Impact of Adding Revenue Canada Databases Under FOAEA—Part 1 Tracing For Locating Persons
Final Report

2004-FCY-10E

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4.0   RESEARCH DESIGN, METHODOLOGIES AND LIMITATIONS

4.1   Overview of Components

The overall objective of this research is to assess the impact and effectiveness of the addition of Canada Customs and Revenue Agency (CCRA) databases to processes used in tracking payors owing maintenance arrears and in identifying and locating the employers of payors against whom wage attachments (garnishees) might be applied.

The research design is comprised of two components:

• Component I—determines the approximate percentage of cases over a period of time that require FOAEA trace searches within the federal-provincial tracing process. This provides a view of the proportional "significance" of the federal trace information.
• Component II—assesses the quality, currency, impact and effectiveness of the CCRA data on the tracing of payors and the location of employers to whom attachments (garnishees) might apply.

4.2   DESCRIPTION OF COMPONENT I

Component I was designed to generate the following specific data:

• The percentage of new and continuing cases enrolled in FMEP that are sent to FAMS for search during a specified period (in this case, January to June 1999);
• The percentage of new and continuing cases sent from FAMS to the FOAEA Unit for federal tracing during this time period; and
• The approximate overall percentage of cases arising in FMEP that require a federal search.

To arrive at the percentages identified above the following data was selected, aggregated, reviewed and compared:

• The number and percentages of new and continuing cases enrolled at FMEP between January and June 1999. Because all FMEP cases may potentially require a trace, both new and continuing enrolments within FMEP were included in the baseline population;
• The number and percentage of the cases (out of total FMEP enrolment numbers) that were sent from FMEP to FAMS for a FAMS search during this time. These do not include cases sent to FAMS for regular, automatic searches; and
• The number and percentage of FAMS cases (originating at FMEP) sent to the FOAEA Unit for further trace data between January and June 1999.

4.3   DESCRIPTION OF COMPONENT II

4.3.1   Objectives

Component II is the primary component of this research. The main activity of this component was to identify and track a random sample of FMEP cases that have received FOAEA trace results in order to describe:

• Recipient, client and case characteristics;
• The type, completeness, timeliness, quality and source of HRDC and CCRA data returned by the FOAEA Unit;
• Whether the data was utilized and/or resulted in the successful location of payors or employers;
• Whether any type of payments were made as a result of FOAEA results; and
• Whether the addition of CCRA data led to a higher number of completed traces or increased payments.

4.3.2   Sample Size and Selection

Three hundred and fifteen cases were randomly selected from a population of cases sent for trace by FAMS with data returns from the FOAEA Unit in the period between June and December 1999. These cases were sent by FAMS to the FOAEA Unit between June 1998 and December 1999 (see Table 1).

A lengthy time period between trace request and trace return was required in order to ensure that all tracing processes would be completed at the time of data analysis. It was estimated that the period between trace request and receipt would average between five and seven months. A generous time period after the receipt of trace results was also required in order to allow enough time for the review of trace results, the application of enforcement actions (e.g. issuance of a Notice of Attachment) and the possible receipt of payments.

The original sample size was estimated at 250 cases to be taken from a population base of 1,585 cases. However, because of the manner in which the population was drawn, the base for the study was larger than first anticipated (3,870). In addition, when the files were reviewed it was found that almost one quarter of the FMEP files were sent to FAMS in mid to late 1998, a period when there were some technical slow downs in the data transfer between FAMS and the FOAEA Unit. As a result, a further 65 cases were randomly sampled in order to increase the proportion of 1999 cases in the study and to increase the validity of the results.

Given a total population size of 3,870, a confidence level of 95 percent and a hypothesized level of FOAEA trace results of 30 percent, a minimum sample size of 298 was required for the study.

Seventy-eight percent of cases forwarded to the FOAEA Unit for tracing were sent in 1999, with the largest proportion (44 percent) transmitted in the last six months of that year.

Table 1   Period of trace request from FAMS to the FOAEA

Period when trace request made by FAMS to the FOAEA	Total
June 1998—December 31, 1998	67 (21%)
January 1, 1999—June 30, 1999	108 (34%)
July 1, 1999—December 31, 1999	140 (44%)
TOTAL	315

4.3.3   Methodology

A case analysis and trace tracking process was developed to collect recipient, payor and case characteristics and to assess trace history, duration, results, application and effectiveness.

