Child Support Cooperation Requirements in Child Care Subsidy Programs and SNAP: Key Policy Considerations

FAMIL

Y SUPPORT

IssueBRIEF

Rebekah Selekman and Pamela Holcomb

Child Support Cooperation Requirements

in Child Care Subsidy Programs and

SNAP: Key Policy Considerations

The EMPOWERED

study, conducted on

behalf of the Assistant

Secretary for Planning

and Evaluation (ASPE)

at the U.S. Department

of Health and Human

Services, examines the

use of performance

measures, work

requirements, and

child support coop-

eration requirements

across human services

programs. This issue

brief examines the use

of child support coop-

eration requirements

in the Supplemental

Nutrition Assistance

Program (SNAP)

program and child

care subsidy programs

funded under the Child

Care Development

Fund (CCDF).

HIGHLIGHTS

• States have the option to require recipients of child care subsidies and Supplemental

Nutrition Assistance Program (SNAP) to cooperate with child support agencies seeking

to establish paternity and support orders; and to enforce child support obligations as a

condition of eligibility.

• Child support cooperation is more frequently required by child care subsidy recipients

(required by 23 states) than SNAP recipients (required by 7 states).

• Within federal parameters, states have considerable exibility to design cooperation

requirement policies. Policy variation across states aects who is subject to the coopera-

tion requirement, the criteria used to determine good cause exemptions, and penalties

for noncooperation. A better understanding of how these policies are implemented at

the local level is needed to identify best practices for the eld.

• Minimal data on cooperation requirements for child care subsidy and SNAP recipients

are collected by states. While there is heightened interest among state and federal policy-

makers to expand the mandate for child support cooperation requirements, the impact of

cooperation requirements on program operations and sta workload, program participa-

tion, child support receipt, and family’s economic well-being remains largely unknown.

Some public programs—Temporary Assistance

for Needy Families (TANF), Medicaid, and

Foster Care maintenance payments under

Title IV-E of the Social Security Act—have

a mandatory requirement for applicants and

participants to cooperate with the child support

program (also known as the IV-D program)

to establish paternity and support orders, and

to enforce child support obligations. However,

for other means-tested public programs, states

have the option to exercise a child support

cooperation requirement (Figure 1). is brief

focuses on the child care subsidy program

funded under the Child Care and Development

Fund (CCDF) and the Supplemental Nutrition

Assistance Program (SNAP).

BACKGROUND

Since the enactment of the landmark 1996 federal

welfare reform law (the Personal Responsibility

and Work Opportunity Reconciliation Act, or

PRWORA), states have had the option to require

SNAP applicants and recipients—custodial

parents, noncustodial parents, or both—to

cooperate with child support.

Additionally,

under SNAP rules, states also have the option to

disqualify noncustodial parents who are in arrears

with their court-ordered child support payments.

Some states have also enacted laws or policies

that require applicants for and recipients of child

care subsidies funded under the Child Care

Development Fund (CCDF) to cooperate with the

child support program as a condition of eligibility.

OCTOBER 2018

MATHEMATICAMPR.COM

PRINCETON, NJ  ANN ARBOR, MI  CAMBRIDGE, MA  CHICAGO, IL  OAKLAND, CA  SEATTLE, WA

TUCSON, AZ  WASHINGTON, DC  WOODLAWN, MD

Requiring child sup-

port cooperation for

public program partici-

pants is a strategy for

reducing poverty and

promoting economic

mobility.

The IV-D child support program collects money from noncustodial parents and

distributes that ﬁnancial support to their children. For some public programs, states

must require cooperation with child support as a condition of eligibility. For other

public programs, states have the option to require cooperation with child support.

REQUIRED FOR ALL STATES

TANF providesﬁnancial

assistancefor eligible low-

income familieswith children

to help pay for food, shelter,

utilities, and other basic needs

Medicaid provides health

coverage to eligible low-

income adults, children,

pregnant women, elderly

adults and people with

disabilities

MAY BE REQUIRED BY STATE

SNAP provides nutrition

assistance to eligible,

low-income individuals

and families through a

monthly beneﬁt

CCDF provides ﬁnancial

subsidies to low-income

families to access child

care so that parents can

work or attend job training

or educational programs

Figure 1. Public programs and child support cooperation requirements

Low-income families

that participate in

multiple public

programs can face

a complex array of

cooperation require-

ments with dierent

policies and rules.

As part of a broader policy conversation about

ways to reduce poverty and promote economic

mobility, there is increased interest at both

the federal and state levels how other public

programs can use child support cooperation

requirements to (1) increase self-suciency

and reduce the need for public assistance by

increasing family income and (2) increase

participation in the child support system and

noncustodial parents’ nancial support of

their children (Doar 2016; Executive Order

no.13828, 2018).

is conversation is, in part,

prompted by concern over a steady reduction in

the IV-D child support caseload, driven largely

by a decline in cases that are current or former

TANF participants.

is brief provides context for discussions on

this important and still evolving policy issue

by summarizing ndings from an exploratory

examination of the current landscape of optional

cooperation requirements. We draw on several

sources, including a scan of publicly available

data, discussions with federal stakeholders, and

in-depth discussions with child support, child

care, and SNAP administrators in eight states:

Colorado, Florida, Kansas, Michigan, Mississippi,

North Carolina, South Dakota, and Virginia.

