April 2023 NCSEA CSQ

ChildSupportCommuniQue

Table of Contents
April 2023
President’s Message……………………………………………….3
Community Corner: Reflections on Diversity, Equity,
and Inclusion Efforts in Child Support...................................….6
Shaping the Future of Child Support with a Comprehensive
Proposal to Congress: Part I …………………………………......9
Breaking Barriers, Building Relationships: Lessons Learned
from Ohio and Virginia on the Value of Working with Parents
…………...................................................... ................... ……...19
Family-First Distribution of Federal Tax Refund Offset
Collections: Why DRA Distribution is Key …………………….…27
It’s Time to Make Families the Priority …………………………..34
OCSE implements the Central Authority Payment
(CAP) Service …..................………………………………..…….41
NCSEA’S 2023 Policy Forum Wrap-up “Engagement –
Delivering Quality Services with a Passion for Helping Families”
………………………….....................……………………….........44
NCSEA U Spotlight ………………………………………............49
NCSEA U Info ………………………………………....................50

James C. Fleming, NCSEA President
It was great to see so many child support professionals at the 2023 NCSEA
Policy Forum for our annual exchange of ideas on how to move the
program forward. Unfortunately, less than two weeks after the Policy
Forum, state child support agencies received news from the Internal
Revenue Service (IRS) that could cause child support programs to take an
unprecedented step backward and negatively impact families.
The Title IV-D child support program has long been a model of innovation
and partnership of state, local, and tribal government agencies and private
partners. Federal child support laws and regulations provide a lot of
flexibility for service delivery through public or private entities.
Unfortunately, the provisions on child support agencies’ use of federal tax
information (FTI) in Section 6103 of the Internal Revenue Code (IRC)
appear much less flexible.
Since at least 2009, the IRS has made audit findings in 48 states related to
“unauthorized” re-disclosure of FTI beyond the three approved elements for
contractors providing support services to the IV-D program: the name and
address of a parent owing child support and the amount of any federal
income tax refund offset.
For the last 13 years, the IRS has agreed that all these findings and any
requirement of agency corrective action would be held in abeyance
“pending resolution by OCSE and IRS of conflicting interpretations of
federal statutes.” The IRS and OCSE agreed on modernized disclosure

language in 2002, but neither Title IV-D nor the IRC have been amended in
the intervening 21 years. In other words, the conflict has not been resolved.
On February 13, 2023, for reasons that are not completely clear, the IRS
reversed its position and announced: “Beginning October 1, 2023, the
Office of Safeguards will no longer hold in abeyance the finding
‘unauthorized disclosure of FTI to the agency's contractors.’” The IRS has
not identified any new security risks that would justify such a monumental
change. This abrupt change, combined with the looming effective date,
jeopardizes delivery of child support services in nearly all states and
territories.
The contractor “fix” has been ably championed in Congress for many years
by the National Tribal Child Support Association (NTCSA) as part of
proposed legislation to expand access to FTI to tribal child support
agencies. The National Council of Child Support Directors (NCCSD) has
been on record in support of the legislation since 2013.
The Tribal Child Support Enforcement Act passed unanimously in the
United States Senate in July 2021 but was not adopted in the House before
the 117 th Congress adjourned on January 3, 2023.
NCSEA adopted a resolution in support of tribal access and the contractor
“fix” in August 2001, observing: “[S]ince the inception of the program,
States have utilized a wide variety of governmental and non-governmental
entities to provide child support enforcement services.”
After numerous safeguard and security audits and more than a decade of
nationwide reliance on the IRS position, it is not practical or workable to
expect child support programs with privatized offices or outsourced state
disbursement units to bring those services “in-house” by October 1. State
systems cannot be modernized without private contractors having access
to production data that may include FTI. Yet, states will lose access to FTI
if the IRS findings are not resolved, which could also lead to states being
out of compliance with IV-D requirements.
The new IRS position will result in dire consequences to Title IV-D
programs and the millions of families and children served by these
programs.

NCSEA will continue to work with NTCSA and NCCSD and our many
private-sector members to expand awareness of this issue and support
legislation that will finally modernize disclosure of FTI for child support
purposes. NCSEA encourages all of you to work with your tribal council,
county commission, Governor’s office, and Congressional delegation to
bring awareness to this important issue.
James C. Fleming is the director of the Child Support Section of the North Dakota
Department of Health and Human Services, President of the National Child Support
Enforcement Association (NCSEA), member of the Board of Directors for the Western
Intergovernmental Child Support Engagement Council (WICSEC), and former President
of the National Council of Child Support Directors (NCCSD).Jim is a member and
former co-chair of NCSEA’s Policy and Government Relations Committee and
NCCSD’s Policy and Practice Committee, and a member of the editorial committee for
the NCSEA Child Support CommuniQue. Jim also co-chairs NCCSD’s Employer
Collaboration Committee.
Jim was named the 2022 recipient of the American Payroll Association’s Government
Partner Award. He has also received the 2009 Family Support Council Program
Awareness Award and the 2004 Freedom Award from the North Dakota Newspaper
Association.
A second-generation attorney, Jim earned his Bachelor of Arts degree from the
University of North Dakota and his Juris Doctorate from Notre Dame Law School. He
has been an assistant attorney general for North Dakota for 28 years, following a
clerkship with the North Dakota Supreme Court. Jim and his wife Terri are the proud
parents of four daughters and were recently blessed with a perfect granddaughter.

Reflections on Diversity, Equity, and Inclusion
Efforts in Child Support
by Yiyu Chen, Kristen Harper, and Mindy E. Scott, Child Trends
The NCSEA Policy Forum has always offered plenty of opportunities to
learn from child support practitioners and program administrators. Each
year the conference seems to outdo itself, and this year was no exception.
Perhaps one of the most thought-provoking sessions of this year’s Forum
was the Inclusive and Equitable Leadership session (held on Friday,
February 3, 2023) in which child support leaders encouraged participants to
form partnerships and begin the long-term journey toward diversity, equity,
and inclusion (DEI) with incremental steps. They provided guidance to
examine all policies with an equity lens and engage staff at every level in a
collective learning process. Tanguler Gray from the federal Office of Child
Support Enforcement (OCSE) shared OCSE’s vision and suggested
making DEI a culture in which all child support practices are immersed.
What research exists to guide child support agencies in achieving these
important DEI-related goals? Last summer, we studied DEI concepts in
child welfare and special education systems and adapted them to define
DEI for child support. From these other systems, we learned that equity
should be considered not only in the outcomes of a system, but also in the
process that yields the outcomes. In the context of child support context,
this means:
• Supporting the diverse needs of each child, including social and
emotional support, nurturing care, and financial support.
• Ensuring parental responsibility is proportional to parental ability.

• Helping families achieve the previous two outcomes through fair,
unbiased, culturally sensitive policies and practices, including
accommodations to parents with barriers to supporting their children.
While more research and input from those within and affected by the child
support system is necessary to refine this definition, promising efforts that
align with our definition of equity already exist. First, more than half of
states have implemented policies to “pass through” some or all child
support dollars collected to families who have received TANF benefits.
These policies prioritize children’s economic needs and can have broader
implications for parent-child relationships. States have also developed debt
compromise programs and reduced or eliminated interest rates charged to
past-due child support in an effort to limit the burden of child support debt
that does not directly benefit children. These policies can increase child
support payments and slow the growth of debt. State child support
agencies have also partnered with criminal justice agencies to identify
eligibility for child support modifications for parents who will be incarcerated
for an extended period of time. These policies consider “right-size” child
support obligations and how child support services affect child and family
wellbeing.
Second, several federal grant programs help address inequities present in
child support programs or offer additional support to parents who may
interact with child support programs. For example, the Procedural Justice-
Informed Alternatives to Contempt project improves fairness in
enforcement processes to encourage child support compliance and
improve parents’ experiences with child support agencies. The Parenting
Time Opportunities for Children pilot explores how child support agencies
can help parents create safe plans for parenting time during the child
support establishment process. The Safe Access for Victims’ Economic
Security project enhances safety for domestic violence survivors accessing
child support and identifies gaps and recommendations for current policies
and procedures. Responsible Fatherhood programs are designed to
promote parenting, foster economic stability, and support fathers’
relationships, including co-parenting relationships, as strategies to help
fathers overcome systemic barriers to parenting. While research is needed
to understand the effects of these types of programs on key equity
outcomes, the projects have similar equity goals—to lessen the child
support burden, increase parental support, and address barriers to
providing support, while also centering individual circumstances.

