Comment on FR Doc # 2026-11530

I respectfully submit this comment in strong opposition to the proposed rule rescinding the regulatory provisions supporting employment and training services for noncustodial parents (NCPs) within the child support program. The proposed rescission is inconsistent with the objectives of Title IV-D of the Social Security Act, which are to improve the effectiveness of child support programs, increase reliable child support collections, and promote the economic well-being of children. Employment services directly advance these objectives by addressing one of the primary causes of nonpayment: insufficient or unstable income. The Department's rationale that these provisions are unnecessary because workforce services are available through other programs overlooks the unique role of the child support program. Employment initiatives operated through or in partnership with IV-D agencies integrate workforce development with child support case management, order compliance, and family engagement. General workforce programs are not designed to identify or serve child support participants, coordinate with child support agencies, or address the legal and financial barriers associated with child support obligations. Eliminating the federal regulatory framework will likely reduce state investment in these specialized services and produce inconsistent access across states. The evidence supporting employment-focused interventions is substantial. Demonstration projects and state initiatives have shown that employment assistance can improve labor force participation, increase earnings, strengthen compliance with child support orders, and reduce long-term arrears. Stable employment is among the strongest predictors of consistent child support payments. Removing support for employment services risks undermining the very outcomes the child support program seeks to achieve. The proposal also fails to adequately consider its long-term consequences. Parents facing barriers such as limited education, criminal records, disability, transportation challenges, housing instability, or economic displacement often require coordinated employment assistance before they can consistently meet their support obligations. Without these services, more parents are likely to experience prolonged unemployment or underemployment, resulting in larger arrears, reduced collections, increased enforcement activity, and diminished family stability. These outcomes ultimately impose greater costs on child support agencies, courts, and taxpayers. The Administrative Procedure Act requires agencies to engage in reasoned decision-making. A decision to rescind an existing regulation should include a reasoned explanation demonstrating that the agency considered the reliance interests of states, service providers, and families that have developed programs based on the existing regulatory framework. The proposal does not sufficiently explain why the documented benefits of employment services no longer justify maintaining these provisions or why less disruptive alternatives were rejected. The Department should also consider whether rescinding these provisions is consistent with broader federal priorities promoting workforce participation, economic mobility, responsible parenthood, and family self-sufficiency. Employment services represent preventive, evidence-informed investments that strengthen compliance through increased earning capacity rather than relying primarily on enforcement after nonpayment has occurred. If the Department believes revisions are warranted, it should modernize the regulations by increasing state flexibility, encouraging partnerships with workforce agencies and employers, and supporting evidence-based employment strategies. Complete rescission, however, removes an important policy framework without demonstrating that doing so will improve outcomes for children or increase program efficiency. For these reasons, I urge the Department to withdraw the proposed rule and retain the regulatory provisions supporting employment and training services for noncustodial parents. Preserving these provisions will better advance the statutory mission of the child support program by promoting sustained employment, improving child support compliance, increasing collections for families, and supporting the long-term economic security of children.