We begin with a national snapshot of the

current status of states’ adoption of coopera-

tion requirements for child care subsidy and

SNAP recipients and an overview of the process

used to implement the requirement. Next we

describe key points in the cooperation process

at which states have exibility to shape policy,

and illustrate some policy variations between the

eight study states. en we oer considerations

for policy and practice and highlight areas ripe

for future research. More details about the study

methods can be found at the end of this brief.

USE OF COOPERATION

REQUIREMENTS: A NATIONAL

SNAPSHOT

As of May 2018, 24 states had exercised the

option to require recipients of child care subsi-

dies and/or SNAP to cooperate with the child

support program. Cooperation requirements

are much more common in child care programs

than in SNAP. Seventeen states require child

support cooperation only for recipients of child

care subsidies; one state requires cooperation

only for SNAP recipients; and six states require

cooperation for both child care subsidy and

SNAP recipients

(Figure 2).

Some states have many years of experience

applying these kinds of cooperation require-

ments. Among the study states, Michigan and

Mississippi have had cooperation requirements

in place since the 1990s, with Florida following

suit in the early 2000s. Since 2005, Colorado,

which has a county-administered child support

program, has given counties the option to require

cooperation of child care subsidy recipients.

Child support coop-

eration may include

participation in activi-

ties such as genetic

testing; attending

court hearings; and

sharing ﬁnancial docu-

ments and information

to locate the noncus-

todial parent.

States with no child

support cooperation

requirements

States with child care

cooperation requirements

States with SNAP

cooperation requirements

States with SNAP and child

care cooperation

requirements

Figure 2. Use of child support cooperation requirements in child care subsidy

programs and SNAP, by state

Sources: The National Conference of State Legislatures Child Support and Family Law Legislation Database; the

Child Care Development Fund Policies Database; U.S. Department of Agriculture Annual State Option Reports; and

the National Council of Child Support Directors' May 2018 survey of state child support directors.

Note: One U.S. territory, Guam, exercises the option to disqualify custodial parents from SNAP eligibility for

noncooperation with child support.

Since 2015, 17 states

have introduced at

least one legislative

proposal to establish

child support coopera-

tion in SNAP.

About half of its counties requir

e cooperation at

this time. Since 2015, ve states have established

cooperation requirements for the rst time

Kansas (2015) requires cooperation for

recipients of child care subsidies and

for SNAP recipients.

Virginia (2016) requires cooperation

for child care subsidy recipients.

North Carolina (2017) requires

cooperation for child care subsidy

recipients in three pilot counties where

a cooperation requirement is being

implemented.

South Dakota (2017) requires

cooperation for SNAP recipients.

Maine (2017) requires cooperation for

SNAP recipients.

e option to establish child support coop-

eration requirements for child care subsidy or

SNAP recipients also allows states to rescind

the requirement. Currently, no single data source

contains information that could be used to com-

pile a complete record of the use of cooperation

requirements across states over time. Based on

our scan, however, it appears that take-up of the

option is dynamic, with some states adding and

others dropping the cooperation requirement in

these programs. For example, Wisconsin began

requiring SNAP recipients to cooperate in 2002

but eliminated the requirement in 2009. Idaho

required SNAP recipients to cooperate from

2004 through 2009,

eliminated the requirement

in 2011, and reinstated it in 2015.

Overall, a comparison of our scan of states

that required cooperation in child care subsidy

programs or SNAP as of 2018 and a similar

review conducted around 2005 suggests a slight

upward trend in the overall number of states

with these kinds of cooperation requirements

(Roberts 2005). e total number of states with

cooperation requirements for child care subsidy

recipients increased from 14 in 2005 to 17 in

2018, with 6 states adding the requirement and

2 dropping it. Also, comparing changes between

2005 and 2018, three states (Kansas, Maine,

and South Dakota) chose to start exercising the

option to have a SNAP child support coopera-

tion requirement, and Wisconsin dropped it.

Since 2005, relatively few states have chosen to

establish cooperation requirements for recipi-

ents of child care subsidies or SNAP recipients,

although, many proposals involving these

requirements were introduced during recent state

legislative sessions. ese have either failed or were

left pending at the close of the session. Since 2015,

for example, according to the National Conference

of State Legislatures’ Child Support and Family

Law Legislation Database, 17 states introduced at

least once bill establishing child support coopera-

tion in SNAP and 7 states introduced at least one

bill establishing cooperation requirements in child

care subsidy programs.

OVERVIEW OF THE COOPERATION

REQUIREMENT PROCESS

Apply for

assistance

Child

support

programs

Referral to child

support for

program for

cooperation

Initial and

ongoing

assessment of

cooperation

Child care

subsidy

program

and SNAP

Administering cooperation requirements relies

on close coordination between the referring assis-

tance program (the child care subsidy program or

SNAP) and the child support program. In turn,

both systems need to inform and interact with

the individuals seeking or receiving assistance

and communicate the outcome of those interac-

tions to each other within established time-

frames. is section summarizes the general steps

in the process and describes how an automated

electronic interface can facilitate it.

Key steps in the cooperation process. e

cooperation process begins when a person applies

for assistance. e assistance program informs

the applicant of the cooperation requirement

and determines whether the applicant should be

referred to the child support program for services.

