National Congress for Fathers and Children
James R. Blackston, Director
6185 Hwy 195 North
Jasper, Al 35503-3409
205-221-6558

March 12, 1999

Re: Advisory Committee on Child Support Guidelines Updates

Dear Sirs and Mesdames:

The Alabama Supreme Court's Advisory Committee on Child Support Guidelines Update is considering the new child support guidelines for the next four years.

Many problems exist with Policy Studies Inc.'s (PSI) Proposal, but none more glaring than the following two, very serous problems that will prohibit Policy Studies, Inc's proposal from consideration. The problems are so serious that Policy Studies submission must be totally disqualified as a conflict of interest, incomplete and false data and full of illegal assumptions.

1. PSI uses the database most commonly used to estimate child expenditures called the Consumer Expenditure Survey (CEX.) The Rothbarth models presented in PSI's report is based on household expenditure date reported in the CEX, (See Proposal Appendix I, page 3.)

I wrote to the Bureau of Labors Statistics, which complies the CEX, and asked the following:

Expenditure data developed from the Bureau of Labor Statistics (BLS) annual Consumer Expenditure Survey consists of 5,000 household surveys conducted each quarter, totaling 20,000 surveys/year. (The 5,000 surveyed is a staggered pool concept. The whole annual sample is the same 5,000 households for 3 quarters, and a new 5,000 for a 4th quarter.)

Is the above information true and if so, how many of the sample actually come from Alabama?

Mike Wald, Regional Economist, Bureau Labor Statistics responded as follows:

Date: Tue, 16 Feb 1999 11:02:03 -0500

The CEX sample is actually two parts - an interview survey and a diary survey. Households are requested to participate in the interview survey for five quarters. Each quarter, 20 percent of the households are in their first interview period, 20 percent are in their second, etc.
Each quarter, our target is approximately 5,400 usable interviews (This can vary by quarter and by year.). The diary survey is a separate sample, and each household selected is asked to keep the diary two weeks out of a year. Annually, our target is approximately 10,800 household responses for the diary survey.

Regarding your question about Alabama, CEX collects data from "certainty" and "non-certainty" areas. The survey targets 29 "certainty" areas (Metropolitan Statistical Areas with populations of more than 1.2 million.) for publication.

As it happens, none of those areas are in Alabama. The "non-certainty" areas are statistically sampled to produce data by Census region (Northeast, South, Midwest, and West) and for the nation. We do not publish separate statistics on the sample by state or area within a state (Except for certainty areas.).

Because the survey does not attempt to provide data specifically for a state, the survey is not designed to track household participation by state. The survey's focus is on maintaining sufficient sample size for the certainty areas, the regions, and nationwide.

No consideration is given to the number of sampled areas in a given state. Any data on non-certainty areas would be insufficient to provide information for any given state or non-certainty area within a state.

Statistically speaking, if you are interested in consumer expenditures for Alabama, I would recommend using data for the South. If you were interested in expenditures of people specifically living in Alabama, it would require a survey specifically to meet that need. I hope this rather long response answers your request. If you need more information, you can reach us at (404) 331-3415, M-F, 9:30 am - 3:30 p.m. (Eastern time.).

- Mike Wald
Regional Economist
Bureau Labor Statistics

The BLS validates the argument that I have been making that the data is useless. The federal mandate is that a child support order is supposed to be just and appropriate in each individual case, and be subject to a rebuttal. Without any meaningful direct correlation between what it truly costs to raise a particular child in a specific location in Alabama, it is truly impossible to rebut the guideline amount there. On what basis can you rebut if there is no way of breaking out the number that you think should be applied in your particular circumstance, and if the data is not even locally based?

Recognizing that each state is to have guidelines appropriate to that specific state, I called the regional BLS office in Atlanta, as well as their main office in Washington, and asked how many of the sample actually came from Alabama. All they could tell me was that it was "somewhat less than 100 surveys" None came from any cities in the Alabama.) Therefore, this state's guidelines, to specifically apply to its child support cases, are based upon generalized data, all of which comes from out of state, and again which are derived from intact family expenditures. With this small national sample size, this has to be the case in each state. The bigger problem however, is the sample data itself.

The BLS publishes a list of "Frequently Asked Questions" regarding the CES. Number 15 specifically asks and answers:

"What are some of the Limitations of the Data?"

"The Interview and Diary Surveys are sample surveys and are subject to two types of errors, non-sampling and sampling. Non-sampling errors can be attributed to many sources, such as differences in the interpretation of questions, inability or unwillingness of the respondent to provide correct information, mistakes in recording or coding the data obtained, and other errors of collection, response, processing, coverage, and estimation for missing data. THE FULL EXTENT OF NON-SAMPLING ERROR IS UNKNOWN. (All caps added for emphasis) Sampling errors occur because the survey data are collected from a sample and not from the entire population. Tables with coefficients of variation and other reliability statistics are available on request. However, because the statistics are shown at the detailed item level, the tables are extensive."

"CAUTION SHOULD BE USED IN INTERPRETING THE EXPENDITURE DATA, ESPECIALLY WHEN RELATING AVERAGES TO INDIVIDUAL CIRCUMSTANCES. (All caps added for emphasis) The data shown in the published tables are averages for demographic groups of consumer units. Expenditures by individual consumer units may differ from the average even if the characteristics of the group are similar to the individual consumer unit. Income, family size, age of family members, geographic location, and individual tastes and preferences all influence expenditures."

2. PSI's proposal is a conflict of interest.

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 non-custodial parents from meaningful involvement with their children, and overall, misses the reality of what child support should truly be.

Williams clearly drives 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.

The problems with Policy Studies, Inc's Proposed Updated Child Support Schedule are very serious and fatal. None of PSI's data comes from Alabama. PSI's submission must be totally disqualified as a conflict of interest, full of false, incomplete and irrelevant data.

Various family advocacy groups and the National Congress for Fathers and Children have alternative proposals and must be given a meaningful opportunity to present accurate and relevant information and data to Alabama's Child Support Guidelines Update Committee. Operating the Committee by mail is absurd, impractical and impossible.

Submitted by N.C.F.C.

s/_______________________
James R. Blackston
6185 Hwy 195 North
Jasper, Al 35503-3409
205-221-6558

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