With these promising efforts in mind, we conclude with three
recommendations for federal and state child support agencies to further
elevate equity in child support:
• Provide consistent funding for effective programs and address
sustainability issues that many grant-based initiatives face.
• Regularly gather, refine, and analyze demographic and program
implementation data to identify sources of and solutions for inequities.
• Infuse DEI into an agency’s culture by implementing a structure to
incorporate voices from persons with lived experiences, child support
clients, and all staff.
Yiyu Chen, Ph.D., is a Research Scientist at Child Trends. She has spent most of her
career studying how family structure is linked to child poverty and how antipoverty
programs mitigate this relationship. Her recent research centers on child support, food
assistance, the Earned Income Tax Credit, and access barriers in the safety net unique
to Hispanic families.
Kristen Harper, Ed.M., is Vice President for Public Policy and Engagement at Child
Trends. She serves as a strategic advisor working to continuously improve the policy
relevance of Child Trends’ portfolio and connect researchers with local, state, and
federal officials. She is also a nationally recognized expert on education policy,
disparities in education opportunity by race and disability, school discipline policy, and
school health and climate.
Mindy E. Scott, Ph.D., is a Senior Research Scholar at Child Trends. She is a
sociologist and family demographer who conducts action-oriented research to improve
the lives of parents, children, and caregivers with diverse identities and experiences.
Her primary research interests relate to family formation, father involvement, and
healthy relationships/marriage research and evaluation.

Shaping the Future of Child Support
with a Comprehensive Proposal to
Congress: Part I
by Diane Potts and Robert Williams
The last broad far-reaching body of law for the child support program
was the Personal Responsibility and Work Opportunity Reconciliation
Act (PWRORA) more than 25 years ago. Recognizing the substantial
changes that have occurred since the passage of PWRORA in 1996,
NCSEA has taken the initiative to draft a comprehensive package of
legislative initiatives intended to shape the future of the child support
program. The Policy and Government Relations Committee (PGR)
led the work, which focused on five areas: assistance recovery,
performance measures, enforcement, funding, and intergovernmental
cases.
On February 1, 2023, NCSEA’s Board of Directors voted to approve
the legislative package. The Board, however, decided to postpone
advancing the legislation until it determines appropriate sponsors,
and that the package would be well-received and not detrimental to
the child support program in any respect.
This article captures two of the major changes—assistance recovery
and intergovernmental case processing. A second article in the next
CSQ issue, Part II, will explain the other proposed changes around
performance measures and enforcement. The funding piece of the
legislative package will be interwoven throughout Parts I and II where
relevant. Together NCSEA believes these changes will modernize the
child support program and benefit the families that it serves.

I. Child Support for Families to Increase Self-Sufficiency
The role of the Title IV-D program in recovering public assistance has
changed dramatically, thereby justifying a reexamination of both
current and former assistance recoupment policies and practices.
When PRWORA was enacted, Aid to Families with Dependent
Children (AFDC) benefits paid to families were more than twice child
support collections paid to families. However, benefits under the
Temporary Assistance to Needy Families (TANF) program, which
replaced AFDC, have dropped sharply in the years after PRWORA.
At the same time, child support collections have increased
dramatically, mostly due to the new and powerful tools that PRWORA
provided for child support enforcement. As a result, child support
payments to families exceeded TANF payments to families as early
as 1999, and the gap became steadily larger in the intervening years.
The table below, which compares TANF Family Case Benefits versus
Child Support Family Distributions between 1994 and 2022, illustrates
this fundamental change in the program.
In FFY 2021, families received more than four times the amount of
child support than TANF cash assistance benefits. NCSEA
understands that child support, more than ever today, plays a
substantial role in the safety net for single-parent families. While
TANF is important for employment, training, and other critical
services, its role in providing cash support is now far surpassed by
cash support distributed by the child support program.

Moreover, with the sharp decline in TANF benefits, the program’s role
in recovery of TANF benefits has also sharply declined. In 1996, 22
percent of child support collections were retained to reimburse
payment of AFDC benefits. In 2021, that percentage retained to
reimburse payment of TANF benefits dropped to just 5 percent,
meaning that 95 percent of the program’s collections are now paid
directly to families, as demonstrated in the table below.
Retained Child Support Collections as a Proportion of Total
Collections
Even though the child support recovery role has dropped
dramatically, the program is important and interrelated with other
safety net programs. There are significant savings that come from
reduced participation in TANF, Supplemental Nutrition Assistance
Program (SNAP), Medicaid, Children’s Health Insurance Program
(CHIP), Supplemental Security Income (SSI), and public/subsidized
housing due to receipt of child support payments. Income from child
support makes some single parents self-sufficient and ineligible for
these government benefits. Regular child support may make some
parents decide voluntarily not to apply. Cost avoidance also comes
from reduced benefits in SNAP, SSI, and housing vouchers because
child support is counted as income for those programs.
The steep decline in the role of TANF recovery to the child support
program combined with the significant increase and importance in the
role of family support recovery has led NCSEA to reexamine
assistance recovery. For several reasons, NCSEA believes that

ecovery no longer makes sense for both current and former TANF
cases for several reasons.
First, safety net programs generally are not funded by program
participants. TANF benefits are not recouped from a recipient’s
subsequent earnings, nor are benefits from programs such as SNAP
or Medicaid subject to recoupment from subsequent earnings or child
support. The current recovery model essentially takes money from
the most fragile families to run government programs, which to
NCSEA is no longer appropriate public policy.
Second, ending the retention of child support collections would
improve the self-sufficiency of current and former TANF recipients—a
result worth pursuing. Research in Colorado on passing through child
support payments to current TANF recipients resulted in a 10.2
percent increase in child support paid, as both parents came to
understand that all such payments would be distributed directly to the
families. The amount of such payments also increased by 39.4
percent. i With TANF benefits being temporary by definition,
establishing a pattern of child support payments while receiving
assistance increases the likelihood that the family will become selfsufficient
after leaving.
Third, eliminating recoupments from former TANF cases would also
improve the perceived fairness of the program. Both parents are
resentful when child support payments intended for the family are
diverted to federal and state governments to repay TANF costs—a
result that haunts the reputation of the child support program and
may be one cause of the declining caseloads experienced by almost
all states and territories.
Finally, changing the practice of retaining support in current and
former TANF cases would greatly simplify administration of the child
support program and reduce administrative costs. It would end the
convoluted, overly complex, and costly distribution process (i.e., the
“buckets”) that weigh down the current program. It would substantially
reduce both systems development and ongoing operations costs—an
important consideration given the tightening of state budgets across
the country.

While there is wide agreement in the child support program on the
desirability of ending recoupment of TANF expenditures from former
TANF families, doing so without funding changes would potentially
cause significant damage to the child support program. While
recoupments from former TANF families constitute only 3 percent of
total IV-D child support collections, the state share of these
collections nonetheless represents 13 percent of the state share of
total IV-D administrative costs. ii
Most states use most or all of retained support in former TANF cases
to fund part of their IV-D program. As a result, the loss of funding
from retained support in former TANF cases would, in the absence of
state backfill, reduce the resources available to operate the program
by as much as 13 percent.
Similarly, the state share of retained support in current TANF cases
represents slightly more than 7 percent of the state share of
administrative costs for the IV-D program. Loss of that funding source
would also significantly damage program operations and the
important services provided to families.
To avoid the impact of such a large loss of funds, NCSEA’s
recommendation to end assignment and retention of child support
collections is conditioned on additional federal funding to backfill the
resulting loss to state revenues. NCSEA proposes that this funding
be provided by tripling the incentive pool.
In the alternative, NCSEA proposes allowing an administrative match
or federal financial participation (FFP) on incentive fund expenditures.
For example, a state with $10 million in incentives could use those
funds to claim the 66 percent administrative match, which would
increase available resources to $29.4 million. Prior to 2005, states
were permitted to match incentive funds with administrative funds, but
this policy was ended by the Deficit Reduction Act of 2005.
Either restoring the administrative match for incentives or tripling the
size of the incentive pool would replace most state funds that are lost
from eliminating recoupments from former TANF cases and
eliminating retained collections for current TANF cases. As of FFY
2019, potential lost state funding from eliminating recoupments from

former TANF cases would have been $824.7 million (former TANF
retained collections + 66 percent FFP). Lost state funding for
eliminating retained collections for current TANF cases would be
$533,799,943 ($181,491,981 + 66 percent FFP).
Restoring the administrative match for incentive payments would
have resulted in $1.141 billion in new program funding. (Alternatively,
tripling the incentive pool would have resulted in $1.176 in new
program funding). Thus, tripling the incentive pool would have
replaced 87 percent of the state revenue loss from elimination of
former TANF recoupments and current TANF retained collections in
FFY 2019. This is indicative of the impact of legislation that would
end retained collections and triple the incentive pool. In addition to
replacing lost state funds due to this policy change, increasing the
incentive pool would also significantly reinforce the performance
orientation of the program.
NCSEA believes that the child support program would benefit greatly
from eliminating cost recovery. To avoid the potential for harm to
program administration and the families it serves that would result
from these policy changes, however, NCSEA proposes restoring the
match or tripling the incentive pool.
II.
Improved Intergovernmental Case Processing to Benefit
Families with Parents in Different States
NCSEA understands that intergovernmental child support cases are
inherently complex because multiple states are involved. There were
just over 833,000 cases between states in FY 2021, totaling
approximately $1.5 billion dollars in child support collections. iii
Interstate collections represent 7 percent of the total child support
caseload and 5 percent of total collections. This understates the
number of cases involved in intergovernmental child support actions,
however, because it does not count cases living in different states
that are enforced directly, without the involvement of the state where
the other parent lives.
The mandatory Uniform Interstate Family Support Act (UIFSA) for
states, as well as federal regulations, have helped standardize
intergovernmental case processing and provide legal parameters for

