P&P August 2015

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many projects we built under the ACF Interoperability Initiative was focused on just this issue. Called the ACF Confidentiality Toolkit, 6 the product examined six human service programs and each one’s rules for confidenti- ality and appropriate data sharing. In building it, we discovered a number of fascinating misperceptions about data sharing. One key finding was that most states believed the federal data- sharing rules for the TANF, child care, and LIHEAP programs were still in place. We discovered, on the contrary, that only the Federal Privacy Act was still in force after welfare reform in 1996 block granted a number of our programs. We learned instead that states had, over the years before 1996, embedded the previous data privacy rules for our human service programs into state statutes and regulations. But with welfare reform, those federal rules no longer applied. States were now unknowingly stuck with privacy rules that they were free to modify almost in their entirety to facilitate improved service delivery. Who knew? We do, now. But data sharing and the confiden- tiality of client data are but some of many issues that states wanting to modernize and innovate in the human service space must navigate. And still, the opportunities have never been greater. I am often asked where, with the remaining 30 months until the A-87 exception expires on December 31, 2018, should states start? One place is infrastructure. Have Medicaid and their 90 percent funding acquired infrastructure tools and solutions such as an Enterprise Service Bus; a kind of technology backbone that allows diverse systems to communi- cate and share services like online application, identity authentication, and messaging services. Another is data warehousing, and with it, data analytics. These tools can propel state human service departments to begin taking the pulse of their services delivery across the breadth of all of their programs right down to the types and quantities of services being

provided and their efficacy. But just as important, these tools can allow states to understand where their biggest bang for the buck lies when dealing with streamlined service delivery. Yes, the data sharing and confidentiality rules surrounding client data must be addressed, but the tools to make that process less intimidating exist today. I will argue that all Americans, including, obviously, our taxpayers, but also our human service case- workers, our program management and executive leadership, advo- cates, and most clearly, our clients, demand greater accountability. But that accountability is not just about issues of program integrity, reduced error rates, and fraud prevention. It is also about making sure that the most vulnerable of our citizens can rely on their government for the assistance promised to them; assistance that is delivered in a cost-effective, efficient, and personalized manner. As we cel- ebrate the 50th anniversary of the War on Poverty, government must continue to innovate, continue to improve how we deliver the services that can best impact our citizens’ lives for the better. Upgrading our automated systems is one place I will argue we can no longer afford to ignore. Prior to his retirement from the federal civil service in May, Joseph W. Bodmer was a senior information technology executive at the Administration for Children and Families and the Office of Child Support Enforcement. Reference Notes 1. See http://www.acf.hhs.gov/programs/ css/tribal-systems 2. See http://www.acf.hhs.gov/about/ interoperability 3. See http://www.ecfr.gov/cgi-bin/text-idx?S ID=94d704978327cf918a40f8a923a2941 8&node=pt2.1.200&rgn=div5 4. See http://www.acf.hhs.gov/cost-allocation 5. See http://www.acf.hhs. gov/programs/css/resource/ cost-allocation-methodologies-cam-toolkit 6. See http://www.acf.hhs.gov/about/ interoperability#chapter-2

Likewise, an automated identity man- agement and authentication solution, used to determine which caseworkers are allowed to use the new case management system, could also be procured by Medicaid, not by human services. Again, the cost to enter the SNAP, TANF, and other human service workers’ data and profiles into that identity management solution would have to be borne by those programs and not Medicaid. Still, for 20, 30, or 40 cents on the dollar and not the whole dollar, our human service programs could enter the 21st century. They could all begin to realize the opportunities to innovate not previ- ously available with the intractable, obsolete automation technologies still in use from the 1980s and 90s. One example I liked to share in speeches and in consultations with state directors and chief information officers was Pennsylvania. In late 2013, Pennsylvania’s Department of Human Services was granted approval for 90 percent funding to acquire an imaging and document management solution for Medicaid that the TANF program would also be allowed to use. In early 2014, the state creatively calculated an opportunity that they could not pass up: bring their child support program onto the imaging solution as well. In doing so, it would replace more than 50 separate, county-based document management solutions in county child support agencies with one unified statewide product. Of course, the child support program would be required to convert the data and docu- ments from the county-based systems to the new statewide system, but the savings in initial acquisition, not to mention the maintenance and opera- tion of a single state system versus 50 county systems was not an opportunity to be missed. I am often challenged by state policy- makers that contend that the onerous data-sharing rules between federally funded state human service programs are too contentious to overcome. And though I do not disagree they can be labyrinthine at times, one of the

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