Recruitment, Selection, and Evaluation Processes in Signal Hill and Lapd

Recommendations 6

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  LAPD and LA Personnel Interviews: 8 interviews Deputy Chief Bostic Commander Kelepecz Commander Gascon Nancy Genussa (civilian employee, LAPD - recruitment) Thomas Brennan (civilian employee, LAPD- human resources) Lieutenant Mark Hurley Margaret Whalen (Personnel Department) Phyllis Lynes, Gail Thomas (Personnel Dept., Public Safety Personnel Division) Dr. Sheldon Kay, licensed psychologist (Personnel Department, OHSD)
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  SHPD and SH Personnel Interviews: (12 Interviews) a. Chief Pedersen b. Captain Risinger c. Detective Sergeant Peterson d. Lieutenant Brown e. Sergeant Cravens f. Police Officer McCraner (POA President) g. Police Officer Leyn h. Mary Gilmore (SH Personnel Department) i. Police Officer Oldenburg j. Police Officer Lowinger k. Police Officer Chambers l. Dr. Susan Saxe-Clifford (Contract Licensed Psychologist) m. Sgt Reuben Padilla, LAPD Spanish language program
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  External Interviews: (4 interviews) Laura Guglielmo, Office of Administrative and Research Services, City of LA Councilwoman Cindy Miscikowski Kelly Martin, Mayor’s Office Gloria Sosa, Mayor’s Office
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  Benchmark Interviews Lori Lee; California POST Sgt. Trendell Coley, Los Angeles Sheriff’s Department Sgt. Mike Borges, LA Sheriff’s Department Capt. Kim Hogan, New York Police Department Hilda Coronel, City of Miami Police Department
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  Focus Groups Signal Hill experienced officers LAPD FTOs/tenured officers LAPD newer officers
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  Used by BFSO staff to initiate a child support enforcement case on ARS If any of these steps is missed it is likely a child support case won’t be established when appropriate. It is difficult to justify the investment in designing and implementing automated interfaces between LEADER and ARS when the function is not being used. We were provided with documentation describing the extraordinary efforts BFSO staff take in order to have DPSS staff enter data and activate the electronic interface: “A CIN number is the unique Client Identification Number assigned by the LEADER computer system to their clients. This CIN number is used in the LEADER/ARS interface to identify participants when changes/updates are made. It’s important to have the ‘link’ to ensure all updates…are processed. If no ‘link’ exists, ARS will utilize a namesearch program to try and identify the participants and process the updates. This may fail if the name, date of birth, or Social Security number on ARS is different from the information on LEADER.” “If no CIN numbers are not found and no duplicate records are found, an electronic referral has still not been sent to ARS by LEADER. Periodically follow these procedures during the control period. If more than 30 days are past and still no referral has been sent to ARS, notify the Eligibility Worker in DPSS who is assigned to this case…If the Eligibility Worker informs you that the case has been approved [for public aid], ask him/her if she could input the mandatory fields on the ‘Absent Parent Information’ screen so the case will trigger and be sent to ARS via the electronic interface in overnight batch.” (Instructions For Linking CIN Numbers to Participants, BFSO internal memo) In our case file sample, the LEADER Absent Parent Information screen is typically incomplete, even if there is an absent parent, and even if there is a child support case already established by BFSO. This indicates that data about the absent parent was not keyed into LEADER by DPSS staff, and has not been updated in LEADER even after the data is collected by child support enforcement staff and keyed into ARS. Keying information into the LEADER Absent Parent Information screen is the trigger for automatic exchange of data about the absent parent between LEADER and ARS. If this is not done, there is no link established. Of the 30 case sample, there were 16 active child support enforcement cases in ARS. However, in 7 of the 16 cases (43.8 percent) ARS had a record of the non-custodial parent’s Social Security number while LEADER did not. In 1 of the 7 cases, the non-custodial parent’s last name was not the same in LEADER as in ARS. Based on this example, it is possible that even if there is a child support enforcement referral to ARS, potentially 1 in 2 cases will experience errors during data exchange because of a mismatched Social Security number. We did not review mismatched dates of birth. The written instructions to child support enforcement staff show that: • Electronic transmission of data between ARS and LEADER is triggered only when DPSS staff complete the LEADER Absent Parent Information screen • Extraordinary efforts are required by child support enforcement staff to track and monitor on their own, using handwritten notes to themselves, when data about absent parents is keyed into LEADER by DPSS staff • DPSS staff need to be prompted to collect and key into LEADER data about absent parents because they typically do not update