establishing, enforcing, and modifying child support orders in these
cases. But more is needed. States continue to focus more on
intrastate cases to the detriment of families with parents living in
different states.
The parts of the legislative package for interstate cases are designed
to streamline communication processes and standardize aspects of
the program. The proposals include mandating that every state's
unemployment agency honor interstate income withholding orders,
imposing timelines for updating arrears balances, and forming agency
workgroups to study interstate communication technologies and
payment processing.
A. Mandating Compliance with Interstate Income Withholding
Orders by Unemployment Agencies
To be comprehensive and uniform, every state should have laws that
require its unemployment agency to honor an income withholding
order issued by another state. UIFSA mandates that employers
comply with income withholding orders issued by any state and to
treat that order as if it were issued by a tribunal in the employer’s
state. In stark contrast, many state unemployment insurance
agencies refuse to honor an income withholding order issued by
another state—even border states where parents frequently
interchange where they work and live.
This lack of uniformity creates disparate results for families when the
parent paying support becomes unemployed and receives
unemployment income that may or may not be subject to withholding
for child support based solely on the parent’s state of residence. This
issue became more evident during the pandemic when
unemployment benefits were greatly expanded, but child support
agencies had difficulty accessing them if the noncustodial parent lived
in a different state. Mandating this requirement would improve
collections from unemployment agencies, which is especially
important during times of economic downturn.

B. Financial Updates Mandate
One of the most significant barriers to intergovernmental case
processing is for the enforcing state to know the exact amount of past
due support from the state that issued the order. The issuing state’s
order often contains provisions, such as interest accrual, that is
different from the law in the state enforcing the order. In this instance,
the enforcing state is especially reliant on the issuing state to
calculate the amount of support owed, including interest. Delays in
providing this information may result in delayed enforcement or
inaccurate arrears balances—to the detriment of both parents and the
enforcing state’s program and reputation.
NCSEA recommends legislation to mandate the frequency for states
to provide updated financial data and mandate the response time to
requests for arrears and interest. This will help alleviate confusion in
enforcement and incorrect arrears balances to the benefit of the
program and the intergovernmental families it serves.
C. Employer Reporting to the National Directory of New Hires
Employers are required to report all new employees to the State
Directory of New Hires (SDNH). Multi-state employers, however, are
permitted to select one state in which the employer does business to
report all new employees. States have implemented the reporting
requirements differently, causing confusion, and efforts by employers
to research and report to the state that—regardless of the number of
employees—has the least onerous requirements. In addition, many
employers have expressed a desire to report to one national
database rather than self-select a state database.
NCSEA recommends legislation that will enable multi-state
employers to report directly to the National Directory of New Hires
(NDNH) administered by the federal Office of Child Support
Enforcement in order to expedite the sharing of the new hire
information to all other states. This will streamline the process and
accelerate the receipt of support to families that rely on it.

D. Workgroups to Study Complex Intergovernmental Issues
One of the most complicated issues in intergovernmental case
processing arises when parties move to different states from each
other and both of their residential states are different from the state
that originally issued the child support order, thereby creating a threestate
case. NCSEA recommends that OCSE create a workgroup with
the goal of streamlining the interstate payment process in these
complicated three-state cases, even though that might require
revising existing language in UIFSA.
In addition, OCSE has required or developed several automated
mechanisms to facilitate communication and information sharing
across state lines. States have various levels of implementation of
these mechanisms, with wide variation across the country. OCSE has
made significant strides in implementing technologies to facilitate
interstate communication, including the sharing of arrears balances,
among the states. However, when there are states that do not fully
implement all available modalities, the usefulness of the technology is
diminished or non-existent. NCSEA recommends that Congress
mandate the formation of a task force requiring OCSE to evaluate
and align federal technology solutions for state implementation that
would benefit the intergovernmental caseload with improved
efficiency and effectiveness.
III.
Conclusion
Change is not easy—especially change to a program’s long-standing
policies and practices. Nevertheless, the child support program today
looks much different than at its inception in 1975 or when PWRORA
was enacted in 1996. For intergovernmental cases, our families are
ever increasingly mobile, and there are policies and technologies that
could be implemented today that will help states get financial support
faster and more efficiently to those families.
For cost recovery, the program today no longer focuses on “paying
back” the government for assistance during hard times; instead, the
child support program’s core value is about helping families move
toward and maintain self-sufficiency. And this cash support to families
from child support comes without direct cost to taxpayers—it comes

only with indirect costs of child support program administration that
has been essentially flat over the past five years. Child support
provides economic and medical support for children by enforcing the
bedrock value of personal responsibility. This major role in the safety
net for single-parent families warrants expanded financial support
necessary to eliminate cost recovery from the program for once and
for all.
Diane Potts is the Child Support Lead Director on the National Strategy Team at
CGI Technologies and Solutions Inc. Diane serves on the NCSEA Board of
Directors and is co-chair of NCSEA’s Policy and Government Relations
Committee as well as an NCSEA Past-President, past Secretary, and an
Honorary Lifetime Member. Diane also is on the Board of Directors for the
Eastern Regional Interstate Child Support Association and is chair of its
Intergovernmental Improvement Committee.
Diane served for six years as Illinois Deputy Attorney General for Child Support.
She was appointed as the official observer to the Uniform Law Commission’s
amendment of the Uniform Parentage Act (UPA) on NCSEA’s behalf, and
currently sits on the UPA’s Enactment Committee. In 2015, she received the
Illinois Child Support Lifetime Achievement Award. Diane received her law
degree from Washington University Law School and her undergraduate degree
from University of Illinois.
Bob Williams has worked in child support at the national level for 40 years. He is
President and Founder of Veritas HHS, which operates contracted IV-D agencies
in three states and voluntary paternity acknowledgment programs in two states.
Bob was formerly founder and CEO of Policy Studies Inc. where he developed
the income shares model for child support guidelines and managed child support
research, consulting, and operations projects. He is a member of NCSEA’s
Policy and Government Relations Committee. Bob earned his B.A. from
University of Illinois at Chicago, and his M.P.A. and Ph.D. degrees from
Princeton University.
i
Tom Zolot, Pass-Through: Direct Support for Children, Final Presentation, Research Report to
Colorado Department of Human Services, June 2020.
ii
Office of Child Support Enforcement, Preliminary Report FY 2021, Tables P-1, P-45, P-15, and
P-12. The State share of administrative costs is $2,379,015,145. The State share of TANF
reimbursements (net of foster care) is $478,775,977. Approximately 35.3 percent of TANF
reimbursements are for retained collections from current TANF recipients. Approximately 64.6
percent are for recoupments from former TANF recipients.
iii
Office of Child Support Enforcement, Preliminary Report FY 2021, Tables P-34 and P-35.

Breaking Barriers, Building Relationships: Lessons
Learned from Ohio and Virginia on the Value of
Working with Parents
By Veronica Riley, Assistant Director for the San Joaquin County
Department of Child Support Services
When received consistently, child support can have meaningful impacts on
families. So, how do we promote consistent payments? Lessons learned
from Ohio and Virginia during their work on the Procedural Justice-
Informed Alternatives to Contempt (PJAC) grant demonstrate that the first
step is building relationships with families to remove barriers to payment.
Child support accounts for 39% of the income received by poor single
mothers, and it reduces their poverty rate by 25% i . It nearly doubles the
income of recipients below the poverty line ii and lifted almost 750,000
people out of poverty in 2021. Most of these children would have been
considered in “deep poverty” if not for child support.

Child support can lessen dependence on public assistance iii . There was a
9% decrease in welfare participation after improvements were made to the
program in the 1990s.
Children receiving child support show academic and cognitive benefits iv like
higher grades and test scores. These children have an increased likelihood
to finish high school, attend college, and have less contact with the juvenile
justice system.
Parents who pay child support are more likely to spend time with their
children v , increasing father-child contact by an average of 27 days per
year.
There are also increased
benefits to single
mothers vi . Single
mothers are 6% less
likely to cohabitate with
non-married partners
due to economic
independence, and are
likely to obtain higher
levels of education. One
study found that for
every dollar of child
support received, the
incomes of custodial
mothers increased by
two dollars.
Households receiving child support have decreased child maltreatment and
neglect vii . Mothers who received support were 10% less likely to have a
maltreatment incident than mothers who did not. Child neglect and
subsequent entry into the foster care system are overwhelmingly due to
issues of family poverty.
Given the positive impact that child support can have on families, it is
imperative that we examine strategies to promote consistent payment. The
PJAC work in Virginia and Ohio found that success starts with
relationships. And the foundation of any good relationship is trust.

