Reducing Bureaucracy and Burden for Child Support Enforcement Programs

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 Child Support Engagement Association (NCSEA) provides mixed feedback on the proposed rescissions, generally supporting many of the 29 proposed changes but specifically opposing the rescission of six specific sections (45 CFR § 302.32, 302.33, 302.38, 303.32, and 304.20). They argue that these specific regulations provide necessary clarity, protect children's interests, and should be retained to avoid unintended consequences.

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 California Child Support Association (CalCSA) provides a mixed response to the proposed rule, supporting the removal of obsolete regulations while opposing the wholesale removal of several other provisions. They argue that removing specific sections regarding financial participation, payment timeframes, and medical support procedures would create operational ambiguity and recommend retaining those provisions or providing clear replacement guidance.

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.

Vicki Turetsky, a former OCSE commissioner, provides a nuanced comment on the proposed rule. She supports retaining rules that improve clarity and compliance but strongly opposes the rescission of specific rules that provide necessary policy interpretations, legal standards, and protections against deceptive practices.

Ann Coffin of the Florida Department of Revenue opposes the full rescission of several specific regulations regarding child support collection, services for non-Title IV-A recipients, medical support notices, and federal financial participation. The agency argues that these regulations provide necessary uniform standards and authoritative guidance not currently addressed by federal statutes.

The North Dakota Department of Health and Human Services supports the proposed rulemaking to reduce bureaucracy but requests the retention of four specific regulations. They argue that rescinding these sections could create uncertainty regarding tax refund distribution periods, paternity-only services, direct payment to families, and "safe harbor" protections for reimbursable activities.