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To Close or Not to Close –Federal & State Perspective on Case Closure

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.

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To Close or Not to Close –Federal & State Perspective on Case Closure

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  1. 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 ERICSA 50th Annual Training Conference & Exposition ▪ May 19 – 23 ▪ Hilton Orlando Lake Buena Vista, Florida ERICSA 50 CELEBRATES YEARS OF SERVING FAMILIES: THE MAGIC IS STILL ALIVE ERICSA ERICSA ERICSA ERICSA ERICSA

  2. 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;

  3. 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.

  4. 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.

  5. 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.

  6. 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.

  7. 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;

  8. 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;

  9. 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.

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

  11. 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.

  12. 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.

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

  14. 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

  15. 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

  16. 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

  17. 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?

  18. Questions ???

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

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