A comprehensive Case Data Collection Form was developed on which to enter results from FMEP, FAMS and the FOAEA Unit prior to their being entered onto an electronic data management system (The Survey System) for aggregation and analysis.

FMEP, FAMS and FOAEA electronic data management systems were reviewed in order to identify the data elements required for the study. The location of the data elements, their descriptors and access points were defined during the Evaluation Design Phase of this project (see Table 2).

Data from each electronic system (FMEP, FAMS and FOAEA) was entered on the Case Data Collection form (see Appendix), and was cross-checked and verified. Trace quality, timeliness and applicability were determined by cross-referencing and analyzing the results.

4.4   Design Phase and Pilot Testing

4.4.1   Purpose of Design and Pilot Phase

Because of the number of data sources and complexity of the data collection process, a Pilot Phase was implemented in order to develop, clarify or refine:

• The most efficient methods of determining and drawing the research sample;
• The source, scope, yield and relevance of data elements;
• Data field definitions;
• Alternative and "best" sources of data;
• Optimal pathways to data access (in FAMS, FMEP); and
• Cross-validation mechanisms for data currency dates.

Table 2   Description of data elements

Data category	Description of data		Data sources
Case ID numbers file linkages	Code numbers identifying cases in FMEP, FAMS and FOAEA systems		FAMS general case screen
Search data: requests and receipts	Search request for: Assets Employment Location		FAMS action history
Case flow and interval data	Date FMEP enrollment Date search request to FAMS FAMS case closed Date legal application	Date affidavit Date Federal Closed Date FMEP search results received	FMEP case screen FMEP enquiry screen FAMS general case screen FOAEA data FAMS external search
Trace characteristics History Case group	Previous FAMS and federal trace requests (dates, type of search, current status) Does not include automatic trace requests from FMEP-FAMS Case group / jurisdiction		FMEP case screen FMEP tracing screen
Financial data Payment requirements and status	Periodic payment times and amounts Amount arrears (date) Amount paid (date) Date last payment Date first payment	Source last payment Regularity of payment –previous 12 months FOAEA (generated payments) date and amount of last payment	FMEP payment status FMEP schedule summary
Payor data	Birth date GAIN status Most recent GAIN duration SIN No.	Gender Probable location Probable employer Occupation Most recent address	FMEP screen FMEP address log FAMS employer screen
Maintenance Order	Type of order (child/spouse) Court level When issued active	Expiry date Number of children on order	FMEP Order Schedule
Recipient and child data	Birth date Date GAIN assignment Gender Probable location	Other file history Number of children Gender of children Birth dates	FMEP recipient screen FMEP assignment screen FAMS children
Trace results Location Employer	Source department Date info sent Date address active Level of completeness of trace result	Relation to existing data (date received and active) Whether data applied Verification means Whether used for payment	FMEP running record FOAEA records FAMS external search
Past enforcement actions	Type of enforcement (NOA, NOFI, NOFG) Federal license denials SC committal hearings	Credit Bureau Driver's license Reg – Land 26.1	FMEP Notice of Attachment FMEP Enforcement Activity Summary
Employer data (historical)	Name of business Most recent addresses Date last known	Date entered Date employed	FMEP employer history FAMS employer

During the pilot phase, 20 cases that required and received FOAEA trace data were selected from FAMS records and tracked through the FMEP, FAMS and FOAEA systems.

Six drafts of the Client Data Collection Form were developed, "pre-tested" and revised during the pilot phase, taking into account case characteristics, data entry requirements, data limitations and program staff feedback. (See Appendix: Case Data Collection Form.)

4.5   Research Issues and Limitations

Several issues related to data definition completeness, accessibility, reliability and comparability affected this research. These are summarized below in relation to their impacts on the data collection and analysis process.

4.5.1   Difficulty in Determining Definitions of Data Fields

The lack of comprehensive data dictionaries (FMEP, FAMS and FOAEA) made the interpretation of some fields difficult. A selection of fields which required definition or clarification is presented in Table 3.

4.5.2   Limitations of Data Fields

Some FMEP data fields and screens within FMEP were not well maintained with the most current enforcement status data, trace history or address related information. This was particularly true in the following four areas:

• Enforcement data and enforcement screen—history of enforcement actions taken (e.g. Notices of Attachment) and active dates;
• Tracing history data and screen—a history of traces requested and results received with active and termination dates;
• Employer address logs—history of previous employer searches, including most active date believed to be correct at the time of entry and the date entered on the system; and
• Payor address logs—history of payor address searches, including the most active date believed to be correct at the time of entry and the date entered on the system.

