Employer Symposium Report
THE OFFICE OF CHILD SUPPORT ENFORCEMENT
and
THE NATIONAL CHILD SUPPORT ENFORCEMENT ASSOCIATION
Employer Symposium:
A Partnership That Works
REPORT
DECEMBER 2005
Employer Symposium Report
Table of Contents
Introduction 3
Issues and Recommendations 6
Communication Methods 7
Electronic Income Withholding Orders (eIWOs) 8
Electronic Payments 9
Federal Employer Identification Numbers (FEINs) 10
Income Withholding Orders 11
Lump Sum Payments 12
Medical Support 14
New Hire Reporting 15
Privacy Concerns 16
Verification of Employment (VOE) 17
Appendix A - Topics Grid 19
Employer Symposium Report
introduction
Purpose
The Child Support Enforcement (CSE) Program was created in July 1975. Over the years, the program has seen many changes and grown significantly. The program is operated by states in partnership with the Federal Office of Child Support Enforcement and numerous other partners. A key partner in the program is the nation’s community of 6.6 million employers, many of whom conduct such vital functions as reporting newly-hired employees, implementing child and medical support orders, and remitting child support payments.
The Employer Symposium was borne of a joint decision of the Federal Office of Child Support Enforcement (OCSE) and the National Child Support Enforcement Association (NCSEA) to reach out to the employer community on child support matters. The Symposium was designed and developed to recognize the importance of the employers to the program and to provide a common forum for the state child support enforcement agencies and the employer communities (with other partners from the judicial and payroll provider communities) to meet face-to-face and discuss ways to improve the operations of this multi-faceted program. The specific goals of the Symposium were to identify and discuss issues of mutual importance to these communities and to develop short- and long-term recommendations for solutions for these issues.
Background
The Employer Symposium was held on August 4-5, 2005 in Cincinnati, Ohio. It followed NCSEA’s 54th Annual Training Conference, which featured several employer-related workshops.
OCSE and NCSEA entrusted the development of the Symposium to a Planning Committee comprising a critical mix of representatives from employers, state CSE programs, OCSE and NCSEA. The Committee identified the areas where problems were regularly noted by employers and states and further refined these areas by creating specific questions designed to ensure focused discussions. The result was a document entitled “The Topics Grid” (attached), which proved to be an effective means of engaging Symposium participants in several hours of discussion.
Format
The Symposium was a mix of plenaries and small group discussions. The first plenary featured a skit entitled “A Day in the Life of a Partnership That Works.” It described a day in the life of child support caseworkers and payroll professionals as they worked through the complexities of child support cases. It described how workers’ responsibilities have increased over time. The plenary was an effective vehicle for highlighting the history of the CSE program and its many changes over the last 30 years. The second plenary showcased the electronic income withholding pilot project, a new initiative led by OCSE involving several states and employers. The participating states and employers (private and public) described their successful experiences exchanging information electronically.
Following the plenaries, in small groups of 14 and 15, employers and child support professionals discussed important topics, such as electronic payments, income withholding, verification of employment, new hire reporting, lump sum payments, standardization, terminations and medical support. These facilitator-led discussion groups shared information and ideas, and short- and long-term recommendations for improving the program.
Participants
A total of 147 individuals participated in the Symposium including:
§ State Child Support Enforcement personnel - State IV-D Directors; Deputy Directors; Program Administrators; Section and Operation Chiefs; Employer Liaisons; Attorneys; Employer Services Managers; and Technical Assistance Advisors.
§Employer personnel - Payroll Managers, Supervisors, and Associates; Project Managers; Business Systems Analysts; Senior Vice Presidents; Garnishment Coordinators/Analysts; Software Development Managers; and Accountants.
§Federal Child Support Enforcement personnel - the Commissioner of the Office of Child Support Enforcement; Associate Commissioner; Division Directors; Senior Quantitative Analysts; Employer Services Team members; Policy Program Specialists; Policy and Automation Liaisons; Technical Assistance Liaisons; and System Analysts.