It is not surprising to most child support professionals that people do not
trust the program. Why is that? Historical evidence suggests that the
practice of welfare recoupment has a disparate impact on low-income
parties and people of color. It also raises concerns about fairness. Some of
the harsher enforcement actions like contempt hearings, driver’s license
suspension, and bank account seizures, including associated fees, seem
counterintuitive to paying parents. Many argue that if people would just pay
their support, then no one would be on the receiving end of necessary
enforcement actions. While this is true, it is worth examining why people do
not pay their support. Research from federal grants and researchers like
Kathryn Edin viii has identified that most people do want to support their
children; however, they have significant barriers to doing so.
Common barriers are:
• Custody/visitation issues
• High arrearages
• Homelessness
• Incarceration
• Institutional racism/discrimination
• Lack of job skills
• Mental health struggles
• Multiple child support obligations
• Other family obligations, such as caring for an aging parent
• Perception of unfair treatment
• Poverty
• Substance abuse
• Transportation
• Unemployment/underemployment
• Unrealistic child support orders
Ohio and Virginia have worked on strategies to build trust, form positive
relationships, and remove barriers to payment after lessons learned from
their work with the PJAC grant. The grant was awarded to five programs,
and we examine the experience of two in this article. Even after the grant
funding ended, Ohio and Virginia have been able to incorporate the
elements of procedural justice into their office cultures.

The five principles of procedural justice ix are:
• Helpfulness- Individuals perceive that people in the system have an
interest in them and have trustworthy motives
• Understanding- Individuals understand their rights and obligations
and the deliberations and decisions made about them
• Respect- Individuals are treated with dignity and respect
• Voice- Individuals participate in the process and tell their sides
• Neutrality- Individuals perceive decision-makers as unbiased
It is important to apply these principles to both parents owing support and
those owed support to establish a foundation of trust. But how?
Virginia is committed to training all staff in the principles of procedural
justice. Per Barbara Lacina, Virginia’s IV-D Director, this reinforces the
practice within their office culture. They have also committed to reviewing
their business processes, including related forms, to ensure that they are
consistent with procedural justice practices.
One of the major takeaways from the PJAC grant was to apply the
procedural justice model to the existing Family Engagement Services team.
According to the team’s Manager, Gregory Harrison, this unit is a

centralized group of caseworkers dedicated to intervention to avoid
contempt proceedings. In cases where all enforcement actions have not
resulted in order compliance, and/or where participants have been
identified as having a barrier to making payments, they are referred to the
specialized caseload.
The Family Engagement Services caseworker contacts both parties to
assess the situation and identify barriers to compliance. The caseworker
develops an individualized case plan in consultation with the parent(s).
Plan activities range from participation in job training programs and
transportation assistance to referrals for custody and visitation access.
Milestones and dates are a critical part of the plan. Throughout this process
it is important that the customers feel respected, have their voices heard,
understand their rights and responsibilities, feel that the process is fair, and
perceive that the caseworker wants them to be successful.
One of the creative components of
Virginia’s case plans is incorporating a
Temporary Assistance for Needy
Families (TANF) debt compromise
program. After achieving certain
milestones, participants are rewarded
with a reduction of their TANF debt. For
instance, individuals earn a 5%
reduction of debt for achieving two case
plan activities, and another 5%
reduction for making three consecutive
payments in 90 days, etc. Participants
can have up to 20% of their debt
waived and an additional dollar-fordollar
reduction applied to lump sum
payments.
In Ohio, they are committed to the
concept of the new order worker. This
person contacts the parties upon order
Family Engagement Services outreach example from
Virginia
establishment. They explain the order, next steps, rights and
responsibilities, and answer questions. They identify any barriers to

payment and work with the parties to seek a resolution and make a realistic
implementation plan. Not only that, but they have programs in place to help
with employment, substance abuse, and referrals for other supportive
services. As Ohio’s Ann Durkin, PJAC coordinator for Stark County,
explains, "They are the experts in their own lives. Not us.” She believes it is
imperative that we treat participants as real, complex people and not just
data on a chart.
Common to both Ohio and Virginia’s strategies for eliminating barriers is
the concept of the “warm hand-off." They have resources available to refer
parties for assistance with food, housing, transportation, custody, and the
like. They are also customizing services to the parties after truly listening to
their individualized needs. In many cases, this results in the worker
facilitating a discussion between the parties to come to a consensus.
Oftentimes, parties agree that the amount of payment is not as important
as the consistency of the assistance to the child. Sometimes, this even
appears as an agreement to help in non-monetary ways, like transportation
to school and sporting activities. Ms. Durkin relayed a story about working
with both parents when it was identified that the noncustodial parent was
temporarily unable to work due to injury. The custodial party did not know
that this was the case and agreed to modify the order. They agreed that the
noncustodial parent would help with the child in other ways until he was
able to work again. Both parties felt heard and ultimately satisfied with the
agreement and supported by the caseworker.
An example of applying the principles of PJAC to everyday casework was
relayed by Michelle Franco, the PJAC coordinator from Virginia. The Family
Engagement caseworker reached out to Stacy, a non-custodial parent who
was recently released from jail. The caseworker quickly identified that
Stacy was concerned about making it to her first appointment with her
probation officer as if she failed to appear, she would be returned to
incarceration for a violation of probation. Stacy had no reliable
transportation and was concerned that she would not be able to appear.
The caseworker provided her with several transportation options (friends,
family, bus passes, etc.). Even though Stacy had a rebuttal for every option
provided, the caseworker persisted in providing options and stressed the
importance of finding a solution to avoid being returned to incarceration.
The caseworker followed up with Stacy several times to remind her of her

options and help her formulate a transportation plan. To the caseworker’s
delight, Stacy called to let her know that she did indeed find transportation
per their plan and attended the appointment with her probation officer. The
caseworker helping Stacy succeed in this singular task made a huge
difference in Stacy’s life. She helped her get on track. Their next case plan
activity is to help her find employment and begin payment. Stacy felt heard
and cared about in this interaction with the child support program. While the
immediate result was not a child support payment, it did lead to a customer
gaining trust and a willingness to engage with the office. Building trust and
relationships matter, however small the progress may be. That is one of the
lessons learned by both Virginia and Ohio during the PJAC grant. Progress
takes time, but it is worth putting in the effort to build a culture based on
helpfulness, understanding, respect, voice, and neutrality.
While trust and relationships take time to build, staff in the programs feel
they are making great strides as they have seen parties more willing to
reach out to the offices, participate and engage in conversations about
barriers, identify needs, and commit to case plans. They feel they are
making better connections and improving the programs' standing with
customers in their communities. While it will take time, the results will pay
off in the end. Both programs are committed to reviewing all business
processes and intersections with customers through a procedural justice
lens. The philosophy of the culture change promoted in both programs is
well summarized by Virginia’s Michelle Franco, who says above all, “be an
ally, not an adversary.”
Veronica Riley is the Immediate Past President of the Western Intergovernmental Child
Support Engagement Council (WICSEC). She serves on the NCSEA Communications
committee and On Location Podcast subcommittee.
Veronica has over 20 years of experience in California child support and has worked in
various capacities in the county, state, and private sectors. She is currently the
Assistant Director for the San Joaquin County Department of Child Support Services.
She holds a B.A. in Political Science and a Master of Public Administration degree.
i
“The Child Support Program is a Good Investment”, Administration for Children and Families Report, December
2016 https://www.acf.hhs.gov/sites/default/files/programs/css/sbtn_csp_is_a_good_investment.pdf
ii
2021 National Infographic- More Money for Families, Administration for Children and Families
https://www.acf.hhs.gov/sites/default/files/documents/ocse/2021_infographic_national.pdf

iii
“The Child Support Program is a Good Investment”, Administration for Children and Families Report, December
2016 https://www.acf.hhs.gov/sites/default/files/programs/css/sbtn_csp_is_a_good_investment.pdf
iv
The Child Support Program is a Good Investment”, Administration for Children and Families Report, December
2016 https://www.acf.hhs.gov/sites/default/files/programs/css/sbtn_csp_is_a_good_investment.pdf
v
The Child Support Program is a Good Investment”, Administration for Children and Families Report, December
2016 https://www.acf.hhs.gov/sites/default/files/programs/css/sbtn_csp_is_a_good_investment.pdf
vi
“Testing the Economic Independence Hypothesis: The Effect of an Exogenous Increase in Child Support on
Subsequent Marriage and Cohabitation” Demography, April 12, 2014,
https://read.dukeupress.edu/demography/article/51/3/857/169452/Testing-the-Economic-Independence-
Hypothesis-The
vii
“Poverty and Child Neglect: How Did We Get It Wrong?” National Conference of State Legislatures, February 21,
2023 https://www.ncsl.org/state-legislatures-news/details/poverty-and-child-neglect-how-did-we-get-it-wrong
viii
“Taking Care of Mine: Can Child Support Become a Family-Building Institution?” Journey of Family Theory and
Review, March 5, 2019, Taking Care of Mine: Can Child Support Become a Family‐Building Institution? - Edin - 2019
- Journal of Family Theory & Review - Wiley Online Library
ix
“A New Response to Child Support Compliance- Introducing the Procedural Justice-Informed Alternatives to
Contempt Project” MDRC, June 2019, https://www.mdrc.org/sites/default/files/PJAC_Study%20Brief_2019.pdf