After receiving the referral, the child support

agency contacts the individual to obtain informa-

tion required to establish paternity or a support

order (if needed) and enforce the order. e child

support agency is typically responsible for tracking

cooperation and updating the assistance agency on

cooperation status. e assistance agency is gener-

ally responsible for making the initial referral to

the child support agency, but there are exceptions.

For example, in Mississippi and South Dakota,

it is the responsibility of the child care subsidy

applicant to initiate contact with the child support

oce to open a case if one has not been opened

and to obtain verication of cooperation.

Applicants can be excused from cooperation

requirements for good cause if they demonstrate

that cooperating with child support would

not be in the best interest of the child; for

example, if it might increase the risk of physi-

cal or emotional harm to the child or custodial

parents. States set their own standards of proof

for demonstrating good cause, ranging from

personal testimony to court documents proving

the risk of harm to the child or custodial parent.

Good cause is frequently determined during

the initial application period or soon thereafter,

but can be assessed at any point during program

participation. An exemption from the coopera-

tion requirement can be determined at any point

by the assistance agency or the child support

agency. If applicants or recipients do not cooper-

ate, they are notied of their noncooperation

status, and they have an opportunity to cooper-

ate or be determined exempt for good cause.

Sanctions for noncooperation with child support

depend on the type of assistance program and the

state’s policy choices. For example, the sanction

for SNAP recipients is typically a reduction in

the overall household SNAP benet, whereas

the sanction for child care subsidy recipients is

typically the loss of the entire benet. In addi-

tion, the duration of the sanction may vary from

a minimum of one month to as long as 10 years.

If the recipient begins to cooperate with child

support, the child support agency modies the

cooperation status. Recipients may have their

benets automatically reinstated or they may have

to reapply. Once recipients no longer receive assis-

tance, they are no longer required to cooperate

with child support. However, the child support

program will continue to collect child support on

behalf of the children unless the custodial parent

asks the program to close the child support case.

is overview of the cooperation process is

based on a single program, but low-income

families often participate in more than one

public benet program and therefore may face

multiple cooperation requirements. is adds

layers of complexity for the administering agen-

cies and for families subject to these require-

ments, especially when the cooperation policies,

processes, and data systems vary by program.

For example, a state’s TANF sanction for child

support noncooperation could result in a full-

family sanction (that is, termination of benets

and case closure), whereas SNAP applies a

partial-family sanction for noncooperation (that

is, the non-cooperating individual is removed

from the household, which typically reduces the

household’s overall benet allotment, and the

Automated electronic

interfaces greatly

facilitate the

implementation of

cooperation policies.

remaining household members ma

y continue to

receive SNAP assistance). us, if members of a

household receive benets from more than one

program, they need to understand that the pen-

alty for noncooperation can vary by program and

know how it aects their eligibility and benets

Facilitating the cooperation process

through an automated electronic

interface. Putting cooperation requirements

into practice is a complex endeavor. To facili-

tate referrals and sharing of information, some

states rely on an automated electronic interface

between the child support data system and the

child care program and/or SNAP data systems,

similar to the automated electronic interfaces

that have been developed between state TANF

and child support systems. Some study states

use manual processes to coordinate transmission

of information, some use automated electronic

interfaces, and some use a mix of the two:

• Florida, Kansas, and Michigan have an

automated electronic interface between their

assistance program(s) and the child support

program.

• Mississippi and South Dakota have an auto-

mated electronic interface between the child

support program and SNAP, but not between

the child support and child care subsidy

programs.

• Colorado, North Carolina, and Virginia rely

on a manual process to exchange information.

Although the particular data elements and system

structures vary, automated electronic interfaces

typically enable the assistance program’s eligibility

data system to send nightly batch referrals to the

child support oce, which then alert the child sup-

port oce to open a case and begin engaging with

the parent subject to the cooperation requirement.

When a child support worker makes a change in

cooperation status in the system, the assistance

worker receives an electronic notication of the

change. In some states, such as Kansas, a change in

cooperation status automatically triggers notica-

tions and other case closure actions in the eligibility

system. In other states, child care or SNAP workers

still have to manually change the cooperation status

in the assistance program’s eligibility data system to

trigger notications and case closures. While auto-

mated electronic interfaces are complicated and can

be expensive to design and implement, respondents

from the study states generally agreed that having

an electronic interface provided critical support for

implementing these types of cooperation policies

and is far pref

erable to more time-consuming,

labor-intensive manual processes.

In states and programs without an automated

electronic interface, referrals between programs

required manual processes to communicate

information. One county in Colorado developed

a Microsoft Access database for the child sup-

port and child care programs to share, so that

sta could record interactions with recipients

and track cooperation status. In North Caro-

lina, child care subsidy program sta and child

support program sta use mail, fax, or email

to share information about clients required to

cooperate with child support. In Virginia, child

care subsidy program sta also use mail, fax, or

email to send information to the child support

program; however, for updates on cooperation

status, child care subsidy sta manually access a

web-based computer system that stores informa-

tion across public programs to check the child

support cooperation status of their clients.

KEY POLICY CONSIDERATIONS

In general, states have considerable exibility to

design cooperation requirements. For example,

they can determine who should be subject to the

cooperation requirement, dene the criteria and

standards of proof for good cause exemptions

within parameters set by the federal government,

and determine the penalty for noncompliance

without good cause.

POLICY CONSIDERATION 1: WHO

SHOULD BE SUBJECT TO THE

COOPERATION REQUIREMENT IN

STATE OPTION PROGRAMS AND

WHEN SHOULD COOPERATION BE

ASSESSED?

