INFORMATION MEMORANDUM

July 31, 1997

OCSE-IM-97-05

TO:STATE CHILD SUPPORT ENFORCEMENT AGENCIES ADMINISTERING STATE PLANS UNDER TITLE IV-D OF THE SOCIAL SECURITY ACT, AND OTHER INTERESTED PERSONS

SUBJECT:SUMMARIES FROM THE "ONE-STATE" INTERSTATE RETREAT HELD APRIL 14-16, 1997 IN PROVIDENCE, RI

Earlier this year, State Child Support Enforcement (CSE) Agencies and Federal Office of Child Support Enforcement (OCSE) Central Office and Regional staff attended a three-day retreat in Providence, RI, to discuss consensus methods for approaching a special kind of interstate case, the "one-state interstate" case. "One-state interstate" cases are those in which one State has or can claim continuing, exclusive jurisdiction over a case, and therefore has the ability to control its enforcement. That State may ask a second State to collect money, obtain evidence, help with service of process, etc. In some cases activity may occur in the second State without the second State CSE agency's knowledge (e.g., direct income withholding).

What differentiates this type of case from the traditional two-state interstate case is that in "one-state interstate" case-processing the second State CSE agency activity is limited by the scope of the first State CSE agency's request, or alternatively, the first State bypasses the second State CSE agency and conducts activity in the second State in furtherance of the first State's case-processing.

The retreat, sponsored by OCSE, was intended to see whether consensus could be met on various issues surrounding the implementation of provisions relating to interstate liens, administrative enforcement, direct withholding, interstate administrative subpoenas and other discovery, and long-arm jurisdiction and service of process. Much progress was made, and OCSE is pleased to share the attached results of the breakout brainstorming sessions. A follow-up retreat is scheduled for October 28-30 in Albuquerque, NM, in which all interstate issues will be discussed.

For more information about the October 1997 Albuquerque Interstate Retreat, please contact: Dianne Offett, Interstate Liaison, 370 L'Enfant Promenade, SW,4th Floor, Washington, DC 20447 (202) 401-5425. For information regarding these notes for the One-state Interstate Retreat, please contact Jeff Ball at the above address or call him at: (202) 401-5427.

________________________________
David Gray Ross
Deputy Director
Office of Child Support Enforcement

ONE-STATE INTERSTATE RETREAT NOTES

Providence, RI

April 14-16, 1997

Purpose of the Retreat and Definitions:

The "One-State Interstate Retreat" provided a forum for thorough discussions about the interpretation and interrelation of various provisions of law that affect nontraditional interstate case processing, and which resulted in a set of papers that give initial, nonbinding guidance to decision-makers about the appropriate handling of these cases.

The term "one-state interstate" refers to an increasingly-prevalent type of case in which one State agency reaches out to accomplish a child support activity in a second State, either without that second State’s child support agency knowledge, with knowledge and no assistance, or with limited assistance from the second State. In other words, the retreat focused on cases in which the second State agency has no or limited secondary responsibilities for a case that is controlled by the first State. This may include direct or assisted child support enforcement activities in the second State, or serving process and obtaining evidence.

Retreat Concept:

The planners wanted a retreat modeled after the UIFSA Fairfax retreats of 1994 and 1996. In those retreats, after descriptive plenaries on the subject matters, participants broke out into subgroups to tackle in-depth one specific part of the puzzle, and to come up with best practices and recommended approaches or interpretation based on any consensus in the absence of any federal statute or regulation. The subgroups would report out, obtain feedback from everyone else, and refine their work. The recommendations contained in a short report generated after the retreat would be made widely available to child support practitioners interested in the topic. The one-state interstate retreat followed this model, and the papers that follow reflect the subgroups’ work.

The Subgroups:

Four topic areas were identified for detailed scrutiny:

1) direct income withholding under sections 501-506 of the Uniform Interstate Family Support Act (1996 version);

2) administrative enforcement, under section 323 of the PRWORA;

3) interstate lien implementation, under sections 368 and 324 of PRWORA; and, 4) administrative subpoenas under PRWORA section 324 and long-arm service of process, electronic hearings and evidence, and two-state discovery under sections 201-202, and 316-318 of UIFSA.

The Papers:

The four subgroup papers that follow the plenary summary represent the consensus opinions of those who attended each of the subgroups. They were drafted by the content leads andfacilitators for each subgroup and reviewed by each subgroup. For the most part, there was unanimity in interpretation and recommendation, but occasionally there was some disagreement. These papers do not necessarily reflect official Federal opinion, and are not binding on the States.

Please note that participants at the first one-state interstate retreat and any other interested persons are invited to a second round of review of these issues this fall, in combination with the UIFSA retreat. This combined retreat will be known as the Interstate Retreat, and will be held October 28-30 in Albuquerque, NM. For more information about the Interstate Retreat, please contact Dianne Offett, OCSE Interstate Liaison, at (202) 401-5425.

Thanks

Thanks to all the attendees and other advisors who helped make the retreat a success. Preliminary planning was done by:

ACF/CSE Regional Offices

Stan Gardner

Carol Monteiro

Chuck Kenher

Dennis Minkler

JP Soden

Vince Herberholt

OCSE Central Office

Dianne Offett

Steve Cesar

Verdell Fields

Jeff Ball

ONE-STATE INTERSTATE RETREAT BREAKOUTS/LEADERS

Interstate Liens

Content Lead: Dan Phillips, NJ

Facilitator: Naomi Rodriguez, OR

Recorder: Jens Feck, OCSE Reg II

This breakout examined the implementation of the provision of the law that requires liens to arise by operation of law and which are to be given full faith and credit in a second state.

Direct Withholding

Content Lead: Dianne Offett, OCSE CO

Facilitator: Susie Becker, Colorado

Recorder: Hope Butler, OCSE CO

This group looked at the three years of implementation of direct withholding in UIFSA States, and how outstanding issues may or may not be resolved through the use of the mandated income withholding form and choice of law changes in UIFSA 1996.

Administrative Enforcement

Content Lead: Janet Wallace, WA

Facilitator: Tom Leeds, NV

Recorder: Chuck Kenher, OCSE Reg I

Administrative enforcement under PROWORA is new to every State. This group reviewed what is required by the statute and how the process ideally should work.

Administrative Subpoena, Long-arm Jurisdiction and Interstate Discovery and Testimony

Content Lead: Steve Cesar, OCSE CO

Facilitator: Sharon Santilli, RI

Recorder: Carol Monteiro, Reg I

This breakout focused on the new administrative subpoena and its interstate use, protocols for service of process in long-arm cases, and conducting interstate discovery and telephonic/videoconferencing hearings using UIFSA provisions.

