Reducing Bureaucracy and Burden for Child Support Enforcement Programs

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.

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.