Family-First Distribution of Federal Tax Refund Offset
Collections: Why DRA Distribution is Key
by Elizabeth Morgan, Child Support Industry Director for Public
Knowledge ®
Since the passage of welfare reform more than 25 years ago, the child
support program has been shifting its focus from cost recovery for cash
assistance programs to a modern perspective of supporting the entire
family. That shift is reflected, in part, through new family-first distribution
policies and employment programs for the paying parent. While many of
these new policies have resulted in more support flowing directly to
families, the COVID pandemic brought to light one particular issue with
current distribution options.
In March 2020, when the full impacts of the COVID-19 pandemic were just
beginning to be realized, Congress passed the Coronavirus Aid, Relief, and
Economic Security (CARES) Act, which authorized advance tax credits, or
CARES Act relief payments, to households. i The CARES Act provided
eligible individuals with relief payments of $1,200, or $2,400 for married
couples filing a joint return.
While the CARES Act exempted these payments from offset against certain
debts owed to the government, Congress did not exempt child support
debts. As a result, federal law required state child support programs to
intercept these CARES Act payments through the Federal Tax Refund
Offset (FTRO) program; these collections were subject to the federal child
support distribution rules for FTRO collections, and states did not have the
option to suspend the offsets when cases met the FTRO criteria under
Section 464 of the Social Security Act.
On April 21, 2020, the NCSEA Board of Directors passed a resolution
urging Congress to exclude child support debt from offset for any future
COVID relief payments. Subsequent federal legislation authorizing

additional COVID economic relief did exempt past-due child support from
collection through federal offset. However, due to the lack of an exemption
in the CARES Act, states collected a record $4.8 billion in child support
through the FTRO program in FFY 2020, three times the typical annual
FTRO collections from prior years.
In FY 2020, all but six of the 54 states and territories had elected to
distribute FTRO collections according to the distribution rules in effect prior
to the enactment of the Deficit Reduction Act (DRA) of 2005. ii This meant
that a large proportion of $4.8 billion in CARES Act payments intercepted
by the FTRO program were distributed first to assigned arrearages before
any collections were distributed to families. State and federal governments
retained those payments and applied them to assigned arrearages.
Because so much of the CARES Act financial relief intended for families
was retained by the government, many states have begun to reconsider
their child support distribution policies. The impact of the interception and
retention of CARES Act payments was antithetical to the new family-first
focus of the child support program, and state programs wanted to change
how child support distribution impacted families.
This article will discuss the history of the distribution rules around FTRO
collections, the impact of distribution policy choices on families served by
the child support program, and issues around FTRO collections and joint
tax returns in those states electing to implement family-first distribution of
FTRO collections.
Legislative History of FTRO: From AFDC to PRWORA to DRA
In 1981, Congress authorized the collection of past-due child support
through the FTRO program. iii At that time, the FTRO collection remedy was
only authorized for Aid to Families with Dependent Children (AFDC) cases,
and amounts collected could only be distributed to assigned arrearages. In
1984, Congress authorized the use of the FTRO program to collect pastdue
support in non-assistance and former-assistance cases. iv However, the
rules for FTRO collections continued to prioritize distribution to assigned
arrearages first, before paying any arrearages owed to the family. v
To begin shifting the distribution of collections to prioritize families first,
Congress has modified the extent to which states may assign arrearages

and has given states options to disburse more collections applied to
assigned support directly to families.
Prior to the creation of the Temporary Assistance for Needy Families
(TANF) program in 1997, public assistance was administered under the
AFDC program vi,vii and all child support owed to the family prior to and
during the assistance period was assigned to the state, up to the amount of
assistance paid to the family.
With the passage of welfare reform under the 1996 Personal Responsibility
and Work Opportunity Reconciliation Act (PRWORA), the assignment of
child support under the new TANF assistance program changed. Under
PRWORA, families temporarily assigned any child support owed to them
prior to the assistance period, and permanently assigned only those
arrearages that accrued during the assistance period. viii While the family
received assistance, the state could retain collections applied to temporarily
assigned arrearages. After the family left assistance, the temporarily
assigned arrearages became conditionally assigned and the state could
only retain collections applied to these arrearages if paid through a FTRO
collection. ix Any other form of collection applied to these arrearages would
be disbursed to the family.
This new type of assignment and associated distribution rules were difficult
for states to implement and explain to the public. They also didn’t go far
enough to advance the move to a family-first policy. In 2005, Congress
simplified the assignment under the DRA when it eliminated the
assignment of any pre-assistance arrearages. Under the DRA, only those
arrearages that accrue during the assistance period are assigned to the
government. x
In addition to this change in the assignment, Congress also provided states
with the option to distribute FTRO collections in former assistance cases in
the same way as any other collection: first to current support, second to
family arrearages, and third to assigned arrearages. xi This allowed states
the option to prioritize family-owned debt ahead of government-owned debt
to help facilitate self-sufficiency when the family left assistance.

FTRO Collections: PRWORA vs. DRA Distribution
When distributing FTRO collections in PRWORA distribution states, the
distribution hierarchy requires states to apply the collection to assigned
arrearages first, then to family arrearages, and never to current support:
1. Permanently-assigned arrearages or conditionally-assigned
arrearages in any order the state chooses (all collections applied
to these buckets are retained by the state)
2. Never-assigned arrearages (all collections are disbursed to the
family)
Figure 1: Summary of PRWORA Distribution
Order
Payment Type:
Non-FTRO
Disbursed/
Retained
Payment Type:
FTRO
Disbursed/
Retained
1 Current support Family Assigned State
2 Never-assigned Family Never-assigned Family
3 Conditionally-assigned Family
4 Permanently-assigned State
For DRA distribution states, the distribution hierarchy for all collections is
the same, including FTRO collections—the only difference is that the
application of a FTRO collection to conditionally-assigned arrearages will
determine whether the government or the family ultimately receives that
portion of the collection:
1. Current support (disbursed to family)
2. Family arrearages: includes all never-assigned and conditionallyassigned
arrearages if the collection is a non-FTRO collection
(disbursed to the family)
3. Assigned arrearages: includes conditionally-assigned arrearages,
if the collection is a FTRO collection, and permanently-assigned
arrearages (retained by the state)

Figure 2: Summary of DRA Distribution
Order
Payment Type:
Non-FTRO
Disbursed/
Retained
Payment Type:
FTRO
Disbursed/
Retained
1 Current support Family Current support Family
2 Family-owned xii Family Family-owned Family
3 State-owned State State-owned xiii State
Example: PRWORA vs. DRA Distribution of a CARES Act
Payment
By way of example, let’s examine a scenario that could have occurred at
the time the FTRO program intercepted the CARES Act payments in 2020.
A family lives in Washington State with three children. The family has been
periodically receiving TANF benefits and has $1,500 in assigned
arrearages and $1,000 in family-owned arrearages. Current support under
the order is $450 per month. In 2020, the family was not receiving TANF
assistance.
Assume that the parent who pays support was expecting a CARES Act
payment of $1,200. Because Washington State is a PRWORA distribution
state, the state would have applied the CARES Act payment first to the
$1,500 in assigned arrearages. The paying parent would not receive any
portion of the payment, and the family would not receive any portion either
through a PRWORA collection or directly from the paying parent.
Figure 3: PRWORA Distribution of a $1,200 CARES Act Payment
Current Assigned Family-Owned
Beginning Month Balances 450 1,500 1,000
$1,200 FTRO Application 1,200
End of Month Balances 450 300 1,000
Now let’s assume that the family lives in Alaska, where DRA distribution is
in effect. In this case, the state would distribute the FTRO collection of the
paying parent’s CARES Act payment first to current support of $450 and

then apply the balance to the family’s arrearages, reducing them by $750.
In other words, the family would receive the entire CARES Act payment.
Figure 4: DRA Distribution of a $1,200 CARES Act Payment
Current Assigned Family-Owned
Beginning Month Balances 450 1,500 1,000
$1,200 FTRO Application 450 750
End of Month Balances 0 1,500 250
Policy Dilemma: DRA Distribution and Tax Offsets Held for Six
Months
The states currently implementing DRA distribution have different
approaches to allocating FTRO collections that are held for up to six
months when a spouse has filed an injured spouse claim. xiv No current
federal guidance exists for these situations, especially with respect to what
month the FTRO collection should be distributed to current support and
when it should be disbursed. Of seven jurisdictions employing DRA
distribution for more than one year:
• Two jurisdictions apply and disburse FTRO collections to any current
support owed for the month in which the FTRO is received. The
balance is held pending resolution of the injured spouse claim.
• Four jurisdictions apply FTRO collections to the current support owed
in the month in which it was received but delay disbursement of the
entire collection until resolution of the injured spouse claim.
• One jurisdiction holds the entire FTRO collection until resolution of
the injured spouse claim and then applies the collection to any unpaid
current support for the month in which the hold is lifted and disburses
the entire amount.
This policy dilemma and others that states encounter while considering the
implementation of DRA distribution will play a part in future policymaking at
the state and federal levels. If Congress moves to legislate full-family
distribution, many of the discrepancies among states should recede,
providing families with more certainty regarding child support and the
potential for financial self-sufficiency.