ADMINISTRATIVE ENFORCEMENT IN INTERSTATE CASES

NOTE THAT THE FOLLOWING DISCUSSION IS BASED ON THE AUGUST 22, 1996 PRWORA VERSION OF ADMINISTRATIVE ENFORCEMENT. TECHNICAL AMENDMENTS PASSED BY CONGRESS IN JULY 1997, ONCE SIGNED BY THE PRESIDENT, ALTERS THE LANGUAGE OF THE SECTION, RENDERING SOME, BUT NOT ALL, OF THE FOLLOWING DISCUSSION OBSOLETE (SEE EDITOR'S NOTE BELOW FOR SPECIFIC CHANGES).

Introduction

Section 323 of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) amends Section 466(a) of the Social Security Act to create a new child support enforcement mechanism called "Administrative Enforcement in Interstate Cases."

Administrative Enforcement in Interstate Cases (AEI) is designed to enable child support agencies to quickly locate and obtain assets held by delinquent obligors in another State or jurisdiction. Although various interstate enforcement remedies to collect arrears have been available for years, AEI differs from the way such enforcement is traditionally pursued in several respects:

183AEI is triggered by a request rather than a formal interstate referral from one IV-D jurisdiction to another. The request certifies (1) the amount of the obligor’s debt and (2) that appropriate due process requirements towards the obligor have been met by the requesting State. The request must also contain sufficient identifying information on the delinquent obligor(s) to permit the assisting jurisdiction to conduct automated matches against data bases which could identify assets owned by the obligor.

183AEI is designed to take prompt but limited enforcement action. When assets are uncovered, the assisting IV-D jurisdiction takes steps to seize the obligor’s assets and sends them to the requesting jurisdiction. AEI is not an ongoing or long-term enforcement remedy, but rather "one-shot" or "quick" enforcement action. Prolonged enforcement is handled through conventional "two-State" interstate solutions or, if appropriate, by direct income withholding under UIFSA.

183AEI requests do not constitute formal IV-D interstate case referrals. The assisting jurisdiction does not open a IV-D case in the conventional sense either during the matching phase or, in the event of a "hit," when it seizes and forwards assets to the requesting State. Accordingly, when an AEI action is completed, the assisting State need not meet IV-D caseclosure criteria before "closing" an AEI action.

183Since AEI requests are not IV-D cases, AEI requests, matching activity, and collections are not reported to the Federal Office of Child Support Enforcement as IV-D services (OCSE-156) or collections (OCSE-34 report). A Child Support Agency’s records concerning the number of AEI requests, "hits," and amounts collected must be maintained, but are reported separately to OCSE.

In keeping with its policy of generally limiting regulations to provisions for which regulations are prescribed by law, OCSE is unlikely to issue implementing regulations for the Section 323 requirements. Therefore, States will have to rely primarily on the statutory language to carry out this provision; additional guidance, if necessary, may be forthcoming in OCSE Dear Colleague Letters or other issuances.

NOTE: At this writing a bill containing technical amendments to PRWORA is before Congress, including amendments that affect AEI. The "Welfare Reform Technical Corrections Act of 1997" was passed by the House and awaits Senate action. If the Senate concurs with the House version, the Administrative Enforcement provision will be modified as noted.

Neither the original nor amended statute specifies the manner in which AEI requests are to be submitted, other than to suggest, though not require, that "electronic" means be used to transmit data between States. The statute does, however, require that incoming AEI data be computer matched against "the data bases of the (assisting) State." Among the changes in the House-passed technical amendments is its portrayal of the process as "High Volume Automated Administrative Enforcement in Interstate Cases."

Further, the statute clearly anticipates that when a "hit" occurs and an asset is identified, an enforcement action be taken to collect on the arrears amount on behalf of the requesting State. A recent opinion from the Office of General Counsel (OGC) of the Department of Health and Human Services contained the following interpretation:

Within 5 business days from receiving a referral (electronic means or other format) from another State with the necessary information about the obligor, a receiving State must check the available databases it has for in-State locate to determine if income/assets exist for that obligor in the State. If anything is matched or identified, the receiving State must proceed to collect support from that source and remit amounts collected to the requesting State.

The reference to "5 business days" reflects the original PRWORA statutory timeframe. The House-passed technical amendments, if enacted into law, will replace the current 5-day timeframe with a requirement that a receiving State use its automated enforcement tools "to the same extent" as it uses them for its own cases, and to "promptly" report the results to the requesting State.

[EDITOR'S NOTE (7/31/97): The technical amendments to PRWORA section 323 that have passed both the U.S. House of Representatives and the Senate and are before the President (section 320 of H.R. 1048 and S. 947) state that under this section the responding State conducts "high-volume automated administrative enforcement, to the same extent as used for intrastate cases." High-volume automated administrative enforcement is defined as using "automatic data processing to search State data bases, including license records, employment service data, and State New Hire registries, to determine whether information is available regarding a parent who owes a child support obligation." This is to be done "promptly." The five-day timeframe is removed. The revision also clarifies that States receive Federal incentive funding for enforcing out-of-state orders.]

On April 14-16, 1997, at a national training conference held in Providence, RI, a group of State and Federal child support staff held several breakout sessions to address AEI implementation issues. The following reflects the scope of discussions by the participants in that workgroup, and the numerous areas involving process and policy where the group reached consensus or unanimous agreement.

Issue: How many individual requests can---or should---a State send to another State per AEI transmission?

183Unlimited number?

183Selected cases based on rational criteria?

The statute provides that a requesting State seeking assistance under this provision may:

...by electronic or other means, transmit to another State a request for assistance in a case involving the enforcement of a support order....

The technical amendment modifies the original language:

...by electronic or other means, transmit to another State a request for assistance in enforcing support orders through high-volume,automated administrative enforcement...

Conclusion:

Although some participants are comfortable with unlimited numbers of cases referred in any single AEI transmission, a large majority favors a more selective approach and clearly feels that "wholesale" submittals should be discouraged, at least until States have had some experience with this process. This conclusion is based on concerns that many State systems don’t have the ability to successfully integrate large numbers of so-called "non IV-D cases" into their IV-D data bases without it being disruptive or extremely time-consuming.

Another concern with "wholesale" AEI submittals is the potential cost to assisting States. As States enact PRWORA-required legislation to conduct data matches with financial institutions, it appears that some State laws will permit financial institutions to impose a volume-based transaction fee on the State IV-D Agency for every name submitted for matching.

Accordingly, the majority of participants encourage States to send only those cases for which there is a "rational" basis for the request. Two criteria are suggested: (1) specific indication or knowledge that a specific delinquent obligor’s assets may be in a particular State, and (2) the application of logical criteria on delinquent obligors, specifically including-

*NCP’s geographic proximity to the assisting State

*NCP’s known past association with the assisting State

*EFPLS match results showing NCP’s link with assisting State

However, when a State intends to send a large number of requests to another jurisdiction, the consensus of the participants is that the requesting States should notify the assisting State in advance.