screen during initial application. All of these are redundant tasks because BFSO staff perform them while having to rely on receipt of a paper form to collect data about absent parents and to initiate child support enforcement cases. Having to perform these tasks eliminates a major potential benefit of using information technology to automate data exchange about absent parents. Timeliness of DPSS ReferrBaFlSsO to A 1997 audit of the Bureau of Family Support Operations reported: “BFSO experiences difficulty coordinating with other agencies to manage the quality and schedule of data inflows…Welfare case referrals are frequently not sent timely or at a steady stream… “When BFSO does not receive timely or complete case referrals from DPSS backlogs in opening cases can occur. This in turn threatens BFSO’s compliance with State timelines for opening cases. Further, BFSO must expend time and effort to research WCMIS [LEADER] or conduct interviews with the CP to obtain the information… “Planned electronic interfaces with DPSS and case processing changes mandated by welfare reform should improve the timeliness of data and reduce the delays in opening cases. --from 1997 PriceWaterhouse audit of BFSO, Finding F: Getting Quality Data at the Source Many of the problems identified in the 1997 audit regarding timely data flow between DPSS and BFSO still exists. Table 2.2 below shows that in our case file review of 30 cases, the Child Support Questionnaire CA 2.1Q forms in eight cases were dated long after the legally required case referral deadline; 2 days after public aid is approved. In fact the median number of days in excess of the two day requirement was 87 days for these eight cases. Perhaps even more disconcerting, the CA 2.1Q forms in these eight cases were all signed and dated after the auditors submitted to DPSS the list of cases selected for our review, two days before the review was actually conducted. These indicate cases where aid payments have been made for long periods without any child support enforcement. Table 2.2 Dates of Aid Approval and Days Elapsed from Required 2 Day Referral Due Date for Cases with Child Support Questionnaires Dated 4/27/01 Date Actual Days Elapsed Case Date Aid Referral Date of from Due # Approval Due Referral Date 1 4/6/00 4/8/00 4/6/01 0 2 11/24/75 11/25/91 4/27/01 3,441 3 5/1/98 5/3/98 4/27/01 1,090 4 12/1/95 12/3/95 12/4/95 1 5 5/12/00 5/14/00 5/14/00 0 6 11/1/00 11/3/00 4/27/01 175 7 9/16/97 9/18/97 2/19/98 154 8 4/12/88 4/14/88 5/4/88 20 Median # Days 87 In many cases DPSS workers do not collect data about non custodial parents, leaving this task to be performed by BFSO workers. This delayed data collection can have ripple effects in child support enforcement case processing. When DPSS staff fill out a CA 2.1Q form and send the form to co-located BFSO staff for completion, BFSO’s 20 day timeline for case initiation begins. BFSO must open a case if appropriate, or determine that a child support case should not be opened of receipt of the referral. However, if the aid applicant fails to remain for the co-located interview, the clock begins ticking even though the CA 2.1Q is unlikely to have any meaningful data with which to make the determination. Very few cases referred are not appropriate for child support enforcement, therefore BFSO is often pressured to initiate a case. DPSS staff often do not insist on the applicant completing the CA 2.1Q secure in the knowledge that BFSO staff will do so. This reduces the likelihood the aid applicant will not make a claim of Good Cause (legitimate or otherwise) until they are interviewed by co-located BFSO staff. However, BFSO cannot accept the claim. They must cease all case processing and refer the applicant back to DPSS staff to determine if Good Cause exists and begin the 20-day clock for determination of the Good Cause claim. After a determination on the claim is made, then the applicant must begin the child support enforcement case initiation process over again. Delays in data collection and case initiation impair the quality of data collected because as the applicant’s financial and household situation changes, data which has been collected becomes outdated. Poor quality data further impairs the chances of successful child support case initiation and collections. RECOMMENDATIONS Based on the above findings, it is recommended that the Director of the Department of Public Social Services: 2.1 Reinstate a management system for measuring the extent to which child support related data is completely collected by Eligibility Workers and referred timely to the Bureau of Family Support Operations, to be reviewed on a regular basis such as monthly by upper management and all District Directors; 2.2 Develop regularly produced LEADER generated reports for management review and analysis, detailing all aid applications, those that should be referred to the Bureau of Family Support Operations according to aid unit characteristics, and the number actually referred, by District Office; 2.3 Develop an ongoing program of auditing samples of case files through LEADER to determine that all cases that should be referred to the Bureau of Family Support Operations are being referred and take corrective actions if they are not; 2.4 Use new LEADER generated management