To Close or Not to Close Federal State

To Close or Not to Close – Federal & State Perspective on Case Closure Donna Buchanan Program Consultant, Policy & Training North Carolina Child Support Services Pam Sala Chief Asst. FOC Operations Oakland County Michigan 1 ERICSA 50 th Annual Training Conference & Exposition ▪ May 19 – 23 ▪ Hilton Orlando Lake Buena Vista, Florida

45 CFR Ch. III, 303. 11 CASE CLOSURE CRITERIA • No longer a current support order & arrearages are under $500; • NCP is deceased and no further action can be taken; 2

Paternity cannot be established because: • Child is at least 18 years old; • No other putative father identified; • Not in best interests of child to establish paternity; and • Identity of the biological father is unknown. 3

NCP's location is unknown & efforts to locate have been unsuccessful: • Over a three-year period when there is sufficient information to initiate automated locate, or • Over a one-year period when there is not sufficient information to initiate automated locate. 4

NCP cannot pay support for duration of child's minority: • Institutionalized in psychiatric facility; • Is incarcerated with no chance for parole; • Medically verified total & permanent disability with no evidence of support potential; and • No income or assets available to NCP. 5

NCP is citizen of (& lives in) a foreign country & • Does not work for Federal govt. or company with headquarters or offices in United States; • Has no reachable domestic income or assets; and • State has been unable to establish reciprocity with country. 6

• IV-D provided location-only services. • NPA recipient requests case closure and there is no assignment to State of medical support or of arrearages which accrued under a support order; • Finding of good cause to not co-operate with IV-D; 7

In NPA case - • IV-D unable to contact recipient within 60 day period despite attempt of at least one letter sent first class mail to last known address; • Recipient not cooperative & action by recipient is essential for next step; 8

• Responding State documents failure by Initiating State to take action essential for next step; • Initiating State notifies Responding State of closure; and • Initiating State notifies Responding State services no longer needed. 9

60 Days Prior to Closure Notification EXCEPT • Locate Only Cases; • NPA recipient requests closure; • Good Cause. 10

Assistance with Collections on Closed Initiating Cases • IF initiating state fails to tell responding state of closure & collections are received: – Initiating state reopens case; – Locates recipient; and – Processes collections. 11

Statewide Clean-up Efforts • Duplicate Case Closure • Interstate Case Reconciliation Project • Reason code 04 – The case is open as a Michigan interstate case, but the interstate case in the other state is closed.

Issues Identifed • Incorrect closure reason codes being used • One closure code to mean multiple things • Statewide system preventing activities from being closed

System Improvements Needed • Deceased NCP’s – currently wait 3 years before closure regardless of assets • No payment in 10 years – • Open activity chains that can’t be closed • Non-IV-D Cases • Multiple IV-D Cases attached to One Docket

Improper Reason Codes Selected • Trying to fit a square peg in a round hole • Closing cases to improve incentives; but case doesn’t meet federal requirements for closure

Case Closure in Oakland County • Entire office trained on what to look for to make sure cases close correctly • What fields in statewide system must be completed • Monthly list of cases eligible for closure • 4 staff review

Case Closure & Interstate Cases • To close or not to close; especially in the world of interstate • • • Child emancipates but still has case with arrears NCP’s address becomes bad CP doesn’t cooperate with state NCP indicates he is living with the CP What problems have you encountered?

Questions ? ? ?

Contact Information Donna Buchanan donna. buchanan@dhhs. nc. gov (919) 855 -4433 Pam Sala salap@oakgov. com (248) 858 -0422