§Judicial personnel - Court Directors; Hearing Officers; and Judges.
Issues and Participant Recommendations
This report captures major topics discussed in the section entitled “Issues and Recommendations.” It also includes a summary of participant recommendations to address many of them. The recommendations captured in this report reflect the desires of those who participated in the 10 diverse discussion groups. They do not necessarily reflect the positions of OCSE or NCSEA.
OCSE will post this report on its Employer Services website where readers may provide feedback on it. NCSEA will post the report on its website as well.
Conclusion
At the Symposium, many participants reported that they had gained practical and useful information that they planned to implement at their offices. The exchange alone generated much enthusiasm. However, more can be done as noted in this report. OCSE intends to refer several issues to some existing workgroups for their examination while others will be addressed as part of the effort to modernize the Federal Parent Locator Service (FPLS). NCSEA, through its policy and government relations committees, will work with OCSE and employers to assist in these efforts. Employers will continue to work in partnership with the states, OCSE and NCSEA to provide feedback and guidance as strategies are developed to address these issues. It is hoped that the contents of this report may suggest a number of ways to increase the effectiveness and efficiency of the CSE program.
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Employer Symposium Report
Issues and Recommendations
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Employer Symposium Report
Communication Methods
Background
Employers play an essential role in the CSE program. They report new hires, enroll children in medical plans, and withhold and remit payments.
The communications between child support enforcement agencies and employers has not, in every case, kept pace with the demand necessary to support the continued need for information by employers from the child support program.
Issues
Employers and CSE agencies recognize the critical nature of good communications to continue the increased collection of child support for children. However, because of the volume of customer service calls and a frequent lack of resources (funds and staff) at the state level, communication efforts are not always sufficient to meet the ongoing needs.
· At times when employers are facing payroll processing deadlines, they need to contact a child support worker and get a prompt response to an issue (e.g., the payment of a bonus or some other lump sum payment). However, they may not always know whom to contact and they don’t always get a reply in a timely fashion.
· Employers need continuing education and outreach on new and changing child support policies.
· Not all state child support websites include important information that employers need, and few states offer web reporting of new hires.
· Some employers use third parties (i.e., payroll service companies and companies that provide verification of income services to employers) to handle their new hire reporting, child support payments and other processes. States may not be aware when employers have outsourced tasks to a third party.
Participant Recommendations
Participants provided a number of recommendations for possible short- and long-term solutions to communications issues. For example, they suggested that states train specific staff to serve as employer contacts who would be able to access case-specific information and provide immediate answers to employers’ questions and that states develop interactive websites that would enable employers to ask questions, access forms and upload information.
Participants also recommended that states improve their outreach efforts to employers and employer associations and provide ongoing training and communication on child support issues. For example, child support staff should speak at local American Payroll Association (APA) conferences and training sessions and the APA should disseminate child support information in its newsletters.
Finally, they recommended that universities, community colleges and other school systems include curricula to educate the public, including employers, about child support requirements.
Electronic Income-Withholding Orders
Background
In 2004, the Federal Office of Child Support Enforcement (OCSE), in partnership with states and public and private-sector employers, developed an electronic format for the income-withholding order (IWO). In 2005, several states and employers began exchanging Electronic Income-Withholding Order (eIWO) information in the pilot project.
Electronic transmission of income-withholding orders increases processing efficiency and improves the speed with which payments are made to families by:
· Reducing the time from IWO preparation to employer processing,
· Reducing errors that can occur through manual processing,
· Reducing cost of postage and processing paper documents, and
· Providing an on-going communications link between CSE agencies and employers should additional actions be necessary.
Issues
The Electronic Income-Withholding Order (eIWO) pilot project gained a great deal of support, and employers and states look forward to the progress of this project. Some concerns voiced at the Symposium included:
· States and employers may lack resources and/or funding to implement the technological requirements of the eIWO.
· Some states say they may require legislative changes in order to implement the eIWO (such as service of process).
· Employers are concerned about having to retrieve eIWO forms from 54 states and territories.