Eligibility criteria for child care subsidies and

SNAP can inuence how states determine who

should be subject to the cooperation requirement.

Cooperation requirements primarily apply to the

custodial parent (or the person who has physical

custody of the child), but states may also require

the noncustodial parent to cooperate.

In our study sample, child care subsidy programs

do not require noncustodial parents to cooperate

with child support, because child care subsidies

are provided specically to custodial parents.

erefore, noncustodial parents are not referred

States may require

noncustodial parents

to cooperate with child

support but typically

only require coop-

eration of custodial

parents.

to child support unless they are applying for assis-

tance as the custodial parent for another child.

Among the ve study states with a cooperation

requirement for SNAP recipients, three states

include specic policy language that appears to

extend cooperation requirements to noncustodial

parents. In these states, respondents reported

that dening cooperation is challenging but can

include making good faith eorts to provide

child support payments. However, in practice,

it appears these states are focused primarily, if

not exclusively, on successfully implementing

cooperation requirements for custodial parents

in the SNAP household.

e initial assessment of child support coopera-

tion may take place before or after the determina-

tion of an applicant’s eligibility to receive benets.

For example, Mississippi

and North Carolina

require applicants for child care subsidies to verify

cooperation with child support before deter-

mining their eligibility for assistance, whereas

the remaining study states determine whether

the applicants are eligible for assistance before

initiating steps to establish cooperation with child

support. Similarly, South Dakota and Kansas

check child support cooperation status for SNAP

recipients before making a nal determination on

eligibility for assistance, whereas Florida, Michi-

gan, and Mississippi determine SNAP eligibility

before verifying child support cooperation.

Among states that do not determine eligibil-

ity before requiring child support cooperation,

respondents described working with applicants

to encourage them to cooperate with child

support and having application processing

times delayed because they were waiting for the

child support program to verify cooperation.

Child care and SNAP respondents believed the

ability to determine assistance eligibility before

establishing child support cooperation enabled

them to meet program-specic time frames for

processing applications and to connect recipients

to services in a timely manner.

Child support caseworkers assess and note the

recipients’ cooperation status on an ongoing basis.

If an individual stops cooperating with child

support at any point, the child support worker

will notify the child care and/or SNAP worker

directly or through the automated electronic

interface. Programs use this information to apply

a penalty for noncooperation in various ways:

• Sta in child care subsidy programs who

are notied of any changes in a recipient’s

cooperation status may only take steps to

initiate the sanction process at the point of

subsidy recertication, which takes place every

12 or more months.

If the recipient does not

cooperate at that time, and has not demon-

strated good cause for refusal to cooperate, the

child care case is closed for noncooperation.

• For SNAP, a change in cooperation status

prompts the SNAP worker to notify the recipient

that the sanction will be applied if he or she fails

to cooperate with child support, pending a deter-

mination of good cause for refusal to cooperate.

Most states provide a 10-day window from the

time recipients are notied of their noncoopera-

tion status to the time that they must reestablish

cooperation before the sanction is imposed.

POLICY CONSIDERATION 2: UNDER

WHAT CIRCUMSTANCES SHOULD

A PERSON BE EXEMPT FROM

COOPERATION REQUIREMENTS?

Federal law requires states to provide good cause

exemptions from child support cooperation

requirements for all public programs. However,

within federal parameters that take into account

the best interests of the child, states may dene

the specic criteria used to dene what consti-

tutes good cause. Best practices for good cause

determination for TANF recipients have been

identied by federal agencies and domestic

violence advocacy groups (Davies 2000). Such

practices include providing a thorough explana-

tion of child support cooperation requirements,

describing the availability of exemptions and

other safeguards, providing enough time for

recipients to make a decision about proceeding

with child support services, and identifying ways

for recipients to cooperate with child support

without sacricing their safety.

Among the study states, good cause criteria

includes cases in which (1) there is a threat of

harm (including physical, sexual, and mental

harm) to the parent or children, (2) the child

was born because of rape or incest, or (3) there is

a pending adoption proceeding for the child.

States may also decide which agency is respon-

sible for determining whether a good cause claim

is valid. Among the eight study states, agencies

typically shared this responsibility, with eligibil-

Reasons for granting

good cause exemp-

tions typically include

the threat of harm to

the parent or child,

a child born of rape

or incent, or pending

adoption proceedings

for the child.

ity workers determining good cause if a claim

was made before the child support referral and

the child support workers determining good

cause after receiving a referral. Two study states

specically noted that a determination of good

cause exemption granted by any one public

program carries over to all public programs. One

state reported that it uses an Intimate Partner

Violence (IPV) indicator tool to identify if good

cause exists. In another state, state-level sta

meetings were being held to address concerns

that eligibility workers were not communicating

the good cause exemption clearly to recipients.

For the most part, study states aligned their good

cause criteria for child care subsidy and/or SNAP

recipients with those for TANF recipients.

A few study states have gone beyond the good

cause exemption criteria used by their TANF pro-

grams and another state was considering doing so:

• In 2016, Colorado expanded good cause to

include teen parents in response to reports

that the child support cooperation require-

ments created barriers for teen parents in

accessing child care subsidies that could

otherwise help them stay in school.