Issue: What data elements should accompany AEI requests?

183Standard data elements?

183State-specific data elements?

183Who decides which elements are to be included?

The statute provides that a requesting State seeking assistance under thisprovision:

133shall include such information as will enable the State to which the request is transmitted to compare the information about the case to the information in the data bases of the State....

Conclusion:

The statute does not specify what data elements are to be used in AEI requests, although the workgroup participants unanimously agree that at a minimum the CSENet-required elements (including NCP name, SSN, DOB, and amount owed) must be included. With the possible exception of DOB, these elements are critical for matching purposes against State data bases. Another reason for using CSENet-required elements is that they contain the identifiers that allow the assisting State to transmit seized assets to the requesting State. Several suggestions were made regarding "optional" identifying data elements that could be helpful for matching purposes (aliases, gender, place of birth, CP’s name), but there is general agreement among participants that these elements should not be required.

A quick enforcement transaction is similar to the kinds of CSENet transactions which will be prompted when "hits" occur between various State and Federal data bases and the Federal Case Registry beginning next year. In these situations, when a State is notified that another State has an interest in one of its case members, CSENet will be used to transmit information between those States on the case member in question. Both situations (FCR inquiry and AEI request) involve transactions where the jurisdiction of a IV-D case is not being transferred, and where one State is simply sending a request to another and does not expect a new IV-D case to be established. Accordingly, OCSE Systems staff have indicated that the transmission of AEI requests via CSENet is a feasible option for States to consider.

Whatever the transmission mode, the participants recognize that it is ultimately the assisting State’s data needs and/or limitations that will dictate what data elements are used, and that matches against different types of data bases may require different elements. Nonetheless, there is consensus that it is desirable to standardize AEI data elements to the greatest extent possible. To this end, the participants recommend that OCSE consider forming a national workgroup to develop a standard format, standard data elements, and a standard form to accompany AEI requests.

Issue: What are the submitting State’s responsibilities when requesting assistance under AEI?

183Case selection

183Certification and amount of arrears

183 Certification of due process

183 Timing and frequency of requests

183 Appeals

Conclusion:

As noted earlier, the majority of participants favor a "rational" approach to the selection of cases for submission under AEI. There is recognition, however, that States cannot be prevented from sending large numbers of AEI cases if they choose. To ensure maximum efficiency in the AEI process, the participants agree that whenever "large" transmissions are contemplated, the requesting State should notify the assisting State in advance to coordinate all technical and logistical aspects necessary for a successful AEI transmission. Coordination should include agreements on when requests are transmitted so that the assisting State can best manage its overall workload and cycle of data base matches (e.g., quarterly financial institution matches). In addition, States should agree to reasonable limits on how often they send "mass" submittals to any one jurisdiction. To facilitate State-to-State communication, a matrix or directory of State AEI contacts should be developed and maintained by OCSE.

The statute requires that requesting States make two specific certifications with each AEI submittal: (1) certify a specific dollar amount in arrears, and (2) certify that all applicable procedural due process requirements applicable to the case have been met.

The participants unanimously recommend that certified arrears balances for AEI purposes mirror the minimum requirements for IRS offsets for Public Assistance and NonPublic Assistance cases. Using IRS offset criteria offers a reasonable and presumably agreeable national standard and could increase computer programming efficiency since States have already identified these cases.

The participants unanimously agree that since asset seizure by the assisting State is AEI’s ultimate objective, the requesting State’s required certification that "applicable" due process has been met must be a certification that the State’s own pre-seizure notice requirements have been met.

When an asset is attached the obligor may have certain appeal rights in the assisting State. Since appeals can be time-consuming, the participants recommend that when appeals are filed before assets are actually seized, requesting States consider the benefits of initiating conventional two-State enforcement actions with the assisting State.

Issue: What are the assisting State’s responsibilities when responding to requests for assistance under AEI?

183Timeframes

183Matching against data bases

183Enforcement

183Appeals

183Case status

183Recordkeeping

Conclusion:

As previously noted, the current statute gives States five days to "respond" to AEI requests from another IV-D jurisdiction. If the technical amendments as passed by the House are enacted into law, States will simply be required to treat AEI requests as they would their other candidates for automated enforcement, and to provide results "promptly" to the requesting State. Therefore States must process AEI requests under the same timeframes as their IV-D cases.

The current statute does not specify which data bases the assisting State must match against. The technical amendment is more specific, defining the data bases to include: "license records, employment service data, and State new hire registries133" The consensus of the workgroup participants is that assisting States should match AEI requests against all available automated data bases, including all available financial institution data matches.

It is the consensus of the workgroup participants that when an asset belonging to a delinquent obligor is identified, the assisting State must proceed to collect the indicated debt, pursuant to applicable State law. This also conforms with the requirement in the pending technical amendment that State use administrative enforcement "to the same extent" as their own cases. Therefore, if permitted under State law, the asset must be immediately seized and the proceeds sent to the requesting State. If immediate seizure is not permitted under State law, the State must proceed to attach the assets (cf. PRWORA Sec. 325), and seize them when permitted.

The workgroup participants agree that when an AEI match uncovers an asset that is suited for ongoing enforcement (i.e., employment, real property, UCI benefits, lottery installment payments), the assisting State should promptly notify the requesting State. The requesting State should then promptly choose a more appropriate interstate enforcement approach.

When assets are frozen or seized, property owners have rights of appeal. The consensus among workgroup participants is that following an AEI action the appeal could take place in either the State where the property is seized or in the State requesting the administrative enforcement, depending on governing State law. The workgroup participants also conclude that if the law of the assisting State gives the property owner the right to appeal pending the actual seizure of the asset, requesting States should seriously consider initiating two-State (IV-D) interstate actions with the other State whenever such appeals are filed. The States involved should evaluate each situation involving such appeals to determine whether a formal "IV-D" entry into the case by the requesting State would be beneficial.

A responding State, whether matching a requesting State’s obligors against its data bases or making a collection in an AEI action, is not processing a conventional IV-D case. The statute specifies that under AEI, "neither State shall consider the case to be transferred to the caseload of such other State." Therefore, while AEI cases must be matched against a State’s data bases "to the same extent" as its own IV-D cases, AEI cases (although they are IV-D cases in the requesting State) do not count as IV-D cases in the assisting State, and must be kept separate. Statistics on case actions and associated collections must be maintained separately.

The workgroup participants unanimously conclude that since AEI cases are not IV-D cases in the assisting State, assisting States should not report or list such cases in their State Case Registry (cf. PRWORA Sec. 311), regardless of whether any automated match occurred or collection was obtained in an AEI case. Such listings could result in those "cases" being reported to the Federal Case Registry (FCR), since the sources for FCR listings will be the State registries.

