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 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.

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.

The Massachusetts Department of Revenue's Child Support Services Division opposes the deletion of specific regulations (45 CFR § 302.32 and 45 CFR § 304.20) within the proposed rule. They argue that these regulations provide necessary protections for federal tax refund offsets and offer more stable, reliable guidance than the proposed sub-regulatory substitutes.

The Louisiana Department of Children and Family Services provides mixed feedback on the proposed rule, supporting the rescission of 45 CFR 302.30 but opposing the rescission of 45 CFR 302.32, 302.33, and 304.20. They argue that the latter three sections contain substantive protections and standards not found in the underlying statutes, and their removal would create audit risks and increase caseload burdens.

The Michigan Office of Child Support opposes the proposed rescission of several regulations, arguing that they provide essential operational guidance and regulatory certainty for the Title IV-D program. The state contends that removing these provisions would create ambiguity, increase the risk of errors in payment distribution, and potentially burden families with unwanted services or fees.

The National Parents Organization (NPO) opposes the proposed repeal of § 302.33 and § 302.38, arguing that the sections are not fully duplicative and that their removal would eliminate important provisions. Specifically, they argue that the repeal would remove the option for paternity-only limited services and could allow private companies to profit from custodial parents by collecting fees for services that provide no added value.