ACF Reducing Bureaucracy Burden Child Support Enforcement Program NPRM 0970-AD39

The League of United Latin American Citizens (LULAC) opposes the proposed rule to reduce bureaucracy in child support enforcement programs. They argue that removing regulations on outreach, oversight, and uniform standards will create barriers for families—particularly Latino and limited English proficient families—and lead to geographic inequities in service delivery.

The Main Street Foundation's Center for Regulatory Analysis and Engagement (CRAE) supports the ACF's proposal to remove obsolete and duplicative regulations from the child support enforcement program. They recommend that the agency provide a public crosswalk of removed provisions, ensure that removed requirements do not reappear as binding guidance, and measure the practical results of the reform.

The National Council of Child Support Directors (NCCSD) supports the proposed rulemaking to reduce regulatory burden but requests that the agency retain five specific sections of the CFR. They argue that removing these sections would undermine operational stability, eliminate uniform guidance on fees and services, and create risks for vulnerable families and state funding predictability.

Sofia DeVito, a Visiting Fellow at FGA ACTION, strongly supports the proposed rule to remove obsolete and duplicative child support regulations. The commenter argues that the rule aligns with federal deregulatory initiatives and provides necessary regulatory cleanup without changing substantive obligations.

Kendra L. Porter, representing the Missouri Department of Social Services, opposes the proposed rulemaking because it introduces ambiguity into current federal regulations. The commenter requests that the Office of Management and Budget withhold approval until the issues regarding regulatory consistency and clarity are addressed.

The Cherokee Nation Office of Child Support Services supports the proposed rule changes to expand Tribal access to federal child support enforcement tools and data. They emphasize that for these benefits to be effective, the Model Tribal System (MTS) must be updated to include automated federal data processing and proactive data matching similar to state systems.

A concerned citizen opposes any provisions in the proposed rule that would weaken or repeal protections requiring child support funds to be paid directly to custodial parents. The commenter argues that allowing private collection companies to intercept or skim payments would impose significant financial burdens and delays on families.

The Washington State Department of Social and Health Services generally supports the proposed rulemaking to reduce bureaucracy in child support enforcement. However, they request the retention of specific regulations regarding 30-day distribution periods for tax refunds, protections against private collection agencies, and the list of FFP-eligible activities to ensure operational clarity and fiscal predictability.

The Texas Office of the Attorney General - Child Support Division supports the proposed rulemaking to reduce regulatory burdens on child support enforcement programs. They agree with the majority of proposed rescissions and provide specific recommendations for modernization, including risk-based audit frameworks and clearer guidelines on technology and certification.

Georgia’s Division of Child Support Services (DCSS) opposes the proposed rescission of several regulations, arguing that while they may be duplicative of statutes, they provide essential, concise guidance that simplifies research and clarifies complex legal requirements. The commenter contends that removing these regulations would increase the bureaucratic burden on states, create contractual uncertainty, and increase costs for updating State Plan Pages.