• North Carolina, which is currently piloting

a new cooperation requirement in its child

care program, created additional good cause

exemption categories designed to reduce

referrals of child care subsidy recipients who

do not need to be connected to child support

services, such as those who already have child

support orders in place or those in house-

holds where the absent parent was deceased

or incarcerated.

• Virginia, like North Carolina, was still in the

early stages of implementing a child support

cooperation requirement for its child care

subsidy program. Respondents expressed

interest in examining how the exibility

to design good cause exemptions could be

leveraged to reduce inappropriate referrals to

child support and thereby reduce unnecessary

burden on the child support program.

POLICY CONSIDERATION 3: WHAT

SHOULD BE THE CONSEQUENCES

FOR NONCOOPERATION?

Study states typically dene cooperation with

child support as (1) completing a child support

intake form that is used to gather information

about the non-custodial parent, and (2) fol-

lowing thr

ough with any activities necessary

for opening and maintaining a child support

case. is includes providing information or

documentation relative to establishing paternity,

identifying and locating the noncustodial parent,

and providing any other information deemed

necessary to establish and enforce the child sup-

port order. For example, the child support agency

could determine that noncooperation exists if the

custodial parent missed scheduled appointments,

did not appear for scheduled court dates, or

otherwise failed to provide requested information

within required time frames.

Penalties for noncooperation are commonly

referred to as sanctions. Sanctions are intended

to encourage cooperation with program require-

ments when recipients might not have cooperated

otherwise. State policy choices related to the treat-

ment of noncooperation include two important

features: type of sanction and sanction duration.

Broadly speaking, there are two types of sanctions:

(1) “full-family” sanctions, which lead to loss of

the entire benet during periods of noncoopera-

tion; and (2) “partial-family” sanctions, which

only disqualify or remove the non-cooperating

individual from the household benet. Sanction

duration refers to the amount of time a sanction

lasts. As highlighted below, states’ approaches to

these critical dimensions of sanction policy often

vary depending on whether the sanctions apply to

the child care subsidy program or to SNAP.

Sanction policy for child support

noncooperation for child care subsidy

recipients

• Type of sanction. For child care subsidy

recipients, noncooperation typically leads to a

full-family sanction that results in the loss of the

child care subsidy. However, the sanction varies

in cases in which the custodial parents receive

child care subsidies for children with dierent

noncustodial parents. For example, in Michigan,

if the custodial parent does not cooperate with

child support, the entire child care subsidy is

terminated. In contrast, Mississippi only termi-

nates the child care subsidy for the children of

the noncustodial parent for whom the custodial

parent is determined to be in noncooperation.

•

Sanction duration. In most study states,

child care subsidy recipients remain ineligible

for assistance until they resume cooperating

with child support. Because of the full-family

State SNAP and child

care subsidy sanction

policies for noncoop-

eration with child sup-

port vary by program.

sanction, families that have been sanctioned

for noncooperation must reapply for services

and verify cooperation with child support

when they do so. Kansas implements a

graduated sanction approach for child care

subsidy recipients, starting with a minimum

ineligibility period of three months that

increases with each repeated incidence of

noncooperation up to 10 years.

Sanction policy for child support

noncooperation for SNAP recipients

• Type of sanction. For SNAP households,

noncooperation with child support typically

results in a partial-family sanction. Non-

cooperating SNAP recipients are removed

from the household benet while the other

members of the household remain eligible

and continue to receive a SNAP benet.

•

Sanction duration. Across study states,

sanctions are closely tied to the period of

noncooperation. Sanctioned SNAP recipients

who re-establish cooperation (“cure” the sanc-

tion) have their SNAP benets reinstated to

the full benet in the next available month

after they begin cooperating. However, states

have the exibility to make sanctions more

stringent. Michigan, for example, requires

that the non-cooperating family member be

removed from the SNAP case for a minimum

of one full month.

CONSIDERATIONS FOR POLICY

AND PRACTICE

Although this study is largely exploratory and

limited to a small subset of states with “at

state-option” cooperation requirements, several

interrelated considerations relevant for policy

and practice emerged from our discussions with

state administrators.

Enhanced automated data systems and

electronic interfaces

. According to state

respondents, having automated data systems sup-

ported the referral of recipients between programs

and the ability to report key program outcomes.

ough such data are critical for understanding

and reporting on the actual or potential impact of

cooperation requirements, most study states did not

have them readily available.

Need for data to inform policy and improve

program management.

Most study states had

limited ability to access data in a format that

allo

wed sta at child support or assistance agen-

cies to estimate the actual or potential impacts

of cooperation requirements. For example,

they could not easily assess the impacts on the

number of referrals, cooperation status, and child

support collections for cases that were referred to

child support by the child care subsidy program

and/or SNAP and were not also participating

in TANF. e lack of federal reporting require-

ments related to cooperation requirements also

reduces the need to have automated data systems

that can run reports on this specic population.

However, this information is important for esti-

mating the extent to which extending coopera-

tion requirements to the state child care subsidy

program and/or SNAP might impact program

outcomes, sta workload, and programs’ ability

to meet federal performance benchmarks.

Limited funding for automated data

systems and electronic interface.

