, and it is "presumed" that the money is spent directly on the child. No accountability, something that occurs in virtually all other financial "trust" situations which child support certainly is, is required of the receiving parent. The full weight of local, state, and federal law however, ensures the accountability of the obligor to pay the recipient.

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