Elizabeth Morgan has worked for both state government and private sector child
support programs for more than 35 years. She currently serves as the Child Support
Industry Director for Public Knowledge ® . Elizabeth has focused much of her career on
child support financials and distribution. She has been a lead author of federal policy
guidance and training for distribution requirements under both PRWORA and the DRA
of 2005. She is an individual member of NCSEA and has served as co-chair of
NCSEA’s Policy and Government Relations’ Legislative Education Subcommittee for
the past four years. She is a past-president and honorary lifetime board member of
WICSEC. Elizabeth holds a B.A. from Whitman College, an M.S. from Western
Washington University, and a J.D. from Seattle University.
i
CARES Act, P.L. 116-136, March 27, 2020.
ii
Deficit Reduction Act of 2005, P.L. 109-171, February 8, 2006.
iii
Omnibus Budget Reconciliation Act of 1981, P.L. 97-35, Section 2331, August 13, 1981.
iv
Child Support Enforcement Amendments of 1984, P.L. 98-378, August 16, 1984.
v
See 42 U.S.C. § 657(a)(2)(B) as in effect prior to the enactment of the 2005 DRA.
vi
TANF was established under the Personal Responsibility and Work Opportunity Reconciliation Act of
1996, P.L. 104-193, August 22, 1996.
vii
Social Security Act of 1935, P.L. 74-271, August 14, 1935.
viii
See 42 U.S.C. § 608(a)(3) as in effect prior to the enactment of the 2005 DRA.
ix
Ibid.
x
See 42 U.S.C. § 608(a)(3) as enacted under P.L. 109-171, February 8, 2006.
xi
See 42 U.S.C. § 654(34).
xii
Family arrearages include never-assigned and conditionally-assigned.
xiii
Assigned arrearages include permanently-assigned and conditionally-assigned.
xiv
42 U.S.C § 664(a)(3)(B).

It’s Time to Make Families the Priority
by Kristie Gordy, Wyoming Department of Family Services, Senior
Administrator, Economic Security Division/IV-D Director
Have you ever thought about child support as a method of primary
prevention? What about Temporary Assistance for Needy Families
(TANF) cash assistance?
All children and adults deserve to live and be safe in their own
homes, while also receiving a fair chance at success.
With innovation and collaboration, health and human services agencies
are poised to prioritize families and ensure they receive all interventions
that allow them to become and remain economically secure. What a
prime, unique, and unprecedented space we are currently operating in;
the question is how do states take advantage of it?
While it might feel daunting and it’s easy to get stuck in analysis
paralysis, it is time for states to step up and take some risks. A ripe
place to start is exploring and reimagining the connection between the
child support and TANF programs and treating them as primary
prevention programs. The opportunity and return on our creativity are
significant, with 40% of child support customers either currently or
previous TANF recipients. i Further, 60% of substantiated child protection
responses involve neglect only, and providing families with economic
support decreases the risk for both neglect and abuse. ii Nearly 85% of
these families investigated for potential child protection concerns earn
below 200% of the federal poverty level ($49,720 for a family of three in
2023). iii Now imagine agencies working together to create a preventiondriven
mindset by aligning these key programs aimed at preventing
systemic and generational poverty and keeping children and families
safe at home.

The federal government intentionally intertwined TANF and child
support. TANF was restructured from the former Aid to Families with
Dependent Children (AFDC) as part of a federal effort to “end welfare as
we know it.” One strategy to accomplish this was requiring TANF
participants to cooperate with the child support program or have their
benefits reduced or eliminated. iv With cooperation comes the
assignment of the parents’ rights to any child support as a way to ensure
states could reimburse themselves and the federal government for the
cost of providing TANF to these families.
The first interplay of this cooperation requirement, as many child support
and TANF administrators know, is “pass-through,” which allows a state
to disburse the assigned child support to the parent to whom it is owed.
States are afforded the following options: 1) for former TANF recipients,
states can pass through 100% of arrearage collections to families; 2) for
current TANF recipients, states can, without having to pay a federal
portion, pass through up to $100 per month to families with one child, or
$200 per month to families with two or more children; v 3) instead of
option two, states can elect to provide full pass-through for current TANF
cases, but the state is not exempted from paying the federal portion; or
4) zero pass-through. vi
Another critical component of the cooperation requirement relates to
domestic violence. An average of 24 people per minute are victims of
domestic violence by an intimate partner in the United States. vii
Research indicates that low-income families face a higher rate of family
violence. Importantly, states can adopt a Family Violence Option (FVO),
which requires screening of TANF participants for domestic violence,
referring survivors to services, and providing waivers from work and
other program requirements as needed. viii Enter the concept of good
cause. TANF participants have the right to refuse cooperation with the
child support program if pursuing those services against a particular
parent is against the best interests of the family, usually because
pursuing services may put them at risk of physical or emotional harm.
While the TANF regulations provide guidelines related to good cause,
states have flexibility in creating policies and approval criteria. ix Yet,
while 41 states and D.C. have adopted the FVO, few families are
granted good cause. x How is this the case when the safety of the
families we serve is paramount? It cannot be denied or ignored that
domestic violence is widespread in both TANF and child support

caseloads and that child support actions trigger threats and/or violence.
The current landscape has been painted and is a place we have
operated in for too long. It’s time to explore the wonderful places we can
go!
Many states are embarking on this journey. For example, the Wyoming
Department of Family Service (Wyoming) has embraced this unique
opportunity and is an example of programs working together to truly
prioritize families. Wyoming has adopted “WY Home Matters,” a systemwide
vision/philosophy to promote a prevention-oriented child and family
well-being system focused on empowering families to travel a path that is
self-sustaining. A critical component is the recognition that economic
support programs and services operate as primary prevention
mechanisms. How are programs such as TANF and child support primary
prevention? Simple. They provide families additional stability and security,
with the ultimate goal of keeping children and families safe at home and
providing them opportunities for success.
Through the lens of WY Home Matters, Wyoming emphasizes the
opportunity to focus on child support and TANF, their unique connection,
and ability to help change the trajectory of families’ lives. Importantly, all
primary prevention economic support programs are designed and
operationalized in a coordinated fashion. This has allowed Wyoming to take
advantage of the family-first movement and make substantial and
meaningful changes in providing services to families, starting with child
support and TANF, with a focus on pass-through and good cause.
Pass-Through
From its inception, the Wyoming child support program elected zero
pass-through to families, focusing on the recoupment of child support to
pay back the state and federal government. It became apparent that this
policy decision was not best for children and families, and the program
found itself in a position to explore changes. xi Clearly, any additional
money, even if it is $100/month, put into the hands of parents is one step
towards empowering them. Couple this with other educational and
economic supports, and it can become the difference between a parent
needing continued economic support and a life of economic mobility and
a better future.

Embracing the prevention-minded focus where families are first, the
child support and TANF programs worked closely together (along with
the other economic support programs such as the Supplemental
Nutrition Assistance Program [SNAP], Child Care, and Utilities
Assistance) to develop a plan to implement pass-through for both
current and former assistance cases.
Current Assistance Cases
Wyoming child support implemented the $100/$200 pass-through to
avoid paying the federal portion. One of the most critical decisions that
must be made in relation to pass-through is disregard. Disregard relates
to the other economic support programs and whether the amount of child
support passed through to the family is counted as income for those
programs. It is important to be cognizant of how a policy shift may bear
negative consequences for families in other ways. To avoid such
consequences, Wyoming found it absolutely necessary to disregard
pass-through income for all of the programs it could. This included
TANF, Child Care, and Utilities Assistance; however, SNAP does not
allow such flexibility, so currently the pass-through income is counted as
income, which is not ideal. Wyoming is exploring the option for a waiver
with the Food and Nutrition Services agency to allow disregard for
SNAP. Wyoming rolled out pass-through for current assistance cases on
May 1, 2021, and since then, hundreds of thousands of dollars have
been put into the hands of families.
Former Assistance Cases
The Wyoming child support program has made two substantial policy
shifts, both with the goal of providing families with opportunities for
success. Putting more money in their hands does just that. First, in
October 2021, it switched its distribution rules to require arrears
payments, including IRS offsets collections, to be distributed to families
first. Since implementation, nearly a million dollars has been distributed
to families.
Next, the child support and TANF programs worked together to plan
implementation of 100% pass-through of child support collections for
these cases. This piece has been the most complex, solely because of
the substantial system programming changes required. No doubt, the
technology work has been substantial, but the outcome for families is
worth the investment. The original goal was implementation at the end of