State

respondents emphasized that automated data sys-

tems and electronic interfaces are important for

transmitting information between the assistance

programs and the child support program. ey

noted the signicant system and cost implica-

tions associated with developing, maintaining,

and upgrading existing interfaces. Respondents’

estimates of the cost of updating their data

systems to facilitate an automated electronic

interface ranged from $250,000 to over $1 mil-

lion. To reduce system implementation costs, one

study state coupled system updates with a broader

initiative to align data systems involving dierent

departments and programs. For example, the state

was able to add child care subsidy program and

SNAP interfaces to the data system used by the

TANF program, which already interfaced with

the child support program.

Planning for the implementation of a

cooperation requirement

. Study states with

recent experience (since 2015) implementing

a cooperation requirement in the child care

subsidy program or SNAP emphasized the need

for plenty of lead time and described engaging

in an extensive planning process that focused on

several key areas.

Modifying program-speciﬁc and auto-

mated electronic interface data systems.

States emphasized the need for signicant plan-

ning, involving both policy and technical sta,

to identify and make necessary changes to their

data systems to support communication between

Tips for facilitating implementation of cooperation requirements

• Use available data and create new reporting capabilities that cross public programs and

estimate the potential impact of cooperation requirements on program participation and

outcomes, sta workload, and the programs’ ability to meet performance benchmarks.

•

When possible, reduce costs of coordinated system development and interfaces by

coupling system updates that support implementation of child support cooperation

requirements with broader updates to data systems.

•

To the extent possible, streamline policies and processes with other public programs for

which a cooperation requirement already exists, including good cause.

•

Provide a long design period for planning, developing, and testing system modiﬁcations and

electronic interfaces.

•

Slowly roll out cooperation requirements across the state to avoid system overload with

new cases, and allow for adjustments in stang to absorb increase in sta workload.

progr

ams. Coordinating data systems required

study states to devote time and resources to

updating their data systems, if possible, or to cre-

ate manual processes for sharing data. Even with

substantial planning time for this part of the

process, states still updated and adjusted their

systems to account for real-time feedback during

the initial rollout of cooperation requirements.

Aligning policies and processes. In planning

for implementing new cooperation requirements,

states sought to identify and align policies and

procedures for referral, intake, and ongoing case

monitoring across assistance programs to better

coordinate and streamline the assistance applica-

tion process and the cooperation determination

process. For example, states aligned procedures

by using consistent good cause exemption

categories across programs.

Minimizing burden. States recognized that

implementing a new cooperation requirement

could result in increasing sta workload for all the

involved programs. Child care and/or SNAP sta

need to explain the cooperation requirement to

applicants and recipients, complete the necessary

referral steps, and process sanctions (or good cause

exemptions) as necessary for non-cooperating

recipients. is increases their workload, and for

child support sta, those increases are associated

with having more cases to work as a result of the

cooperation requirement, and with spending more

time communicating with the child care and/or

SNAP program about the cooperation status.

Most states faced the challenge of handling

workload increases with existing sta because

they had little or no funding to hire more sta.

Only o

ne study state—Kansas—provided

additional support to oset the anticipated

increase in workload when it rolled out its

new child care subsidy and SNAP cooperation

requirements. Other states did not have

additional stang resources and had to absorb

the increase in workload, which some states

viewed as a challenge for their already strained

systems. All of these study sites sought to

reduce the initial burden on sta by rolling

out cooperation requirements slowly, either by

focusing on specic regions or by rst requiring

new applicants to cooperate and later expanding

the requirement to current recipients.

DIRECTIONS FOR FUTURE

RESEARCH

is work is an exploratory examination of

child support cooperation requirements in light

of increased interest in broadening their reach

and impact in public programs. At a basic level,

there is no single source of data to track states’

use of cooperation requirements across public

programs. To obtain a more complete picture

of key policy features and continue systematic

tracking of states’ use of these requirements,

future research eorts could compile informa-

tion on the use of child support cooperation

requirements across public programs over time

in a single data source. A database of this type

could also be used to track key policy features

such as cooperation requirements for noncusto-

dial parents, timing of cooperation assessment,

good cause exemption categories and standards

of proof, and sanction policies.

State and f

ederal stakeholders want to know more

about the impacts of cooperation requirements

on each program’s application rates, caseload

size, performance benchmarks, and family and

economic well-being. Both state- and federal-

level stakeholders report that this information

is critical for assessing the costs and benets of

expanding mandatory cooperation requirements.

Across the study states, respondents reported that

they would like to use the data they have available

to try to estimate some of these key outcomes.

However, across the study states, there is a lack of

systematically collected data on child care subsidy

and/or SNAP recipients who are required to

cooperate with child support.

Due to data system limitations and compet-

ing priorities, assessment of outcomes related

to cooperation requirements has been very

minimal. Research using existing integrated

state administrative data or matched data from

child support, child care, and SNAP, could help

answer these pressing policy questions.

Although this study provides a formative

examination of cooperation policies at the state

level, local-level practitioners could provide a

deeper, more nuanced understanding of how

cooperation requirements are implemented in

the eld. Collecting qualitative data at the local-

level could capture variation in implementation

practice across localities (such as urban versus

rural areas) and from caseworker to caseworker.

Moreover, such data could further clarify and

compare cooperation requirement policy and

implementation practice within and across

the SNAP and child care programs. Issues of

interest that could be explored with local-level

practitioners include the use of and challenges

associated with relying on automated electronic

interfaces to support communication between

programs, variation in and best practices for

good cause exemptions, and how sanctions for

noncooperation are applied.

