Allowable Costs for Tribal Child Support Programs
POLICY INTERPRETATION QUESTIONS - TRIBAL
DATE: May 13, 2019
TO: Tribal IV-D Agencies
FROM: Scott M. Lekan, Commissioner, Office of Child Support Enforcement
SUBJECT: Allowable Costs for Tribal Child Support Programs
Tribal child support programs have requested guidance on whether they may receive federal financial participation on the below activities. The costs of these activities must be reasonable in accordance with 45 CFR 309.145(o) and 45 CFR 75.404. A tribe must include them in their annual tribal budget or request to add them to their approved budget by submitting a budget revision pursuant to 45 CFR 309.130(b) and (f). A tribe must also maintain adequate documentation of all claimed costs in accordance with 45 CFR 309.85(b) and 309.145(o)(1). Additionally, when considering the below activities, we encourage tribes to determine how they would improve the efficiency and effectiveness of their tribal child support program and to maintain data on the results.
Question 1: What fatherhood activities may a tribal child support program provide?
Answer 1: Child support programs are uniquely positioned to provide fatherhood activities because caseworkers have direct contact with Fathers. Allowable fatherhood activities include, but are not limited to, the following:
- Collaborating with responsible fatherhood programs
- Referring noncustodial fathers to services to help increase their ability to support their children financially and emotionally (see question 1 of PIQ-12-02)
- Conducting parenting and co-parenting classes (see below question 2)
- Providing outreach to incarcerated fathers to inform them about the tribal child support program or their child support orders
- Mediating child support issues
- Providing intensive case management (see question 4 of PIQ-12-02)
- Paying for bus fare or other minor transportation costs for fathers to participate in child support proceedings (see below question 3)
Visit OCSE’s Fatherhood or National Responsible Fatherhood Clearinghouse websites for more information on engaging fathers in your caseload. Contact your Regional Program Specialist if you need technical assistance.
Question 2: What kinds of educational and outreach activities may a tribal child support program conduct?
Answer 2: A tribe may conduct educational and outreach activities to inform the public, parents, family members, and young people about the tribal child support program (see question 3 of PIQ-12-02). This includes disseminating information through various media, such as print, broadcast, outdoor, or internet. Additionally, the tribal child support program may conduct classes or provide information on parenting, co-parenting, family budgeting, and the financial consequences of raising children when parents are not married to each other.
Question 3: May a tribal child support program pay for bus fare or other minor transportation expenses to enable custodial or noncustodial parties to participate in child support proceedings and related activities?
Answer 3: Yes. Like states, a tribal child support program may use IV-D funds for bus fare or other minor transportation expenses to enable custodial or noncustodial parties to participate in child support proceedings and related activities (see 45 CFR 304.20(b)(3)(v)). For example, providing bus passes and gas vouchers are considered allowable as local transportation assistance in support of providing child support services . Providing local transportation vouchers can be a highly cost-effective means to increase participation in child support interviews, genetic testing, and hearings, and decrease no-shows and defaults (see page 93551, comment 8 of Section 304.20—Availability and Rate of Federal Financial Participation of the Flexibility, Efficiency, and Modernization in the Child Support Enforcement Program final rule).
Tribes must develop policies and criteria for using IV-D funds for bus fare or other minor transportation expenses, which warrants a plan amendment. We also encourage tribes to consider alternatives to requiring travel to the child support office or court, such as the use of technology, including web applications, video conferences, or telephonic hearings.
Question 4: May tribes use child support funds to prevent and reduce domestic violence?
Answer 4: Yes. The tribal child support program may use IV-D funds to provide information about family violence and to screen and make effective referrals to emergency shelters and family violence services, including advocacy and counseling services, for families in the child support caseload. A tribe may also use IV-D funds to develop, produce, disseminate, and present outreach, education materials, and curricula about safe access to child support services. Please see question 6 of PIQ-12-02 for additional examples of allowable activities to prevent and reduce domestic violence.
INQUIRIES: ACF OCSE Regional Program Managers