· Because employers may report two different Federal Employer Identification Numbers (FEINs) – one for New Hire reporting and one for Quarterly Wage reporting – state employer tables and FEINs may not be in sync. Therefore, states may be sending eIWOs to the incorrect employer location.
· States are concerned that the eIWO may not satisfy the requirement that a copy of the IWO be provided to the noncustodial parent (NCP) and inserted in the court file.
Participant Recommendations
Participants provided a number of possible short- and long-term solutions to the eIWO issues and these recommendations will be forwarded to the existing eIWO workgroup for its review. This workgroup consists of representatives from the states, employers and Federal OCSE staff. Specifically, the workgroup should explore the feasibility of standardizing functionality so that there can be a uniform eIWO. It should also explore the creation of a single web portal for the receipt of eIWOs and the exchange of other related information.
Further, participants felt that the benefits of the eIWO should be marketed to state child support agencies and employers using such venues as the American Payroll Association Annual Congress as well as the OCSE website, and various child support conferences.
Electronic Payments
Background
All state child support agencies (except California and South Carolina) offer payment by Electronic Funds Transfer (EFT)/Electronic Data Interchange (EDI), the primary method of sending payments electronically. The EDI portion of the transmission includes identifying information so that the payment can be properly credited to the payor's case. Employers and state agencies that switch to electronic payments will realize lower costs, fewer errors, and faster processing.
· Large employers can save time and money by sending their child support payments electronically. E-payments eliminate many processing costs, are largely error-free, and get money to children and families faster. Many large employers have experienced substantial savings by converting to e-payments for child support.
· Small-to-mid-sized employers have realized savings by submitting their child support payments to the 16 state and county web sites now accepting e-payments for child support.
Issues
· Employers need correct contact information for state child support agencies for EFT/EDI remittance.
· Some employers don’t remit their payments electronically because of the requirement to include case information in an EDI format (child support addendum segment).
· Some employers don’t remit payments electronically because of the fees they must pay to their banks.
· Both employers and child support agencies need to review how to expand use of e-payments.
· Need uniform identification of file edits for e-payments.
Participant Recommendations
Participants recommended that OCSE continue to maintain its EFT/EDI matrix of contact information and, if possible, it should identify secondary EFT/EDI contacts in each state. Further, they recommended that states, OCSE, and employer groups should continue their outreach efforts to promote the benefits and cost-effectiveness of e-payments.
Participants would also like to see banks lower their fees for EFT/EDI and to assist small businesses that are interested in converting to e-payments for child support.
Federal Employer Identification Numbers
Background
In many instances states identify employers by their Federal Employer Identification Number (FEIN). The FEIN is the key to processing information from the Federal Parent Locator Service (FPLS) to issue IWOs, and it is used as an identifier for incoming EFT payments. The FEIN is one of the most reliable data elements for identifying an employer.
Many states have employer tables on their systems, and staff work diligently to maintain employer address accuracy and eliminate duplicate addresses. Nevertheless, state employer tables are often prone to duplication and erroneous entries. One of the reasons for this problem is that some employers have multiple addresses and FEINs that are difficult to reconcile. Some states reported that they have employers with no FEINs.
Issues
· State CSE agencies report that the use of multiple FEINs by employers causes states to send the IWOs and National Medical Support Notices (NMSNs) to incorrect addresses.
· Employers use multiple FEINs (for new hire and quarterly wage reporting) which cause states to send multiple verifications of employment (VOEs).
· Some states’ systems do not allow for multiple employer addresses. These states have difficulty maintaining multiple addresses for employers and therefore may not know where to send IWOs, NMSNs, service of process or other forms.
Participant Recommendations
Participants would like to explore mechanisms that would allow state CSE agencies to synchronize information in their employer tables with federal FEIN tables. OCSE, through its effort to improve employment information in the National Directory of New Hires, will explore further FEIN issues.
Participants also want employer groups (e.g., the American Payroll Association) to assist them by building and maintaining an on-line matrix with employers’ contact and address information for IWO, medical support and other information.