reports to regularly compare percentage of total applications, data collection completeness rates and the timeliness of case referrals to the Bureau of Family Support Operations, by District Office, with the goal of determining and replicating practices that achieve the highest rates of data collection completeness and timely referrals; 2.5 Continue with current efforts to complete all LEADER screens upon application or no later than first annual review. Costs and Benefits Implementation of the above recommendations would require staff time to develop new LEADER generated reports but should not require any new direct costs for hardware or software as LEADER was designed to allow for custom made management reports. Additional staff training will not incur any new direct costs but would also require staff time. The benefits of the above recommendations would include additional management oversight and accountability for DPSS’s child support data collection efforts and timely referrals to BFSO. The improved accountability and management oversight of this function should produce improved performance in these areas and a higher rate of successful child support cases. Activating LEADER’s electronic interface with BFSO’s information system should streamline the case referral process and improve the accuracy and usefulness of both systems. 3. Need For Process Controls on Case Sanctions • A review of a sample of cases in which BFSO requested imposition of sanctions on aid applicants for non-cooperation indicates that DPSS does not follow up on such requests in accordance with regulation and procedures. In 42 percent of a sample of BFSO sanction requests for non-cooperation, sanctions were not imposed nor was there a record of a Good Cause determination by DPSS that would preclude imposition of the sanction. Neither DPSS or BFSO can provide evidence that all sanctions are being imposed when appropriate or that the required steps are taken by DPSS to determine Good Cause which can exempt an applicant from cooperation. • It appears that some aid applicants who do not cooperate with child support enforcement may not bear a sanction for failure to cooperate. If the sample reviewed is representative, County aid payments could be as much as $7.2 million more than they should be a result of not imposing sanctions on non-cooperative aid applicants and recipients. • Organizations which are mutually dependent for proper and timely case processing must have controls over their case transactions to provide accountability and assurance that all necessary transactions are made, that legally mandated timelines are met, and allow for auditing and monitoring staff performance. No such controls over sanction requests and outcomes appear to be in place at DPSS leaving management with little ability to monitor and control these activities. • Data mismatches were found between LEADER and BFSO’s information system in 36 percent of the cases reviewed. Such mismatches could result in failure of electronic communications between the two systems or voiding of cases. The probability of data mismatches is increased by redundant data entry that now takes place due to the absence of electronic interfaces between the two systems. Failure to Cooperate and Good Cause Exemption As described previously in this report, public aid applicants are required by law to cooperate with the child support investigation process if one or more of the applicant’s children has a non- custodial parent. Cooperation is defined as follows: • Applicant must provide all relevant information about identity and whereabouts of non-custodial parent • Provision of complete forms • Appear at BFSO as scheduled • Submit to genetic testing of paternity • Serve as witness in court • Forward any direct payments received from non-custodial parent The cooperation requirement can be waived for Good Cause such as a threat to self or the children as a result of cooperating, court proceedings being underway for adoption of the children, children conceived as a result of rape or incest, or cooperation not being in the best interests of the children. Documentation of non-cooperation and Good Cause determinations are required on standardized forms which are to be prepared by DPSS staff and included in case files. If BFSO staff determine that an applicant is not cooperating, they are required to send a Two-Way Gram and the DA-594 form to DPSS requesting that a sanction be imposed on the applicant or recipient. Before DPSS may impose a sanction, State law and regulations require DPSS to ascertain whether the applicant has a legitimate reason, or Good Cause, justifying non-cooperation (California Welfare & Institutions Code §11477.02 and California Department of Social Services Manual §82-510.4). The actions take by DPSS staff in response to sanction requests from BFSO are to be recorded on a PA 112 form. Good Cause is to be verified through sources such as the following, to be documented on a CA 51 form: • Legal or medical documents such as birth certificates • Court documents • Statement of adoption agency • Records of law enforcement, court, government or other competent professionals • Sworn statements made under penalty of perjury Exhibit 3.1 shows the steps involved in imposing sanctions. If BFSO staff request