By statute, States are required to maintain records on the number of AEI requests received, the number of cases in which support was collected, and the amounts collected. If the pending technicalamendments are enacted, AEI collections will be credited towards the assisting State’s Federal IV-D incentives. On the assumption that IV-D incentives will continue to be based on Federal fiscal year distributed collections, the workgroup participants recommend that States keep quarterly statistical data on AEI activities, including dates of distribution of collections to requesting States. If only annual data is maintained, it should be kept on a Federal fiscal year cycle for incentives purposes. States are not required to maintain the names, SSNs, or any other identifiers of parties involved in AEI requests.

If a State’s systems requirements dictate that incoming AEI requests must be categorized and/or treated like IV-D cases for computer matching, asset seizure, or collections distribution to occur, it should be done with the goal of eventually separating AEI requests from the State’s IV-D caseload once the matching and enforcement actions, if any, are completed. If States cannot process AEI requests on separate PCs or separate data bases, they should be coded for later identification and retrieval from the IV-D case data base. Thus, when States report their IV-D collections and case statistics (case inventory and services provided), all assisting State AEI collections and activities will not be included on current OCSE quarterly reports. Similarly, when States begin transmitting State Case Registry data to the FCR next year, assisting State AEI "cases" will not be included.

Finally, in view of the technical amendment which, if enacted, counts AEI collections when calculating Federal IV-D incentives, States should be prepared to maintain AEI records on collections made on behalf of other IV-D jurisdictions to the same extent as their IV-D collections records (AEI collections received from another IV-D jurisdiction are counted as regular IV-D collections). It is reasonable to assume that if AEI collections sent to another State are used to calculate incentives, they will be subject to State and/or Federal audits.

Issue: Must States pass enabling legislation in order to meet AEI requirements?

Section 323 of PRWORA amends Section 466(a) of the Social Security Act, which begins: ...each State must have in effect laws requiring the use of the following procedures....

Therefore, State law must permit the IV-D Agency to act on behalf of other IV-D jurisdictions in the manner prescribed by Section 323. States must evaluate their own statutes to determine whether theyneed additional legislation or whether their current statutory authority permits them to implement AEI by administrative rule or similar action.

INTERSTATE LIENS

Introduction

Section 368 of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) amends section 466(a)(4) of the Social Security Act (the Act), and requires that:

(1) liens arise by operation of law against real and personal property for amounts of overdue support owed by a non-custodial parent who resides or owns property in the State; and

(2) the State accords full faith and credit to liens described in paragraph (1) arising in another State, when the State agency, party, or other entity seeking to enforce such a lien complies with the procedural rules relating to recording or serving liens that arise within the State, except that such rules may not require judicial notice or hearing prior to the enforcement of such lien.

Section 466(a) of the Act requires that States pass enabling legislation in order to meet the "interstate lien" mandate.

Section 324 of PRWORA amends sections 452(a) and 454(9) of the Act, and requires that:

(1) forms are to be promulgated for use by States in interstate cases for the imposition of liens; and that

(2) States are required to use the form described in paragraph (1) for the imposition of liens in interstate child support cases.

The following represents the subgroups' discussions, consensus and recommendations on the appropriate scope, applicability and process relative to the imposition of interstate liens.

Background

The process of establishing and enforcing liens in intrastate cases has been successful in numerous jurisdictions. In New Jersey, for example, all arrearages in excess of $1

(a) create a lien by operation of law;

(b) all liens are filed at on central location (280,000 cases have generated 240,000 liens);

(c) IV-D periodically updates liens;

(d) liens are passive (payor must search central lien data base, and satisfyIV-D lien prior to any payment);

(e) liens are filed against individuals, not property; accordingly, lien attaches to subsequently purchased property; and

(f) upon finding a lien, IV-D coordinator is contacted for updated lien amount.

New Jersey receives significant collections from liens, especially through liens on settlements and civil lawsuits. Nonetheless, 39% of New Jersey's liens are under $100, and IV-D is recommending that State law be amended to set a 30 day arrears threshold before liens are filed. In addition, New Jersey does not pursue liens on automobiles due to, on average, limited equity.

However, even within the limited context of enforcing liens at the intrastate level, other operational problems may exist. In Vermont, liens are filed in each of the townships, and currently, there is no link to a central lien data base. This undermines the ability of both IV-D and title companies to easily access lien information. In Massachusetts, no definitive procedure exists to handle 3rd party interests in property. While there is a delay provision, IV-D does not send notice to a 3rd party, even if such party is identified. Here, as in most other jurisdictions, the property law of the State would determine what 3rd party notice may apply to CSE liens. And as to automobile liens, most jurisdictions would still have to resolve the issue of who would verify lien amounts for the many weekend transactions in the car sales business.

State variations also extend to the data elements required for the successful filing of a lien. In New Jersey, liens can be filed even if all of the Non-custodial parent's (NCP's) identifying information is not available; however, liens are filed in the name of the individual parties, not the name of the IV-D agency - contrary to the proposed interstate lien form, naming the IV-D agency as party in interest. Also, New Jersey law may require a separate notice to the obligor, even if the initiating State already provided the obligor with notice of the lien - the proposed interstate lien form does not currently provide data on the obligor's address. In Vermont, a lien on property, as a passive lien and without a sufficient description of property, would not serve to stop the sale of the respective property, or any other NCP property. Finally, New Jersey law provides for different due process depending on the type of lien; accordingly, the initiating State would need to specify a lien type - a data element not currently included in the proposed interstate lien form.

Consensus and Recommendations on Scope of Process

The subgroup reached the following consensus based on the foregoingdiscussions:

(1) State law relative to the imposition of liens varies widely, both as to process and complexity.

(2) Likewise, state law relative to the process for contesting the imposition of a lien varies widely, and there are no uniform rules on how to contest a lien in interstate actions, nor does Federal law provide for such uniformity.

(3) The proposed interstate lien form may need to be revised in order to accommodate State-specific needs.

For these reasons, the subgroup decided that the scope of the use of interstate liens in One-State Interstate actions (without utilizing the PRWORA section 323 Administrative Enforcement provision) should be limited. In this respect, the subgroup makes the following recommendations:

Recommendations:

(1) The interstate lien process is not suitable for one-state interstate enforcement actions; instead, the process should be used for filing passive liens in order to encumber property in foreign States.

(2) The proposed notice of lien form should only be used for titled or real property.

(3) The following changes to the proposed lien form should be adopted:

(a) Add Name, DOB, SSN and address of NCP (Only Name should be mandated element; others are optional);

(b) Notice should identify obligee (and State, when appropriate) as creditor, and list IV-D agency contact. Since form could be used in private actions, form should be generic whenever appropriate;

(c) Add check box for requesting acknowledgment (when appropriate), and return should include recording information; and

(d) The reference to "interest" should be a general reference, rather than specifying a specific interest rate. Proposed language: "Judgment may be subject to interest."