To further inform policy, future research could also

examine the impact of cooperation requirements

by collecting qualitative data from applicants,

current recipients, and former recipients on their

perspectives and experiences with these require-

ments. Such research could examine how appli-

cants learn about cooperation requirements and

how this information inuenced their decision to

participate in child care and/or SNAP. In addition,

speaking with individuals about their decision

to cooperate would shed light on how recipients

from dierent programs weigh the advantages and

drawbacks of cooperation with child support and

the extent to which they feel child support services

increase their family’s economic well-being.

Child support cooperation

requirements: building the

knowledge base

To better inform policy discussion and

development on the use of child support

cooperation requirements, additional

data collection and research is needed to:

• create and maintain a single data

tracking source to compile informa-

tion on the use of child support coop-

eration requirements across public

programs over time;

•

draw from existing integrated state

administrative data or match state

administrative data from child sup-

port, child care, and SNAP to learn

more about the impact of coopera-

tion requirements across multiple

programs on child support outcomes,

SNAP or child care subsidy participa-

tion, and family well-being;

•

examine how cooperation require-

ments across multiple programs are

implemented at the state and local

level, including variation in case-

worker practice, use of and challenges

associated with automated electronic

interfaces, enforcement of sanctions

for noncooperation and best practices

for good cause exemptions;

•

explore how applicants and recipients

of public programs learn about coop-

eration requirements, the trade-os

these requirements present for families,

and whether the cooperation require-

ment inﬂuenced participation in SNAP,

child care and other public programs.

REFERENCES

Davies, Jill. “Recommendations for Training

TANF and Child Support Enforcement Sta

About Domestic Violence.” Welfare and Domestic

Violence Technical Assistance Initiative.

Developed by the National Resource Center on

Domestic Violence, Building Comprehensive

Solutions to Domestic Violence Initiative, 2000.

Available at https://vawnet.org/sites/default/les/

materials/les/2016-09/WELprac3.pdf. Accessed

October 3, 2018.

Doar, Robert. “Reinvigorating Child Support

Enforcement as an Anti-Poverty Program.”

Washington, DC: American Enterprise Institute,

April 2016. Available at http://www.aei.org/

publication/reinvigorating-child-support-

enforcement-as-an-anti-poverty-program/.

Accessed October 2, 2018.

Executive Order no.13828. “Reducing Poverty in

America by Promoting Economic Mobility and

Upward Mobility.” 83 FR 15941, April 10, 2018.

Available at https://www.federalregister.gov/

documents/2018/04/13/2018-07874/reducing-

poverty-in-america-by-promoting-opportunity-

and-economic-mobility. Accessed October 3, 2018.

Roberts, Paula. “Child Support Cooperation

Requirements and Public Benets Programs: An

Overview of Issues and Recommendations for

Change.” Washington, DC: Center for Law and

Social Policy, November 2005. Available at https://

www.clasp.org/sites/default/les/public/resources-

and-publications/les/0252.pdf. Accessed

October 2, 2018.

e White House. “Executive Order Reducing

Poverty in America by Promoting Opportunity and

Economic Mobility.” April 10, 2018. Available at

https://www.whitehouse.gov/presidential-actions/

executive-order-reducing-poverty-america-

promoting-opportunity-economic-mobility/.

Accessed October 2, 2018.

U.S. Congress. “Agriculture and Nutrition Act

of 2018.” H.R. 2. 115th Congress. April 12,

2018. Available at https://agriculture.house.gov/

uploadedles/agriculture_and_nutrition_act_

of_2018.pdf. Accessed October 2, 2018.

U.S. Department of Health and Human Services

(HHS). “Case Worker Desk Card: Safely Pursuing

Child Support.” HHS, Administration for

Children and Families, Oce of Child Support

Enforcement. April 17, 2012. Available at https://

www.acf.hhs.gov/css/resource/safely-pursuing-

child-support-desk-card. Accessed October 3,

2018.

ENDNOTES

Before PRWORA provided states the option to

apply a child support cooperation requirement on

SNAP recipients, states could (and still may) elect

to remove individuals from their household SNAP

benet if they fail to perform actions required by

certain federal, state, or local means-tested public

assistance programs. is is known as a “compa-

rable disqualication”. Our study focuses on states

that impose a specic cooperation requirement

for SNAP recipients, and not on those that use

comparable disqualications.

Recent eorts to reauthorize the Agricultural

Act of 2014 (also known as “e Farm Bill”)

included a provision approved by the U.S. House

of Representatives (H.R. 2) to remove the state

option to require cooperation of SNAP recipients

and make cooperation with child support manda-

tory for both custodial and noncustodial parents. In

contrast, the Senate-passed version of the Farm Bill

(S.3042) did not include a mandatory child support

cooperation requirement for SNAP recipients.

As of this writing, the Farm Bill lapsed because

Congress was unable to reach a consensus before

the reauthorization deadline.

Maine is included in the count of states that

require child support cooperation for SNAP

recipients because it requires noncustodial parents

who have child support orders to cooperate with

child support as a condition of receiving SNAP,

even though they do not require custodial parent

SNAP recipients to cooperate with child sup-

port. Although Virginia law requires the referral

of SNAP applicants to child support, it is not

included in the count of states that have child sup-

port cooperation requirements for SNAP recipients

because the law does not require cooperation with

child support as a condition of SNAP eligibility.