Enforcement data was sometimes missing and the status of enforcement actions unclear. This caused problems particularly if it was necessary to establish the status or currency of a Notice of Attachment (NOA) to determine whether an accurate employer contact had been made.

Trace history data was also frequently incomplete and/or missing. There were many instances where the specific FOAEA trace being addressed by this research was not included in the trace history record.

Although enforcement and tracing data are reported in this document, complete accuracy cannot be ensured.

Table 3   Selected field definitions

Field	Data description / clarification
Case data requested and received (FAMS)	Prior to the research implementation phase, FAMS identified the specific data needed from the FOAEA Unit in its trace request. However, some of these categories were aggregated by the time of the research implementation phase, making analysis difficult. In any case, the FOAEA Unit does not apply trace request parameters but carries out employer and payor address searches in all cases. A limited analysis was carried out where requests for data could be identified.
Date of FMEP request	Date FMEP sent trace search request to FAMS.
Prov. closed / fed. initiated	Date FAMS search closed/ date FAMS notified FMEP federal search will be undertaken. Does not signify exact date search request sent to the FOAEA Unit.
App. legal date	Date on initial FAMS application for trace results to the FOAEA Unit. Province has 30 days to "activate" the application with an affidavit.
Receive aff. date	Certifies affidavit online authorizing FOAEA search request.
Federal Closed	Date at which FAMS "picks up" first trace results from the FOAEA Unit. This is not necessarily the precise date when results are sent or when they arrive. Represents date of only first trace results. Other addresses related to the same trace request may be sent after the Federal Closed date.
Payor occupation	General type of occupation only—specific occupation may not be available.
Payor address	May be "last known" if payor in process of being traced. May not be available on FMEP records.
Employer name and address	May be "last known" if in process of being traced. May not be available on FMEP records.
REMO Data	Defined by case group: RDI—REMO, payor lives in B.C. RDO—REMO, payor lives outside of B.C. Vol—both payor and recipient live in B.C. DEEM court sent file to FMEP for enrollment (term no longer in use).
Enforcement actions (the following actions will be recorded)	NOFI—garnishee of federal funds. NOFG—garnishee of federal salaries. NOA—Notice of Attachment to local companies. DL—Driver's License. License denial—federal license denial (marine, passport, aviation). SC—committal hearing. Reg. Land—lien against land and house. Credit Bureau. 26.1—action against personal property.
Arrears payments made	Both date sensitive. Arrears are current on the date the case was reviewed. Arrears include all federal fees owed.
Maintenance Order payment requirements	Maintenance Order can consist of lump sums, process fees and periodic, regular payments. Only basic periodic payment requirements and outstanding balance were tracked and calculated.
Payment source	Source of payments does not specifically identify whether payment is voluntary or required. Payment sources include: Cheque. Money order. Post-dated cheque. TFC—transfer funds on behalf of recipient. Dir—direct payment. Fed. Payment—unclear as to source.
Regularity of payments	Derived categories indicate regularity of payments over past 12 months. No payments. Very occasional (several times over a period of years). Occasional (2 to 5 times over a 12-month period). Somewhat regular (6 times over a 12-month period). Regular (payments match or are close to requirements).
Previous trace history	Includes all previous trace requests excluding withdrawn and automatic searches. Cpte—completed. WD—withdrawn. Data on all traces requested by FMEP is not entered automatically and does not appear to include all trace requests.
FOAEA date sent	Not clarified. May be date when HRDC and CCRA send trace results to Department of Justice (FOAEA Unit) for transmission to FAMS.
Source dept.	Human Resources Development Canada (HRDC). Canada Customs and Revenue Agency (CCRA).

Coding of address element

Field	Data description / clarification
- Complete	All address elements included with or without postal code.
- Incomplete	Some address elements, but insufficient for a trace (e.g. postal code).
- Entered dates	Date when address entered on FAMS or FMEP system by staff.
- Date active	Last known date when debtor/employer at this address (according to records, search or other information).

Of more consequence to this study was the lack of consistent, complete and up-to-date data in the FMEP employer and payor address logs (both fields and screens). These fields were expected to include a list of recent trace results (employer addresses or payor residential addresses), dates that these addresses were last considered to be active, and dates when the search results were entered into the FMEP system.