2022, but due to shifting priorities, this was delayed, with a planned go
live in the next few months.
FVO and Good Cause
While Wyoming recognizes the critical economic staple child support is to
families, it also acknowledges that in some instances pursuing child
support is not safe or in the best interests of the parent and child(ren). As
such, it is a priority of the child support program to provide participants with
the best information possible to enable them to make informed and
confident decisions related to pursuing child support.
Wyoming’s TANF program has always adopted the FVO but acknowledges
that the policies and criteria created were very difficult to meet and did not
align with what is known about individuals experiencing family violence
(e.g., requiring a police report). The child support program recognized a
few years ago that more focus and intention must be placed on domestic
violence screening, sparking the comprehensive work. The child support
and TANF programs collaborated in discussing and exploring options
related to the TANF/child support cases and discovered two things: 1) the
good cause policies were too stringent and there was flexibility to adjust;
and 2) child support staff were generally more knowledgeable about the
intricacies of these families’ lives.
As a result, the programs recommended and implemented substantial
changes, including 1) overhauling and relaxing good cause policies and
criteria; 2) transitioning review and determination of good cause requests
from the TANF program to the child support program; and 3) creating more
robust domestic violence screening policies and tools. These changes went
into place on May 1, 2022, and since then, the number of good cause
requests that have been received, reviewed, and approved exceed those
for the prior years.
Last, Wyoming also implemented a Massachusetts-inspired policy change
related to caretaker relatives, typically grandparents. Grandparents
stepping up to raise their grandchildren should not have to encounter more
barriers in doing so. In Wyoming, nearly 50% of the TANF caseload is
made up of caretaker relatives. Wyoming’s previous policy required those
caretaker relatives to cooperate with the child support program in order to
receive their TANF benefit. Children being raised by family is the best
option, and our policies should not impede that model, so now cases where

a caretaker relative believes that opening or proceeding with a child
support case would not be in the child’s best interest must be considered
for a good cause exception. This new policy went into effect on March 13,
2023, and Wyoming looks forward to the benefits this change provides to
this special population.
Wyoming is proud to have made these policy and practice shifts and
excited to see how other states utilize opportunities and benefits to families.
Getting child support into the hands of financially struggling parents is not
only better for that family, but also for the system as a whole, as it will help
reduce the overall cost of programs such as TANF. The healthcare industry
figured out how prevention strategies reduce the cost of the overall
healthcare system and extend life expectancy. It is time the health and
human services system does the same. Innovative, collaborative, and
prevention-minded programs will empower parents to achieve their highest
employment and self-sufficiency potential.
All children and adults deserve to live and be safe in their own
homes, while also receiving a fair chance at success.
Kristie Gordy was born and raised in Cheyenne, Wyoming. She began her career with
the Wyoming Attorney General’s Office and took a job with the Wyoming Department of
Family Services (Department) in 2008. Kristie worked as the Department’s Ombudsman
and Senior Legal & Policy Analyst until she was appointed as the Interim IV-D Director
in 2013. She became the Wyoming IV-D Director in November 2014 while continuing to
serve as the Department’s Senior Legal & Policy Analyst. In October 2017, she was
promoted to Economic Security Division Administrator and, along with child support,
oversees the SNAP, TANF, Child Care, Quality Control, Eligibility Integrity,
LIEAP/Weatherization, and Homelessness programs, as well as field operations. Kristie
earned a Bachelor of Arts from Northern State University in Aberdeen, South Dakota,
and graduated from the University of Wyoming College of Law in 2006. She is licensed
to practice law in both Wyoming and Colorado.
i
DCL-22-04. FY 2021 Preliminary Data Report and Tables. Office of Child Support Enforcement,
Administration for Children and Families, 11 May 2022, www.acf.hhs.gov/css/policy-guidance/fy-2021-
preliminary-data-report-and-tables. Accessed Mar. 29, 2023.

ii
Anderson, C., Grewal-Kok, Y., Cusick, G., Weiner, D., and Thomas, K. “Child and Family Well-being
System: Economic & Concrete Supports as a Core Component.” PowerPoint presentation. Chapin Hall at
University of Chicago, Mar. 2023, www.chapinhall.org/wp-content/uploads/Economic-Supports-deck.pdf.
Accessed 29 March 2023.
iii
Id.
iv
“Policy Basics: Temporary Assistance for Needy Families.” Center on Budget and Policy Priorities, 1
March, 2022, https://www.cbpp.org/research/family-income-support/temporary-assistance-for-needyfamilies#:~:text=Congress%20created%20the%20TANF%20block,with%20children%20in%20poverty%2
0since. Accessed 29 Mar. 2023.
v
Full pass-through on current assistance cases is an option, but a state must pay the federal portion.
Colorado is an example of a state that has implemented full pass-through.
vi
Deficit Reduction Act (DRA) of 2005, P.L. 109-171 (Feb. 8, 2006).
vii
“Domestic Violence Statistics.” National Domestic Violence Hotline,
https://www.thehotline.org/stakeholders/domestic-violencestatistics/#:~:text=Women%20ages%2018%20to%2024,rates%20of%20intimate%20partner%20violence.
Accessed 29 Mar. 2023.
viii
“Policy Basics.”
ix
45 C.F.R. § 260, Subpart B.
x
“Policy Basics.”
xi
The Wyoming child support program budget does not rely on pass-through collections.

OCSE implements the Central Authority Payment
(CAP) Service
by Scott Hale, Federal Collection and Enforcement Manager,
Division of Federal Systems, Office of Child Support Enforcement
On January 3, 2023, international child support payments took a significant
step forward with OCSE’s implementation of its Central Authority Payment
(CAP) service. The service provides a much-needed alternative for states
to send payments to countries that no longer accept checks and require
payments to be sent electronically. Germany’s decision to stop accepting
checks on March 20, 2023 (see DCL 22-14) highlights the urgent need for
this service.
In her remarks to the NCSEA Policy Forum earlier this year, Commissioner
Gray highlighted the importance of this initiative for OCSE. “This is a highpriority
project for OCSE as we know that many states have found the
transition from checks to electronic payments challenging. With the
introduction of the CAP service, OCSE has been able to assist states in
making the transition, and the solution puts more money in the hands of
families, more quickly, by using fast, cost-effective federal processes.”
OCSE announced the implementation of the service in DCL-23 -02 and
followed up with a call with states on February 23, 2023. A majority of
states are now enrolled with the service or completing the enrollment
process.
How CAP works
The CAP service leverages existing federal international payment
processes to send payments quickly and cost-effectively to foreign
authorities. States send payments to CAP using the same ACH electronic
process they use to send payments to other states. CAP consolidates the
payments by destination country and transmits a single weekly payment
electronically to the foreign authority through the federal International

Treasury Services (ITS). The payments flow through a federal HHS bank
account specifically designated for international child support, managed by
the HHS Program Support Center. ITS converts the payment to the
destination’s foreign currency before it is sent, eliminating currency
conversion costs for the receiving parent. CAP concurrently provides a data
file to the foreign authority containing the case and payment details, so the
foreign authority can disburse the child support to the custodial parent.
Enrollment with CAP
States that wish to use the CAP service complete an enrollment process
before payments can be sent through CAP to foreign authorities. States
must reconcile their cases with each foreign authority to ensure that the
foreign authority can properly identify any payment it receives. A one-time
setup process, including testing of the state’s NACHA (National Automated
Clearinghouse Association) payment file, ensures that the state is correctly
sending the payment data that is required for the file that CAP sends to the
foreign authority.
Foreign partners
Although the CAP service is currently sending support payments to
Germany only, the service will expand to include payments to other
countries that require electronic payments. Fourteen countries have
formally asked the U.S. to stop sending checks (see IM 21-05), and OCSE
expects more foreign partners to request electronic payments now that the
service is available. OCSE’s announcement of the implementation of the
CAP service at a recent meeting of the Hague Experts Group on the
International Transfer of Maintenance was enthusiastically received by all
countries attending. Payments from CAP to all foreign authorities will use
the same process, and states that are enrolled in CAP will be able to start
sending payments to any foreign country that joins CAP once they have
reconciled their caseload with the foreign authority, and properly identified
the country in their payment file. No additional set-up is required.
Benefits for families
Replacing checks with electronic payments makes a significant difference
for families. Checks are expensive to cash, and foreign parents can wait
months for U.S. checks to clear. The CAP process eliminates these costs
and delays. Parents receive the payment in their own currency, quickly, and
reliably.

OCSE and the CAP team are grateful for the assistance of California,
Georgia, Michigan, and New York in the design, testing, and piloting of the
CAP service. Their advice, feedback, and support were invaluable in the
successful implementation of the service.
For more information about CAP, please email
CAP_Program@acf.hhs.gov.
Scott Hale is the Manager of the Federal Office of Child Support Enforcement’s (OCSE)
Federal Collection, Enforcement, and Special Matching Programs. As manager, Scott is
responsible for the program and operations oversight of the Federal Offset, Passport
Denial, Multistate Financial Institution Match, and Insurance Match programs which
accounts for over 5 million noncustodial parents owing more than $110 billion in pastdue
child support. He is also OCSE’s senior liaison and subject matter expert for IRS
safeguarding and disclosure. Scott has 30 years of experience working in child support
at the local, state, and federal levels including 25 years with OCSE.