(4) As to actions against non-titled or personal property, the initiating State should use the "quick administrative enforcement" provision of PRWORA section 323, for both the imposition of the lien and the subsequent seizure of property.

History of Interstate Lien Form

A history was provided of the development of the Interstate Lien Form which appears to lend support to the group's recommendations.

The form was not drafted for nor ever intended to be a tool for One-state enforcement actions. Instead, it was intended to be a tool used by States to encumber an obligor's real or titled property located in a foreign State. In drafting the form, the following process was anticipated: (a) that only the IV-D agency in the State in which the property is located would take action to execute on the lien; and (b) that the filing and execution of liens against other property (such as bank accounts identified through data matches) would be conducted by the IV-D agency in which the property is located, pursuant to a AEI (Administrative Enforcement in Interstate Cases) request.

Consensus and Recommendations as to Liens on Real Property

The subgroup decided that Congress, in adopting the interstate lien provision, did not intend to change the way of business of States relative to the filing and recording of liens. Direct filing is not prohibited by the federal law, and the law is silent as to fees and duration. However, Congress did intend to expedite the process, and best practices should accordingly facilitate expediency. In this regard, the subgroup makes some general recommendations:

General Recommendations:

(1) States need to develop automated linkages, to the extent feasible, between liens and those who need access to lien information;

(2) Best practice if State develops a central lien registry; and

(3) States need to identify a Central Interstate Lien/Judgment coordinator for both intra and interstate lien actions, to provide payoff information, assistance with lien filing, etc.

The subgroup expects that, when it comes to cases in which interstate lien actions are anticipated, we will be dealing with cases in which there is some knowledge of real property, including the location of such property. However, if systems are established, such as one being proposed inTennessee, whereby a name and SSN can be recorded at a central location, which will go to all political subdivisions for recording purposes, it may be a best practice to file a lien in the NCP home state regardless of actual knowledge of property, and wait on hits via title searches.

Below are the subgroup's specific recommendations on where and how to file liens against real property.

Recommendations:

(1) If the initiating State has reasonable knowledge of the existence and location of real property, the interstate lien should be served on and filed directly with the filing agency (this could be a central or local point);

(2) OCSE needs to develop a National Directory describing how and where to record specific types of liens in each State, including names and addresses of filing locations, phone numbers and applicable filing fees; and

(3) A uniform process for releasing interstate liens needs to be developed, along with development of appropriate release forms.

In conjunction with these recommendations, the subgroup makes the following "best practices" recommendations.

Recommended Best Practices:

(1) If a State knows upfront that the filing of a lien may lead to an immediate contest or that the filing otherwise raises complex issues, the State should proceed under appropriate Two-State interstate provisions;

(2) Do not send a lien unless you have a reasonable belief that the obligor has property in the receiving State;

(3) Do not use the interstate lien provision if the responding State already has the case on its system (either as a IV-D case, or an AEI case);

(4) Consider doing a controlling order determination prior to sending the lien (Note: if you have any party to the action in your State, you can make a controlling order determination outside a two-State framework);

(5) IV-D agency should co-sign all lien releases; and

(6) A State's ACSES (or comparable) data base should maintain a record of all places where real property liens have been filed, so that, if a case closes and arrears are satisfied, or if a case closes with outstanding arrears, the lien recorder can be advised appropriately (i.e., lien release, update lien information on CP address, etc).

Parking Lot Issues:

Are there policy reasons for extending the interstate lien process to One-State enforcement actions for property other than real estate, and if so, what needs to be done to overcome the procedural issues raised by the workgroup, such as perfecting filing in compliance with State law, and responding to contests within respective State time frames?

INTERSTATE ADMINISTRATIVE SUBPOENAS,

LONG-ARM JURISDICTION AND INTERSTATE DISCOVERY

Addressed in Section 325 of the PRWORA, State Laws Providing Expedited Procedures, this subsection gives state agencies authority to take a number of actions relating to the establishment of paternity or the establishment, modification or enforcement of support orders, without the necessity of obtaining an order from any other judicial or administrative tribunal. It provides for State agencies to recognize and enforce the authority of other State agencies to take a number of actions including: subpoena financial or other information needed to establish, modify or enforce a support order, and to impose penalties for failure to respond to a subpoena.

The process is envisioned as followed:

State A (initiating/requesting state) sends to State B (responding/assisting State) a simple, abbreviated interstate transmittal; checking the box for "other" and writing the specific action requested. The abbreviated transmittal must include all of the necessary documentation (i.e. laws, forms, discovery documents) that State B would need to provide the requested assistance. Upon receipt of State A's request, State B sets up a skeletal case. Each state keeps their own costs, court sanctions, and would not bill the other state for costs it incurs in performing necessary action. When the requested action is completed, State B closes its skeletal case. Both states claim FFP for the expenses associated with their respective actions on the case. (Process is similar to quick locate case processing in most states.)

INTERSTATE SUBPOENA

Issue: Does OCSE anticipate the Interstate Subpoena will require personal service or affidavits of mailing? If affidavits of mailing are required will OCSE provide a standard document?

Consensus: State A would serve the Interstate Subpoena on the out-of-state target following its state rules or local law for service of process. Because local law is used, the form state A is currently utilizing for service on local cases should be used. OCSE would not need to develop a standard form.

Issue: The Interstate Subpoena effectively asserts jurisdiction where there has been no minimum contact. Doesn't this violate the due process clause of the Fourteenth Amendment?

Consensus: No. Scenario: State A sends the interstate subpoena directly to the target (generally an employer) in State B and employer objects. Employer's recourse is to object directly to State A however, State A doesn't have the ability to coordinate a hearing (in State B) to handle the employer's objection, so State A would request State B's assistance in obtaining the information requested in the subpoena by referring a simple interstate transmittal and accompanying documentation. The case would become a limited service two state case. The employer has notice and an opportunity for a hearing in State B so there is no violation of due process.

Issues: The Interstate Subpoena provides that failure to comply will subject the witness to penalties provided by the laws of his/her state. Given different state laws, how is this possible?

What involvement does other IVD agency have if there is non-compliance with the Interstate Subpoena? What is the contemplated enforcement mechanism? When would the use of the Interstate (or another form of interstate discovery assistance) require the opening of a case in some State other than the State issuing the subpoena? Once opened, how can the case be closed?

Consensus: State A asks State B to enforce the interstate subpoena (not a full enforcement case). State B sets up skeletal case and takes the appropriate action. Upon completion, State B closes its case (action completed) - no further action is necessary.

