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SDNH Reporting of Employer Addresses

PIQ-99-07

Published: December 2, 1999
Information About:
State/Local Child Support Agencies
Topics:
Federal Systems, National Directory of New Hires (NDNH)
Types:
Policy, Policy Interpretation Questions (PIQ)

U.S. Department of Health and Human Services
Administration for Children & Families
Office of Child Support Enforcement

PIQ-99-07

DATE: December 2, 1999

TO: State IV-D Directors and Regional Program Managers

FROM: David Gray Ross
Commissioner
Office of Child Support Enforcement

SUBJECT: SDNH Reporting of Employer Addresses

In consultation with States over the last couple of months we have identified a problem with the source of employer addresses on W-4 reports transmitted from the State Directories of New Hire (SDNH) to the National Directory of New Hires (NDNH). Specifically, what seems to be occurring in some States is that while an employer reports an address on his new hire report to the SDNH, the SDNH is not submitting that address to the NDNH. Instead, the SDNH is using the Federal Employer Identification Number (FEIN) to pull the address from another employer database housed at the State. The address pulled in this manner may not be the appropriate address for child support activities, such as employment verification or income withholding.

SDNH reporting of employer information is required by the Social Security Act as follows:

Social Security Act, section 453A (b) EMPLOYER INFORMATION.-

(1) REPORTING REQUIREMENT.-

(A) IN GENERAL.-Except as provided in subparagraphs (B) and (C), each employer shall furnish to the Directory of New Hires of the State in which a newly hired employee works, a report that contains the name, address, and social security number of the employee, and the name and address of, and identifying number assigned under section 6109 of the Internal Revenue Code of 1986 to, the employer.

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(e) ENTRY OF EMPLOYER INFORMATION.-Information shall be entered into the data base maintained by the State Directory of New Hires within 5 business days of receipt from an employer pursuant to subsection (b).

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(g) TRANSMISSION OF INFORMATION.-

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(2) TRANSMISSIONS TO THE NATIONAL DIRECTORY OF NEW HIRES.-

(A) NEW HIRE INFORMATION.-Within 3 business days after the date information regarding a newly hired employee is entered into the State Directory of New Hires, the State Directory of New Hires shall furnish the information to the National Directory of New Hires.

To summarize the statute: the employer reports six pieces of information to the SDNH, the SDNH enters that data on to the database at the State, the SDNH transmits that data to the NDNH. The clear language of the statute requires that the SDNH use and transmit the information submitted by the employer. This should be the most accurate, up-to-date information, and it is the specific information needed for the purpose for which it is submitted. Any other approach to submission undermines the NDNH, as it diminishes the accuracy of the information, and is contrary to the law.

Technical assistance is available to States that need help in identifying or correcting problems such as this. Please contact Angela Kasey at 202-205-3423, email akasey@acf.hhs.gov, with any questions you may have.