Policy & Practice | Winter 2024

The historically narrow view of the (child support) program as solely a collection and enforcement mechanism has hindered its ability to generate lasting social and economic impacts at the root level. On the other hand, states and counties are ready for change and eager to reimagine a whole family approach to child support that is fully integrated across the human services ecosystem.

child support payment up to $100 per month for a household with one child or $200 per month for a household with two or more children. If a state allows a pass-through to the TANF recipient in excess of this amount, it must pay out of its own pocket to reimburse the federal government for its due share. Recent research 5 has shown that child support pass-throughs can sig nificantly reduce child poverty as well as increase payment rates and levels 6 from noncustodial parents. By lifting the $100/$200 limit for waiving federal reimbursement of child support pass-throughs, Congress would make it more financially feasible for states to implement such policies. Federal Policy Strategy 3: Align Employment and Training Opportunities for Noncustodial Parents Through waivers, IV-D incentive funds, and collaborations with other workforce partners, at least 25 states currently provide 7 employment and training (E&T) services for noncus todial parents in their child support program. These efforts have an oppor tunity to be brought to far greater scale by expanding work supports for noncustodial parents through a proposed rulemaking 8 that allows for federal financial participation via IV-D child support funding for noncusto dial parents. With the potential for a dedicated E&T funding stream in child support on the horizon, the federal government can help integrate this new resource into the broader continuum of work force development services. Such programs as the Workforce Innovation and Opportunity Act, TANF, and SNAP E&T have long worked to build shared infrastructure for offering comprehen sive and integrated workforce services. In early efforts to expand a robust set of services that help noncustodial parents with the tools they need to economi cally support their families, federal cross-programmatic efforts to align technical assistance, financing, and guidance will be key to fostering system

strategies can help create the enabling conditions for continued progress in re-centering state and local child support collaborations with other human services program areas. This is in service of improving long-term outcomes that bolster family stability and mobility, foster systems change with and for families, include diverse family structures, and adapt to changing family circumstances. Federal Policy Strategy 1: Release Guidance on Best Practices in Child Support Cooperation Requirements Child support cooperation require ments mandate that parents cooperate with their child support agency as a condition of receiving government benefits. Many federal benefits, including SNAP, Medicaid, and child care subsidies, provide states with flexibility about whether to establish cooperation requirements as a condi tion of participation, how to establish good cause from the requirement, and whether to apply the requirement to custodial, noncustodial parents, or both. In other programs, such as TANF, child support cooperation is a federal requirement, though states have discretion as to how they exempt participants due to good cause. Earlier this year, the U.S. Department of Agriculture released guidance 3 to SNAP grantees, sharing the lack of strong evidence that such requirements result in positive

outcomes, outlining expectations for evaluating for good cause when states select this policy option, and outlining mandated coordination with child support agencies when coop eration requirements are imposed. This type of proactive engagement of states reflects a promising approach to encourage collaboration with child support agencies and to critically revisit long-standing cooperation rules. Similar, coordinated efforts that speak consistently to states across federal benefits can help prompt thoughtful reexamination of when and how child support cooperation requirements are applied. Federal Policy Strategy 2: Eliminate Federal Share of Retained Collections forTANF Recipients to Encourage Full Pass-Throughs TANF recipients with child support orders must assign their rights to child support payments to their state TANF agency, which uses that money to reimburse itself and the federal government for TANF assistance. However, approximately half of states 4 allow some or all of the child support payment to be passed through to the TANF recipient and be disregarded as income when determining TANF eli gibility and benefit level. When states choose this option, federal law allows them to exempt reimbursing the federal government for its share of the

See APHSA Insights on page 36

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Winter 2024 Policy & Practice