South Dakota and Maine established coopera-

tion requirements for SNAP participants for the

rst time since 2015. However, both states have

cooperation requirements for child care subsidy

recipients that predate their SNAP cooperation

requirements.

In 2017, North Carolina passed a bill to pilot

cooperation requirements for child care subsidy

recipients in three to six counties. Beginning in

February 2018, North Carolina implemented

cooperation requirements in three counties. e

pilot lasts through December 2018. In March 2019,

the Division of Child Development and Early

Education and the Division of Social Services will

report to the Joint Legislative Oversight Commit-

tee on Health and Human Services and the Fiscal

Research Division on the outcomes of the pilot,

including costs and recommendations or challenges

sustaining cooperation requirements long term.

Mathematica

is a registered trademark of Mathematica Policy Research, Inc.

Scan this QR code

to visit our website.

Mississippi has an electronic interface between

the child support system and the SNAP program,

allowing a determination of SNAP eligibility

without verication of child support cooperation.

However, there is no interface between the child

care system and the child support system, which

is why applicants must contact the child support

oce to obtain verication of cooperation.

e Child Care and Development Block Grant

Act of 2014 established requirements designed to

provide more stability for families receiving child

care subsidies, including a federal-level policy

requiring eligibility redetermination periods of a

minimum of 12 months—essentially providing

continuous eligibility for families for a minimum of

12 months so long as their income does not exceed

the federal income threshold and they do not expe-

rience a non-temporary change in work, education,

or training that aects eligibility. In contrast, states

previously had the authority to set redetermination

periods and almost half used a six-month period.

Across study sites, caseworkers were trained to not

consider custodial parents to be non-cooperative if

they truly lacked information on the noncustodial

parent that was needed by the child support agency.

For noncustodial parents, criteria used to determine

noncompliance did not include an inability to pay

child support or owing back child support.

Acknowledgments

The authors wish to express

their appreciation to all those

who contributed to this project,

including administrators and

other sta from the child sup-

port, child care, and SNAP agen-

cies in the eight study states

and representatives from the

Administration for Children and

Families’ Oce of Child Support

Enforcement, the Administration

for Children and Families’ Oce

of Child Care, and the Depart-

ment of Agriculture’s Food and

Nutrition Service. We would

also like to thank Robert Doar

from the American Enterprise

Institute, Rodney Hopkins from

the University of Utah, Meghan

McCann from the National Con-

ference of State Legislatures,

and Diane Potts, President of the

National Child Support Enforce-

ment Association 2017-2018,

for their valuable assistance and

insights. Finally, we thank the

Oce of the Assistant Secretary

for Planning and Evaluation at

the U.S. Department of Health

and Human Services for its sup-

port of the EMPOWERED project

and we are especially grateful

for the thoughtful guidance

provided by Lauren Antelo, our

Federal Project Ocer.

This report was prepared under

contract #HHSP233201500035I

/ HHSP23337027T. The opinions

and views expressed in this

report are those of the authors.

They do not necessarily reﬂect

the views of the Department of

Health and Human Services, the

contractor or any other funding

organization.

Overview of child support cooperation data sources

Data collection for this exploratory study of child support cooperation requirements was

conducted between December 2017 and June 2018 and included semi-structured discus-

sions with federal and state-level stakeholders and a scan of publicly available databases on

state-level child support cooperation legislation and policy. When possible, we triangulated

data across sources.

The scan relied on three main data sources to identify the current status of states adoption

of the cooperation requirements in SNAP and federally-funded child care programs:

• The National Conference of State Legislatures (NCSL) Child Support and Family Law

Legislation Database, which covers passed, pending and failed legislation from 2012-

2018 (http://www.ncsl.org/research/human-services/child-support-and-family-law-

database.aspx)

• The CCDF Policies Database, which includes child care subsidy policies for the 50 states,

the District of Columbia, and the US territories and outlying areas from 2009 through

2015 (https://www.researchconnections.org/childcare/studies/36581)

• USDA State Options Reports, the compilation of results of state surveys conducted by

the Food and Nutrition Service on the use of various SNAP policy options from 2002

through 2018 (https://www.fns.usda.gov/snap/state-options-report)

In addition to these resources, we used information collected as part of a survey of IV-D

child support directors conducted by The National Council of Child Support Directors in

May 2018 to conﬁrm information collected through our scan. The results of this survey are

not publicly available.

Discussions with federal stakeholders included representatives from the Administration for

Children and Families’ Oce of Child Support Enforcement, the Administration for Children

and Families’ Oce of Child Care, and the Department of Agriculture’s Food and Nutrition

Service. To gain more insight into state-level policies, telephone discussions were conduct-

ed with IV-D child support directors and SNAP and/or child care subsidy program sta in

eight states: Colorado, Florida, Kansas, Michigan, Mississippi, North Carolina, South Dakota,

and Virginia. (We also conducted an interview with one county administrator.) These states

were selected because they provided variety in which programs had the cooperation re-

quirement (that is, SNAP-only, child care-only, or both), had cooperation requirements that

had been in eect for diering lengths of time, and represented a mix of county-adminis-

tered and state-administered child support systems.

All discussions were held with state-level administrators except in Colorado, where discus-

sion included a county-administrator as well. Further insights into state experiences with

child support cooperation requirements for child care subsidy recipients and SNAP partici-

pants were obtained through a meeting convened for this purpose at the National Child

Support Enforcement Association Policy Forum in February 2018.