Accuracy of these fields was critical to this research because the data should have enabled the researchers to compare and assess the quality, currency and value of FOAEA results with that of existing data on the FMEP database (derived from FAMS and FMEP searches). However, data was frequently missing from these fields. The researchers found many instances where FOAEA trace results had been received, but were not entered, and other situations where fields were empty. They also found instances where an active date was entered, but not linked with any data.

In all these cases, it was necessary to "reconstruct" parts of the employer and payor address logs through a review of the FMEP running record. This enabled the researchers to assess the currency of FOAEA trace results.

4.5.3   Reliance on the Running Record

Because of the lack of information on trace results and trace histories in some key fields, it was necessary to reconstruct or confirm data in the running record. The running record is a narrative of case related actions and results completed by family maintenance staff in an abbreviated form. It contains the most complete picture of each case and tracing efforts, but it is subjective, not organized by category or key word, can be very lengthy, and is difficult for someone not involved in the case to interpret.

In order to assess and validate trace results, the running record was reviewed in each case. This contributed to the length of the review research process and difficulties in accurately determining outcomes.

4.5.4   Lack of Clear Information on Trace Outcome or Payments

There was no specific data field within the FMEP database to validate the source of the trace information or whether trace information had been received, reviewed or applied. It was also difficult to ascertain whether a specific trace had been successful, or whether the trace had resulted in payor or employer contact or payment. This information had to be inferred from other data and the data analyzed to establish cause and effect. For example, it was sometimes difficult to assess whether a Notice of Attachment (NOA) was issued as a result of a federal trace or from some other information. Similarly, it was not easy to determine whether payments made were the result of a NOA or another action.

The study attempted to determine the source of any maintenance payments made and whether these were voluntary or compulsory. Again, this was difficult to distinguish. Type of payment (e.g. cheque) was broadly defined and could include a variety of sources, including direct payment from a payor or from a company garnishee (Table 18).

4.5.5   Difficulty in Assessing FMEP Review and Application of Data

In most cases, there was a minimum period of five to seven months between the FMEP search and request and the receipt of FOAEA data by FAMS. However, it was sometimes difficult to establish if and when FMEP staff had reviewed trace results after they had been sent by FOAEA via FAMS. In most cases, this was ascertained through a review of the running record. However, in some cases it appeared that there were lengthy delays before the FOAEA data was assessed and/or applied. In a small number of cases involving employer searches, data from the FOAEA Unit appeared to be correct and would likely have resulted in a NOA if the trace information had been reviewed immediately by FMEP.

4.5.6   Duplication of Data

Some of the data sent by the FOAEA Unit was incomplete and duplicative. This had implications for the overall quality of and response to the data. Inconsistencies were also found in the data sent and data entered into the FAMS system. This applied in relation to "postal code only data." In some cases, the FOAEA Unit sent several postal codes to FAMS, but with a range of active dates. However, the FAMS electronic system retained only the first postal code received even if subsequent data was more currently dated. Because postal code data is likely to be of limited value it is doubtful whether this filtering had negative impacts. Even so, all trace partners should clarify any automatic filtering. If filtering is applied, it should eliminate all but the most recently active information, even if the information is incomplete.

4.5.7   Lack of Precise Information on Trace Process Intervals and Applications

The trace request and return process, review and application of trace results and the triggering of enforcement processes are carried out in a series of stages. One of the objectives of this research was to ascertain time intervals between tracing stages. This was made difficult for the following reasons:

• No clear FOAEA "send" date could be identified;
• The "Federal Closed" date is identified in the FAMS system as the time when the FOAEA trace results are received. However, this date often reflects the point at which FAMS search officers retrieve data from the FOAEA system, not specifically the time when the data is actually sent or arrives. Sometimes there may be a lag between when the FOAEA Unit sends the trace results and their retrieval (recorded) by FAMS; and
• FMEP does not note the date when FOAEA data is received, or more importantly, when its staff review the trace results. Because FOAEA data is sent to FMEP automatically by FAMS, the "Federal Closed" date was estimated as being approximately the same date as FMEP receipt.

4.5.8   The Difficulty of Determining the "Life Span" of Trace Data

The maintenance tracing process is complex and lengthy and operates in a dynamic and changing environment. FOAEA trace results comprise only a small part of the total amount of payor residential and employer address information that is available. They also can be affected by other data such as new information from the recipient or FAMS at any time. Even in cases where FOAEA data has been successful in determining the location of an employer or payor, it is impossible to say how long this data will remain accurate or current.

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