Issue: Is the Interstate Subpoena to be used in all types of cases? If its use is not restricted to UIFSA cases will there be a problem with the section allowing faxed evidence in States where local rules of evidence require certified copies of documents?

Consensus: Based upon the participant’s interpretation of this question, the Interstate Subpoena should be used in UIFSA and nonUIFSA interstate cases. While OCSE can't mandate its use in nonIVD cases, States are not discouraged from using it in other cases if they wish.

This form was primarily designed for UIFSA cases and in UIFSA actions the rules of evidence contained within UIFSA will apply. However, if this form is used in a non-UIFSA case, States would have to clearly specify both the information requested and the appropriate manner for transmitting the requested information since UIFSA evidentiary rules may not apply.

Pursuant to the Act, States must have provision for administrative subpoenaand may wish to use the administrative subpoena even when using the judicial process however it was noted that this could cause be problematic in some instances.

Issue: States have raised many constitutional issues relative to the Interstate Subpoena. Doesn't this provision give preferential treatment to UIFSA cases? Isn't this an equal protection argument? How about in terms of defenses that may be asserted by the obligor?

Consensus: The workgroup didn't feel that there was a valid equal protection argument. Child support cases ARE treated differently by Congress. The work group believed that any equal protection contest would be defeated by the strong compelling interest/rational basis argument available in support of the Federal/State interest’s in ensuring that children get the support they are due.

Issue If the subpoena target objects to the subpoena and the court enters a judgment affecting the rights of that individual as a sanction, isn't this a violation of the due process clause?

Consensus: No. The subpoena target has received both adequate notice and an opportunity to be heard. There is a forum available to the target of the subpoena whether its being used as a one or two state process. The interstate subpoena informs the target of the subpoena of the right and process to contest.

DISCOVERY

Issue: When a State decides to pursue long-arm jurisdiction, UIFSA allows that State to make use of UIFSA's evidence and discovery provisions at sections 316 (Special Rules of Evidence and Procedure) and 318 (Assistance with Discovery). When a state needs the assistance of a second state (service of process/discovery/etc.) in its "one-state proceeding, who pays the costs incurred by the second state?

If a State A requests State B's assistance in discovery, should State B set up a skeletal case? How should the case be designated? Should the case be dismissed after discovery request is completed? If the court orders the obligor to pay court costs or sanctions how should monies be distributed?

Consensus:

For (simple) service of process: State A sends the case to State B on an abbreviated interstate transmittal checking the box for "other" and indicating service. States will need to know where to send the transmittal. (Seerecommendation below). Upon receipt of State A's request for assistance with service, State B sets up a skeletal case. Both States claim FFP for their respective expenses associated with the necessary actions taken on the case. No direct billing for service of process fees. State B closes when service is completed.

For assistance with discovery: State A sends the case to State B using a simple, abbreviated interstate transmittal form with the necessary documentation (discovery pleading) attached. State B sets up skeletal case. If the process results in court costs being awarded for State B's efforts (service and sanctions), State B keeps these costs. State B closes the case upon referral to State A of the information requested. Both States receive FFP for their services.

Recommendation: Address and state contact information (i.e. where transmittals should be sent for both local and county levels) should be maintained, perhaps on the IRG or another automated source. States should also communicate by phone or fax with the other state prior to sending the transmittal since many times there is a return date by which service must be perfected.

Issue: In this area of "interstate" discovery, how is a witness or parties protected from abuse? What procedural safeguards exist?

Consensus: Assuming abuse refers to badgering or excessive information requests, the witness or party (or their attorney) may raise an objection to the court (State B). State A's laws would control whether the information requested was relevant or subject to exclusion due to any privilege. In the issue of domestic abuse, State A should check off the non-disclosure box when generating documentation to State B and omit the custodial parent’s address and other non-pertinent information.

Issue: In the area of discovery which state's law govern a refusal to provide evidence based upon the assertion of a privilege?

Consensus: State A's (the requesting State) laws and procedures govern.

Issue: Would it be advisable if all states adopted a standard time frame (30-60 days) for the protection of documents? Should State B apply local law in determining the time in which the NCI must respond?

Consensus: Yes. Ideally there should be a standard timeframe to produce documents. Virtually every state must follow local laws regarding timeframes for production of documents and answers to interrogatories. The responding State (State B) should turn documents around and return to initiating state using forum State's timeframes (hopefully which are within 30-60 days).

LONG ARM JURISDICTION

Issue: If long-arm jurisdiction is available in a case, must it be used?

Consensus: No. The initiating State is responsible for determining if the use of long-arm jurisdiction is "appropriate". Appropriateness may be influence by the States’ rules and laws involved (i.e. higher guidelines, post-secondary education provision, statute of limitation, etc.). When a responding State receives a two-state transmittal where it appears that long-arm may have been available, the assumption to be made by the responding State is that the initiating state has reviewed the case and determined that long-arm is not appropriate. The responding state shouldn't second-guess the initiating State or return cases.

Issue: Give examples of sufficient basis for long-arm jurisdiction. (Reference Sec. 201 of UIFSA).

Consensus: Any one of the bases for asserting long-arm jurisdiction listed in the UIFSA Handbook would be sufficient however, the more bases attributed to the case the better to avoid a constitutional challenge.

The District of Columbia and Rhode Island use a checklist to determine whether a case meets long-arm criteria (however DC runs into problems with securing personal service which sometimes requires them to revert to the two state process).

Issue: Which States’ laws applies to rules regarding sufficient services -which rules apply to issues of substantive law?

Consensus: The rules/laws of initiating state.

ADDITIONAL ISSUES/RECOMMENDATIONS

Litigation

In anticipation of potential legal challenges to these provisions, it would be helpful for OCSE to maintain a clearinghouse of related cases, perhaps on ACF's Electronic Bulletin Board, that States could access and use as a resource.

Staffing Studies

Section 345 of PREWAR (1% appropriation) provides for funding of staffing studies therefore it is recommended that OCSE develop and publish staffing guidelines to ensure that each state has adequate staffing resources to accomplish outcomes and improve program efficiency. Currently, some states are relying on contract staff to handle some program activities (i.e. arrears only cases).

DIRECT WITHHOLDING

As a general rule, the group agreed that before a State uses direct income withholding the State should determine that direct income withholding is appropriate.

DIW #1.

Question: State A issues an income withholding order based on its own child support order. The obligee and child live in State B. The obligor lives in State C. Can State B issue a direct income withholding order using State A's child support order?

Answer: Yes. State B can send a direct income withholding order/notice using State A child support order. If the direct income withholding is unsuccessful State B can facilitate State A's order to be registered in State C for income withholding or any other enforcement remedies that are available in that State.

DIW #2-A.

Question: In a situation where more than one State is owed arrears, how should arrears be reconciled. Which State's law apply to arrears and interest accrual?