a sanction for non-cooperation, there are only three possible resolutions: 1. DPSS staff follow-up with the applicant who continues to be non-cooperative and sanctions are imposed (child support enforcement case proceeds) 2. DPSS staff follow-up with the applicant who subsequently cooperates with child support enforcement efforts (child support enforcement case proceeds) 3. DPSS staff follow-up with the applicant who substantiates a claim of Good Cause (child support enforcement case is closed) Exhibit 3.1 Flowchart for Imposing Sanctions BFSO Sanctions Requested DPSS Has Documented Request for Sanctions BFSO BFSO Does Not Reports Subsequent Report Subsequent Cooperation Cooperation DPSS DPSS Has Documented Has No Documented Follow-up Follow-up DPSS DPSS Confirms No Substantiates Good Good Cause and No Cause Claim Cooperation DPSS Does Not DPSS Does Impose Sanctions on Impose Sanctions on LEADER LEADER Sanctions Not Sanctions Operative Operative on LEADER on LEADER All three of these scenarios are supposed to be documented on required forms and included in the case file. The sanction for non-cooperation is as follows according to State law: Sanction for Non-Cooperation—Applicants who do not cooperate with child support enforcement are subject to a sanction of 25% of their aid payment. BFSO notifies DPSS the applicant is not cooperating. DPSS must follow-up on the request to assure no Good Cause exists and then impose the sanction by reducing the aid payment by 25%. Because sanctions are a case transaction initiated by BFSO instead of DPSS, unlike child support enforcement referrals, and because sanctions represent an important element of the County’s child support enforcement program, we reviewed the sanctions process through a second sample of cases. Cases were selected for this second sample from a list provided by BFSO of cases for which sanctions were requested in March 2001. We randomly selected 30 of these cases managed at DPSS Southwest Family office. DPSS provided us with 28 of the 30 files we requested. Two of the files were unavailable and not provided. A summary of the results of this case review are presented in Table 3.1 Table 3.1 Summary of Results of Case File Review Cases Referred to DPSS by BFSO for Sanctions to be Imposed Total sample 30 # case files deleted from sample 2 Subtotal: # cases reviewed 28 No record of BFSO sanction request at DPSS 4 Subtotal: # cases with record of BFSO request at DPSS 24 # cases with sanctions imposed: # cases no documentation of DPSS follow up 10 # cases with documentation of DPSS follow up 4 Total # cases with sanctions imposed 14 # cases sanctions not imposed: # cases no documentation of DPSS follow up 10 # cases with documentation of DPSS follow up 0 Total # cases sanctions not imposed 10 Of the 28 reviewed cases out of the 30 requested, four did not have a record of BFSO’s sanction request for non-cooperation. This means that DPSS does not have a record of BFSO’s request in 4 of the 28 case files (14%). As a result, no DPSS follow up action occurred in response to the BFSO request and assumedly the applicants received full aid even though they were reported as non-cooperative by BFSO. Of the 28 case files we reviewed, only 4 had evidence of full compliance regarding sanctions for failure to cooperate including: • Two-Way Gram indicating non-cooperation • DA 594 form requesting sanctions (and none showing subsequent cooperation) • PA 112 form indicating follow-up and outcome • LEADER Sanctions screen indicating sanctions imposed In the 24 sample cases where DPSS did have a record of BFSO’s sanction request, a Two-Way Gram form was found in each case file reporting that the applicant/recipient had not cooperated with child support enforcement as were companion DA 594 forms requesting DPSS to impose sanctions for non-cooperation. Of the 24 cases, only 4 case files (17 percent) had a PA 112 form documenting DPSS staff follow-up on the BFSO request. Twenty of the cases (83 percent) had no DPSS documentation of follow up. Excluding two cases where subsequent cooperation was documented by BFSO (and not DPSS), there were 18 cases without any documentation of follow up. Of those, nine had sanctions imposed anyway according to LEADER and nine did not. Of the two cases where cooperation was subsequently obtained, one had a sanction appropriately imposed and recorded on LEADER and removed when the applicant subsequently cooperated. The other case never had a sanction recorded on the LEADER Sanction screen. Since the sanction is a reduction in the aid payment, the sanction must appear on the Sanctions screen in order for the sanction to be activated. Follow-up consists of contact with the aid applicant, possibly including a personal interview to assure the applicant understands the ramifications of failure to cooperate and whether or not Good Cause exists. The absence of follow up violates CDSS Manual §82-510.4 that requires DPSS to determine Good Cause if BFSO finds failure to cooperate. All four of the cases with evidence of DPSS follow-up had sanctions recorded on the LEADER Sanctions screen. In the sample, none of the 28 case files had CA 51 forms or other documentation indicating the aid applicants had made a claim of Good Cause, or had a Good Cause claim reviewed, substantiated, or