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

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 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.

The commenter opposes the removal of section 302.33(a)(6) because it would eliminate state flexibility in providing paternity-only services. They argue that establishing paternity is important for non-monetary benefits like inheritance and birth certificates.