Answer: Arrears are simultaneously accrued and simultaneously credited. A State can continue to accrue arrears until the tribunal determines the controlling order. Once the controlling order is determined, the responding tribunal can reconcile all arrears up to that date using the highest rate in existence at any given time.

DIW #2-B.

Question: Which State's law apply to arrears and interest?

Answer: The laws of the issuing State applies to arrears and interest accrual.

Each State calculates arrears differently. All States should calculate arrears using similar principles, and accounting methodology. There are no such standards or Federal regulations. States often don't know how arrears were calculated by another State and, therefore, are not aware of what formula was used. It was stated that it should be the responsibility of the State seeking the enforcement to do the calculation. This may involve the State seeking theenforcement asking for a calculation formula from the issuing State.

Recommendations:

It is recommended that the Federal Office of Child Support Enforcement develop standards for calculating arrears and interest. There should be a nationwide agreement on accounting standards on distribution of payments and allocation of arrears distribution among States. A standardized worksheet is recommended so that States can visually see how arrears and interest are calculated by the issuing State. Nationwide interest rate method and fee structure is recommended, including multiple orders. It is recommended directing this issue to distribution work group.

DIW #3.

Question: Which State's law applies to arrears that accrue after registration for enforcement? a request for interstate income withholding? a request for direct withholding?

Answer: The issuing State's laws applies to arrears that accrue after:

þ registration for enforcement;

þ a request for interstate income withholding;

þ a request for direct withholding.

DIW #4.

Question: How should a state interpret inexplicit terms on an income withholding order that allowed the employer to withhold a fee plus interest?

Answer: The employer should interpret the terms on an income withholding order by abiding by the employee's principal place of employ-ment. Employers request that child support obligations be a sum certain. UIFSA Section 502 contains specific provisions about which portions of an order are governed by the law of the State that issued the support order and which portions are governed by the laws of the employee's principal place of employment.

DIW #5.

Question: What is the best solution for dealing with direct withholding requests issued by other States to employers who do not read/speak English? Should there be a dual language form?

Answer: No. The State should obtain an interpreter for those clients who do not speak English. Some States have employer outreach programs in place that assist bi-lingual employers.

It is recommended that the Federal office consider develop forms in dual language. There was consensus that OCSE could develop a brochure or handbook of instructions for States with bi-lingual employers.

DIW #6:

Question: How does a State make administrative changes (i.e., change to payee) to a direct withholding order? How does the employee know that the payee has been administratively changed?

Answer: There was agreement that a State may change the beneficiary "payee" in interstate and intrastate cases and change the registry "payee" in an intrastate case. However, there was extensive discussion on changing the registry or "collection unit" on an interstate case. A State should not assume another State's registry unless the current registry State agrees.

Recommendations:

When a State has CEJ and the controlling order but the obligor, obligee, and child no longer reside in that State, a State that may be a payee for child support should contact the issuing State and both should agree to change the registry.

FFCSSOA should be amended to clarify that if a State that did not issue the order assumes the registry responsibility, that State must calculate any arrearage based upon the laws and methodology of the issuing State until another State assumes CEJ.

OCSE should seek to amend the technical amendment pending before Congress.

DIW #7:

Question: How are IV-D agencies enforcing child support orders/income withholding orders/notices with Indian reservations?

Answer: States have to work out relationship with tribes. States are establishing cooperative agreements with tribes. Some States consider tribes as a nations within U.S. making tribal/Statesupport more like an international issue rather than an interstate issue.

Tribes in Colorado do not accept income withholding. The State must file the order with the tribal court. The tribal court decides whether to issue an order.

Connecticut's IV-D agency has an agreements with two casinos for service of process. The IV-D agency does not file orders with the tribal court. It depends on original reservation agreement. One viewpoint was that it should not matter if they are enrolled on the reservation or casino to do an income withholding.

Rhode Island has trouble enforcing child support orders/notices if the obligor is a member of a tribe. Tribal rules/laws supersede State rules. However, constable service can be completed if the obligor leaves tribal grounds and his/her place of employment is known. Wage withholding with Connecticut's casino tribes is maintained through agreement.

States that have tribes agree that most tribes do not usually honor State income withholding orders. A majority of attendees thought tribes that receive funding/grants should comply with IV-D rules and procedures.

DIW #8:

Question: A State receives a interstate case for registration for enforcement only. The responding State proceeds with a income withholding order/notice to the employer. The initiating State sends a direct income withholding order/notice to the employer. The employer contacts the IV-D agency stating he received a direct withholding from the initiating State and is collecting the obligation. What are you doing with the interstate case if there is no case closure criteria?

Answer: There was consensus that States use one option (registration for enforcement or direct income withholding) at a time. If the initiating State sends a direct withholding order/notice, they should not send the case for registration until the direct withholding is proven to be unsuccessful. If the employer complies with the direct income withholding, there is no need to register the order/notice for enforcement.

If a initiating State has a direct income withholding order in place and still sends an enforcement request to the responding State, the initiating State should cooperate with the responding State in getting the responding State's withholding order substituted for the direct income withholding order if the responding State requests this. If the initiating State does not cooperate with the responding State in withdrawing the direct income withholding order, the responding State should have case closure criterion that allows it to close the initiating State's request for services, unless enforcement other than withholding (such as medical support or liens) is sought.

Recommendation:

OCSE should develop closure criteria for responding State and/or protocol for these situations. [Editor's note: match this with the new case closure criteria proposed by the regulation reinvention workgroup.]

During this sessions the group discussed the Order/Notice to Withhold Income for Child Support (standardized income withholding form). There was consensus that the instructions to complete the proposed Order/Notice should reflect the following changes:

Clarify that the terms of the order are those of the State that issued the support order and not those of "your" State.

Clarify that the Name and Address of where to send the payments is the "collection unit" specified by the tribunal that issued the controlling order. If no collection unit is specified, then the State issuing the Order/Notice can designate where the payments should be made as long as that payee assumes the responsibility of accounting for all the payments and applies the laws and methodology of the issuing State in determining any arrearage.