denied. Accordingly, all of the applicants in the sample should have been sanctioned for non-cooperation. This confirms staff reports that Good Cause claims are relatively rare and that this exemption is rarely used. Four cases where sanctions were imposed by DPSS suffered from another problem and the sanctions were never actually activated. In these four cases, the Sanction End Date on the LEADER is earlier than the Start Date. For example, one case had sanctions imposed with a Start date of 5/1/01 and End Date of 3/1/01. The sanction would never operate because on 5/1/01 when LEADER tries to activate the sanction, it simultaneously ends the sanction because the End Date of 3/1/01 has already past. We have evidence of a failure in LEADER’s functionality in which the system automatically terminates sanctions. This is confirmed by 4 of 14 sanctions (29%) which have been rendered inoperative in this manner. If the four cases of inoperative sanctions are added to the 9 cases where sanctions were requested but never imposed and were not waived for Good Cause, DPSS performance in this area worsens. In this analysis, 13 of 22 cases (59%) sanctions were not imposed where they should have been. Three of every five aid applicants who does not cooperate with child support enforcement does not face sanction. If the other four cases in which DPSS has no record of BFSO’s request to impose sanctions are added back, the analysis worsens even further to 17 of 28 cases (61%) where sanctions were not imposed where they should have been. Potential Risk The potential cost of failure to impose sanctions where they should can become immense. Not only does the County make aid payments that are too high, it makes high payments on too many cases. It reduces the incentive to cooperate with child support enforcement and loses opportunities to recoup aid expenditures. • 9 cases where sanctions were not imposed but should have been • 4 cases where sanctions were imposed but not operative • 4 cases where DPSS had no documented request for sanctions • 17 of 28 cases (61%) we presume should have had sanctions imposed but didn’t • 7,900 requests for sanctions from BFSO annually x 61% = 4,819 cases • 4,819 cases x $500 monthly aid payment11 x 12 months x 25% sanction = $7,228,500/year additional aid costs In the sample, there was a mismatch of data between BFSO and DPSS on the non-custodial parent name in 10 of 28 cases (36%). A mismatch of even one letter is enough to cause the automated link between LEADER and ARS to fail. In addition, a mistake of even one letter in a name is enough to render the court documents generated by ARS legally void. This error impairs BFSO ability to initiate child support enforcement cases within timeline. We did not review mismatches of Social Security number or date of birth in these cases. Mismatches in these data elements would cause similar failure. In more than one of three cases, there is reasonable likelihood that automated data exchange will fail due to one mistaken keystroke. This likelihood would be reduced if there was no need to reenter data into ARS which has already been keyed into LEADER. This requires activation of electronic interfaces between the two systems. If such interfaces were established, redundant data entry and the increased risk of data entry mistakes could be reduced. When Not To Cooperate Even quality data will not improve effectiveness of child support enforcement when it is a rather simple matter to appear to cooperate with child support enforcement by providing information indicating the absent parent is an alien who resides abroad. This set of circumstances is frequent and typically results in opening a child support enforcement case that is subsequently closed because BFSO cannot locate the non-custodial parent. The County’s child support enforcement effort is reduced in effectiveness when there is no disincentive for aid applicants for failing to cooperate. But it is also less effective when parents are not rewarded for cooperating. California has established a $50 pass-through which is given to aid recipients who cooperate, if the other parent of their children makes child support payments. The $50 does not affect eligibility determination and benefits calculation for public 11 CalWORKs monthly aid payment amounts vary depending on household composition and other sources of income. A typical payment for a mother and one child is approximately $600 per month. A slightly lower amount, $500, was used for this calculation. aid (it does affect food stamps.) The monthly pass-through is meant to overcome resistance to cooperating with child support enforcement. However, it may be fiscally rational to accept a 25% sanction in order to protect a non-custodial parent, who may provide greater value in unreported cash or in-kind support such as diapers, from County efforts to enforce child support obligations. Even though eligibility for public aid requires aid recipients to forward any direct child support payments to the County, applicants may choose not to keep them if they are worth more than the sanction. Table 3.2 below shows an example of where a choice to not cooperate with child support enforcement is rational. In the first column, a custodial parent is keeping direct support from