Employment Verification for Federal Agencies and the Military
DATE: September 27, 2002
TO: STATE AGENCIES ADMINISTERING CHILD SUPPORT ENFORCEMENT PLANS UNDER TITLE IV-D OF THE SOCIAL SECURITY ACT AND OTHER INTERESTED INDIVIDUALS
SUBJECT: CHANGE IN DEPARTMENT OF DEFENSE POLICY RE: REQUESTS FOR EMPLOYMENT VERIFICATION; REDUCING THE VOLUME OF EMPLOYER VERIFICATIONS FOR FEDERAL AGENCIES AND THE MILITARY
BACKGROUND: The Department of Defense (DoD) has recently announced that, beginning in November 2002, it will no longer respond to Federal Parent Locator Service (FPLS) locate requests about active and reserve military and civilian personnel records because this information is already provided (to the FPLS) through quarterly wage reporting to the FPLS National Directory of New Hires (NDNH).
DoD will continue responding to FPLS locate requests for military and Federal government civilian retirees. They will accept and return these locate requests on a monthly basis.
As a key source of locate and employment information for the child support program across the country, the FPLS includes two federal databases mandated by the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA)—NDNH and the Federal Case Registry (FCR). The data populating the NDNH are reported on a regular basis by employers and by states according to requirements of federal and state legislation.
Once an employment record has been received by the NDNH, it is matched to the FCR to determine if any state is looking for the individual. If so, the record is forwarded to the state(s). If new FCR data are submitted, they are matched to the NDNH to obtain any employment data. If employment data are found, the proactive data are sent to the state. Upon receiving the FPLS-matched information, states should not delay issuing the notice by sending a request for verification, since the data should be considered already verified.
As our nation’s largest employer, the Federal government has an important role in child support enforcement. Federal agencies are striving to provide complete, timely, and accurate information to the FPLS. Of the more than four million federal employees, more than half work as military personnel or for the United States Postal Service. Both these entities have reported an inundation of verification requests from state child support agencies acting on new hire and quarterly wage matches from the FPLS. This places an overwhelming burden on the agency employer and significantly increases the amount of time before support flows to the family.
The Defense Finance and Accounting Service (DFAS) recommends that once the child support enforcement agency receives a match from new hire or quarterly wage, an income-withholding order/notice should be initiated immediately. Requesting employment verification would significantly delay the process because employment verification is a manual process at DFAS. The wage and employer information from the DoD, provided through the FPLS, is current.
By automating the generation of income-withholding orders/notices, a state can meet the two-day turnaround requirement and can substantially increase collections. Sending an income-withholding order/notice immediately, instead of a request for employment verification followed by an order/notice, reduces the paperwork burden on the employer significantly. Since the vast majority of child support collections come from employers through income-withholding, reducing the burden on employers, whenever possible, is in the best interests of the child support community.
Address information for active duty military is available through the DFAS field organizations. Addresses for DoD civilian employees may be obtained through the Freedom of Information/Privacy Act Office at the field organizations. The OCSE Employer Outreach Team is preparing a Quick Guide to the Military, which will soon be mailed to all child support offices.
INQUIRIES: For further information and assistance on these issues, contact your state technical support (TS) liaison. ______________________________
Sherri Z. Heller, Ed.D.
Office of Child Support Enforcement