NCSEA’S 2023 Policy Forum Wrap-up
“Engagement – Delivering Quality Services with
a Passion for Helping Families”
by Connie Chesnik and Margot Bean, Co-chairs, NCSEA 2023
Policy Forum
‘Engaging’ is the best word to describe the 2023 NCSEA Policy Forum. The
449 in-person and 264 virtual attendees enjoyed informative, thoughtprovoking
discussions and presentations led by excellent speakers
addressing this year’s theme, “Engagement – Delivering Quality
Services with a Passion for Helping Families.” Our mission was to
promote engagement and enthusiasm for what we can offer to families. We
accomplished that through a two-pronged approach of addressing quality
and well-informed services with a desire to do good for our families.
We were honored to have both the federal Office of Child Support
Enforcement (OCSE) Commissioner, Tanguler Gray, and the
Administration for Children and Families (ACF) Assistant Secretary,
January Contreras, join us for the opening plenary. Assistant Secretary
Contreras shared a strong message of support for the work being done in
the child support program. She applauded Commissioner Gray’s efforts to
increase child and family safety and well-being, build economic stability,
and center the well-being of Native American families and tribal
communities. Commissioner Gray followed by sharing her priorities for the
coming year, including:
• Extending flexibility to programs during public emergencies.
• Improving federal and state collaboration with tribal programs.
• Reinvesting in programs that support fathers and further employment.

Together, their message provided the
perfect segue for the second plenary,
a lively discussion on a legislative
proposal from NCSEA that reflects a
significant culture shift in the child
support program, covering objectives
from cost recovery to family support.
Attendees listened as NCSEA
President, Jim Fleming, and Board
members Diane Potts and Bob
Williams discussed the reduced role the child support program has had in
cost recovery and the desire to end retained collections from current and
former Temporary Assistance for Needy Families (TANF) recipients in
order to pass all collections through to families. The panelists discussed
proposed improvements to federal performance measures, new
enforcement measures, and proposals for expanded federal funding to
assist noncustodial parents in increasing their ability to earn income and
develop parenting time agreements that foster deeper relationships with
their children.
Thursday afternoon’s plenaries began with an impactful session that
bridged the gap between enforcing child support orders, the foundation of
our program, and tools that can be used to improve engagement with
families. Michigan’s trauma-informed approaches to enforcement and
Georgia’s use of electronic hearings demonstrated how we can serve
families more effectively. Texas and Oregon highlighted improvements
made to existing enforcement tools. The first day of the Policy Forum
concluded with a brief history of the 1115 Demonstration Waiver and
Special Improvement grants, and an innovative discussion on the
experiences of a few states in administering those grants. These projects
have provided an opportunity to test new ideas that have helped the child
support program move toward stronger engagement with participants and
stakeholders. Speakers from around the country highlighted their
noncustodial parent employment projects, digital marketing, behavioral
interventions, and procedural justice grants, focusing on the impact their
work has had and the ongoing actions being taken to sustain their efforts.
In discussing how these projects moved their agencies closer to
engagement, program representatives noted that as cases became
customers, they’ve learned to meet people where they are and have gained
a better understanding of the populations they serve.

Friday’s sessions opened with a plenary dedicated to continuing the
dialogue on equitable and inclusive leadership. The discussion was led by
speakers who have succeeded in implementing change in their programs.
They shared their experiences by modeling diversity, equity, and inclusion
(DEI) in the tone and delivery of their messages and emphasized the need
to normalize DEI in our culture so that it becomes a practice and not an
initiative. One of the more memorable quotes of the conference came from
Ryan Parker, Vice President of Diversity, Equity, and Inclusion at CGI, who
urged attendees to be thermostats, not thermometers. “Don’t take the
temperature in the room, set it!”
The discussion of equity carried over into a session on recent ACF policy
guidance relating to foster care referrals. This session offered another
opportunity to engage with our IV-E partners. Attendees heard from states
that have successfully implemented the new guidance, as well as states
facing implementation challenges. Strong collaboration between child
support and child welfare agencies was encouraged, and both the ACF
Children’s Bureau and OCSE offered their assistance to make changes in
support of the children and families that we all serve.
The importance of collaboration
continued into the Friday
afternoon plenaries, beginning
with a discussion of
collaboration between the
Temporary Assistance for Needy
Families (TANF) and child
support programs featuring child
support directors and economic
support administrators focused on aligning their programs to enhance
economic mobility through employment and training services. The
discussion included the perspectives of custodial and noncustodial parents
whose lived experiences helped create an understanding of how trust
building and trauma-informed service delivery can produce better
outcomes.
Friday concluded with a very powerful session on understanding and
engaging justice-involved families. The session began with a presentation
from the Wisconsin Institute for Research on Poverty regarding the

prevalence of incarceration in the United States, providing staggering data
on the number of state and federal prisoners who are parents to minor
children. That presentation was followed by Fatherhood Program Director
Sharmain Harris, who brought attendees to tears with his compelling story
that culminated in a pardon from Wisconsin Governor, Tony Evers, in late
2022. Sharmain talked to his audience about how he leveraged what he
has learned from his past to build a positive future where he has organized
one of the most successful fatherhood programs in the country. Sharmain
also emphasized the importance of engaging with fathers in the child
support program, noting that while we may be able to measure how much
they pay in support, we should also be measuring how much time they
spend with their children.
It was a packed house on Saturday for two of the most engaging sessions
of the Policy Forum. Debt reduction was the topic of the first session,
prompted by the publication of OCSE IM 22-03, addressing the family and
state benefits of debt compromise. Research shared with attendees
demonstrated that while two-thirds of state-owed arrears are over $20,000,
they comprise only 15% of the cases with state-owed arrears. Most cases
involve amounts below $5,000 and attendees learned about different debt
reduction programs being used around the country that can reduce
hardships for families and improve outcomes for the child support program.
The 2023 NCSEA Policy Forum concluded with a riveting discussion on
child support caseload reductions. Preliminary results from the recently
conducted National Child Support Market Research Survey highlighted
reasons families opt not to reach out to the child support program.
Panelists shared ideas on internal policy changes that can be made to
address barriers to participation.
The NCSEA Policy Forum would not be possible without the hard work and
planning of the Policy Forum Planning Committee. Our sincere thanks to
the team for their efforts over the past six months:
Carol Beecher Janice McDaniel Jay Bland
Kelly Micka Kara Bradley Katie Morgan
Verrhonda Bullock Ann Marie Oldani Larry Desbien
Sharon Pizzuti Jason Cabrera Diane Potts
Robbie Endris Amy Roehrenbeck Jim Fleming
Laura Roth Corri Flores Trish Skophammer

Laura Galindo Elaine Sorensen Paul Gehm
Jonell Sullivan Matthew Gomez Jeff Thompson
Emily Gregg Elise Topliss Meg Haynes
Rob Velcoff Lyndsey Irwin Marie Waite
Daniel King Carla West Marcie Martinez
Jamie Zaffino
Margot Bean (Co-chair)
Connie Chesnik (Co-chair)
We look forward to seeing you next year in Washington, D.C. from
February 2 to February 4 for the 2024 NCSEA Policy Forum!
Connie M. Chesnik received both her undergraduate and law degrees from the
University of Wisconsin-Madison. As an attorney for the Wisconsin Department of
Workforce Development, Connie advised the child support program for many years and
has spoken frequently on Wisconsin’s child support guidelines and Wisconsin’s tribal IV-
D program. She is currently the Administrator of the Division of Family and Economic
Security in the Department of Children and Families where she oversees Wisconsin’s
child support, refugee, and employment programs. Connie is a member of the State Bar
of Wisconsin, and the State and National Child Support Enforcement Associations. She
currently serves on the NCSEA Board of Directors.
Margot Bean is a Managing Director in Deloitte Consulting’s Human Services
Transformation Practice, focusing on helping child support programs improve their
outcomes by providing effective and efficient data driven customer-focused services.
Margot’s wide variety of government experience prior to joining Deloitte provides her
with deep understanding and insight: Commissioner of the federal Office of Child
Support Enforcement, IV-D Director of the New York State Child Support program, IV-D
Director of the Guam Child Support Program, and child support attorney. She is a
current member of the NCSEA Board of Directors.

Announcing 2023 NCSEA U at
Leadership Symposium
Leading with Heart
Participants in the 2023 NCSEA U at Leadership
Symposium program will have the opportunity to explore
the importance of what it means to lead with heart in order
to change their workplaces for the better. Leading with
Heart will equip participants with the tools to become more
empathetic leaders, for the benefit of their teams and the
families they serve.
We are pleased to introduce the 2023-2024 summer NCSEA U instructors, Robbie
Endris and Laura Van Buskirk.
PLANNING AND LOGISTICS
What is included with NCSEA U?
A pre-conference Get Acquainted Webinar, virtual and on-site sessions, one postevent
webinar, plus networking events at Leadership Symposium.
The 2023 NCSEA U program will be held in conjunction with the NCSEA 2023
Leadership Symposium in Anaheim, CA. The Leadership Symposium is scheduled for
Sunday, August 6 through Wednesday, August 9, with the NCSEA U classes held
directly following the conference on the afternoon of Wednesday, August 9 and the
morning of Thursday, August 10. The 2023 NCSEA U registration fee is $200.
APPLICATION PROCESS
Application Now Available - final submission date is Monday, May 1, 2023
Click for more
information, including
application link