the non-custodial parent in addition to her aid payment. Because she has elected not to cooperate with child support enforcement, and keep the child support given to her directly, her aid payment is reduced by 25% sanction. If she elects to cooperate with child support enforcement, her aid payment is not sanctioned, but child support from the non-custodial parent is assigned to the County to recoup the aid payment, and she does not keep it. Electing to cooperate removes the sanction, but that is not enough to compensate her for the loss of the child support she had been receiving directly. Even with the sanction, the custodial parent is better off not cooperating with child support enforcement. In this case, it is rational not to cooperate with child support enforcement. The custodial parent receives more than otherwise, the non-custodial parent likely pays less than otherwise. The only loser is the County, which makes the aid payment and does not recoup the cost through child support enforcement. Table 3.2 Example of Rational Choice to Not Cooperate with Child Support Enforcement Failure to Cooperate Cooperation DPSS Aid Payment $400.00 $400.00 Direct Unreported Child Support from Non-Custodial Parent 200.00 0.00 Subtotal $600.00 $400.00 $50 Pass-Through from Child Support Collection 0.00 50.00 25% Sanction For Failure to Cooperate -100.00 0.00 Total $500.00 $450.00 RECOMMENDATIONS Based on the above findings, it is recommended that the Director of the Department of Public Social Services: 3.1 Investigate possibility of phasing out paper forms documenting child support related activity to be replaced by entering the same data on LEADER and printing out hard copies thus eliminating redundant data entry on LEADER and ARS; 3.2 Add a logic check in the LEADER Sanctions screen to eliminate the possibility of sanction end dates preceding start dates and thus canceling sanctions imposed for non- cooperation. 3.3 Work with the Bureau of Family Support Operations to jointly develop control lists and statistical reports that are based on the same data base and reconcile to one another tracking the status of cases transactions between the two agencies; 3.4 Begin maintaining a LEADER generated control list of all cases for which sanctions have been requested by BFSO; 3.5 Begin maintaining a LEADER generated control list of follow up actions taken by Eligibility Workers in response to BFSO requests for sanctions and the outcomes of each request: Cooperation obtained; Non-cooperative but with Good Cause; and Non- cooperative and sanctioned; 3.6 Develop an ongoing program of auditing samples of case files through LEADER to determine that all cases that should be sanctioned at the request of the Bureau of Family Support Operations are indeed being sanctioned or Good Cause is documented and take corrective actions when there are exceptions; 3.7 Begin preparing a summary annual report on child support cases for the Board of Supervisors reporting: number of aid applications; number of referrals to the Bureau of Family Support Operations; number of cases open; percentage of open cases on which there has ever been a child support collection; number of cases determined non- cooperative but with Good Cause; number of non-cooperative cases without Good Cause; and number of cases sanctioned. Costs and Benefits There would be no new direct costs to implement the above recommendations. As with the recommendations in Section 2, staff time would be required to design new management reports and audit functions in LEADER and making adjustments to the LEADER Sanctions screen. The phasing out of paper forms to be replaced by LEADER generated forms and documents could reduce some printing and duplicating costs and will save staff time by ending redundant data entry. Implementation of the above recommendations will improve accountability and management oversight over the process of imposing sanctions. By ensuring that DPSS staff follows up on all sanction requests and that sanctions are imposed in all appropriate cases, County aid payments for CalWORKs recipients could be reduced by as much as an estimated $7.2 million per year. Mailing Addresses and Locations To be # Form Authority/Source Prepared by sent Purpose to: I CA 2.1 DPSS Includes check box for Agreement with assigning child support rights and medical support rights. Should be in paper file. II CA 2.1Q DPSS DA Support Questionnaire should list NCP name, DOB, work place, SSN, etc. Should also be in file when changes have occurred as recorded during redetermination. All shaded questions must be answered or marked unknown. Not sent if good cause determined. Copies of birth documents should accompany. III CA 51 Administrative Directive DPSS DA Prepared by DPSS and should 3880 document good cause. This is to be forwarded to DA IV DA 594-G Administrative Directive DA DPSS DA form indicating that 3880 applicant/recipient failed to cooperate after the CA 2.1Q referral from DPSS. V PA 112 Administrative Directive DPSS DA Reports “EW Report on 3880 Client’s failure to Cooperate” in response to receipt of a DA 594-G from the DA. To be sent even if good cause is determined. Above documents are available for download as Acrobat Files. File size is 4.3 megabytes and may take some time to download. DOWNLOAD FILES