ONE-STATE INTERSTATE ATTENDEES

Gary Ambukewicz

Office of Child Support

279 Main Street

Norwich, CT 06330

David Aerts

Office of Child Support

601 East 12th Street

Room 276

Kansas City, MO 64106

Jeff Ball

Office of Child Support Enforcement

901 D Street, S.W.

Washington, D.C. 20447

Karen Bartlett

Office of Child Support Enforcement

901 D Street, S.W.

Washington, D.C. 20447

Dennis Barton

Office of Child Support

1961 Stout Street, Rm. 924

Denver, CO 80294

Rochelle Batties

Office of Child Support

1844 Plymouth Street

Philadelphia, PA 19126

Susan Becker

Office of Child Support

1575 Sherman Street

Denver, CO 80203

Tom Bernier

Office of Child Support

50 N Ridley Street

Montgomery, AL 36111

Joe Bodmer

Office of Child Support Enforcement

901 D Street, S.W.

Washington, D.C. 20447

Cece Bozetarnik

Office of Child Support Enforcement

51 Weston Avenue

Brattleboro, VT 05300

Bill Brownfield

Office of Child Support Enforcement

730 E Broad Street

Richmond, VA 23219

Barry Brooks

Office of Child Support Enforcement

P. O. Box 12017

Mail Code 040

Austin, TX 78741

Hope Butler

Office of Child Support Enforcement

901 D Street, S.W.

Washington, D.C. 20447

Steve Cesar

Office of Child Support Enforcement

901 D Street, S.W.

Washington, D.C. 20447

Patricia Clark

Office of Child Support Enforcement

1401 Portland Street

10th Floor

Cambridge, MA 02139

Ruth Clark

Institute on Family Law & Policy

342 Massachusetts Ave.

Indianapolis, IN 46204

Mary Clayton

Office of Child Support Enforcement

P. O. Box 40458

Phoenix, AZ 85067

Robert Clifford

Office of Child Support Enforcement

P. O. Box 8436 - 5th Floor

Philadelphia, PA 19101

Marilyn Cohen

Office of Child Support Enforcement

901 D Street, S.W.

Washington, D.C. 20447

Nancy Crocker

Office of Child Support Enforcement

227 Metro

Jefferson City, MO 65109

Don Deering

Office of Child Support Enforcement

901 D Street, S.W.

Washington, D.C. 20447

Jim Dingeldine

Office of Child Support Enforcement

504 Virginia Street

Charleston, WV 25302

Jerry Fay

Department of Revenue

Office of Child Support Enforcement

141 Portland Street, 10th Floor

Cambridge, MA 02139-1937

Jens Feck

United State Court House

Carlos Chardos Avenue

Room 227

Hatorey, PR 00981

Verdell Fields

Office of Child Support Enforcement

901 D Street, S.W.

Washington, D.C. 20447

Stephen Grant

Office of Child Support Enforcement

901 D Street, S.W.

Washington, D.C. 20447

Mark Gray

Child Support Enforcement

77 Dorrance Street

Providence, RI 02903

Charlotte Guyer

Office of Child Support Enforcement

6 Hazen Drive

Concord, NH 03301

Vince Herberholt

Office of Child Support Enforcement

2201 6th Avenue - Suite 600

Seattle, WA 98121

Margaret C. Haynes

Service Design Associates

2000 L Street, N.W.

Washington, D.C. 20036

Mary Ann Higgins

26 Federal Plaza Bldg.

Room 4049

New York, NY 10278

Larry Holtz

Office of Child Support Enforcement

901 D Street, S.W.

Washington, D.C. 20447

Nancy Ignazi

Office of Child Support Enforcement

27 Water Street

Wakefield, MA 01880

Judy Johnson

Child Support Enforcement

P. O. Box 53552

Oklahoma City, OK 73152

Irine Jorner

Office of Child Support Enforcement

509 South 6th Street

Springfield, IL 62703

Terry Justin

Office of Child Support Enforcement

901 D Street, S.W.

Washington, D.C. 20447

Charles Kenher

Office of Child Support Enforcement

39 Ayers Village Road

Methuen, MA 01844

Allison Kur

DOR\CSE

141 Portland Street

Cambridge, MA 02139

Linda Lawrence

Office of Child Support Enforcement

105 West Adams Street

21st Floor

Chicago, IL 60603

Sheila Leblanc

Office of Child Support Enforcement

901 D Street S.W.

Washington, D.C. 20447

Tom Leeds

601 N Pecos

Las Vegas, NV 89109

Carol McLeod

Office of Child Support Enforcement

Operation Support Branch

#2 Peach Tree Street

Atlanta, GA 30357

Dennis Minkler

Office of Child Support Enforcement

26 Federal Plaza

Room 4048

New York, NY 10278

Carol Monteiro

Office of Child Support

JFK Federal Building

Boston, MA 02203

Dail Moore

Office of Child Support Enforcement

901 D Street, S.W.

Washington, D.C. 20447

Thelzeda Moore

Social Services Administration

402 West Washington

Room W-360

Indianapolis, IN 46204

Cathy Needham

Office of Child Support Enforcement

444 Lafayette Street

St Paul, MS 55155-3846

Diane Offett

Office of Child Support Enforcement

901 D Street, S.W.

Washington, D.C. 20447

Israel Ortiz

Office of Child Support Enforcement

6 Hazen Drive

Concord, NH 03301

Susan Paikin

Senior Associate

13 Deer Run Little Baltimore

Newark, DE 19711

Dan Phillips

4 Nottingham Court

Mt. Holly, NJ 08060

Monty Powell

Office of Child Support Enforcement

400 Deaderick Street

15th Floor

Nashville, TN 37248

Naomi Rodriguez

Oregon Child Support

Interstate Branch

1495 Edgewater N.W., Suite 290

Salem, OR 97304

Earl Scales

Office of Child Support Enforcement

P. O. Box 352

Jackson, Mississippi 39205

Eileen Schrauben

Office of Child Support Enforcement

7109 W Saginaw, 3rd Floor

P.O. Box 30478

Lansing, MI 48909-7978

Louween Schoenhard

Office of Child Support Enforcement

700 Governors Drive

Pierre, SD 57501-2291

Barbara Shea

Child Support Enforcement

77 Dorrance Street

Providence, RI 02903

Marilyn R. Smith

100 Goddard Avenue

Brooklyn, MA 02’

J. P. Soden

Office of Child Support Enforcement

50 United Nation Plaza

Room 334

San Francisco, CA 94102

Marie Soler

Office of Child Support Enforcement

278 Tubingen St.

College Park R.P

Puerto Rico 00921

Don Twomey

DOR/CSE/SMB

P. O. Box 7077

Boston, MA 02204

Jeanne Vega

Forms Analyst

2535 Capitol Oaks Drive

4th Floor

Sacramento, CA 95833

Michael Vergenz

Florida Department of Revenue

325 W Gaines Street

Tallahassee, FL 32399

Christine Wall

Office of Child Support Enforcement

1109 Glencastle Way

Raleigh, NC 27606

Janet Wallace

500 1st Avenue

Seattle, Washington 98104

Carol Ann White

Attorney General Office

4586 Miwok Road

Placedville, CA 95667

Leann Wilber

P. O. Box 4500

515 East 100th Street

Salt Lake City, UT 84145

Chris Hart-Wright

Office of Child Support Enforcement

800 9th Street, 2nd Floor

Washington, D.C. 20001

Jeff Young

Office of Child Support Enforcement

219 Capitol Street

Augusta, ME 04333

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