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Government Relations Task Force

GRTF Child Support and Other Garnishments Subcommittee

One of the critical roles of employers and their payroll professionals is to help support our government in ensuring that our nation's children are cared for through our child support enforcement programs. Without the cooperation of employers and payroll professionals with the processes of reporting newly hired employees and collecting and remitting child support payments of noncustodial parents to state child support enforcement agencies in an accurate and timely manner, many single parents and their children would be financially strained to the point where they would be have no choice but to participate in state public assistance programs.

APA's GRTF Child Support and Other Garnishments Subcommittee actively monitors federal, state, and local administrative and policy trends that can impact employers and their payroll professional role in the withholding and remittance of child support payments. The subcommittee participates in monthly conference calls to discuss administrative burden issues relating to child support enforcement activities and works with child support agency officials to continually evaluate and offer constructive feedback on emerging child support enforcement policies, procedures, and administrative systems. This dialog and feedback helps all parties involved with the child support enforcement process to create a system that is workable for everyone to achieve common goals and objectives.

If you would like to participate in this subcommittee, please contact William Dunn, CPP, Director of Government Relations, via e-mail at [email protected] or by calling him at the APA Washington, D.C., office at 202-232-6889.

DOL Issues New Guidance on Lump Sum Payments

APA's GRTF Subcommittee on Child Support and Other Garnishments succeeded in obtaining guidance from the U.S. Department of Labor (DOL) finding that lump-sum payments are covered by Title III of the Consumer Credit Protection Act (CCPA) for purposes of garnishments. At issue are those states that believe the CCPA does not apply to lump sum payments and are garnishing as much as 100% for child support payments. The updated guidance includes a statement, "Earnings may include payments received in lump sums."

DOL's Response to APA: December 22, 2016 DOL Letter

DOL Fact Sheet #30: The Federal Wage Garnishment Law, Consumer Credit Protection Act's Title III (CCPA)

November 9, 2016: APA Letter to the U.S. DOL Wage and Hour Division about lump sum payments and child support

Comments and Letters

February 17, 2017: California Senate Bill 16 Letter

February 13, 2017: Colorado Senate Bill 17-080 Letter

January 1, 2017: APA Statement Supporting Uniform Wage Garnishment Act

December 2, 2016: APA Submits Recommendations to OCSE on the Revised IWO Form and Instructions

November 11, 2016: Letter to Pennsylvania Bureau of Child Support Enforcement regarding employer fees for child support in Pennsylvania Act 64

June 1, 2016: Letter to Colorado Governor Hickenlooper - Compliance with federal guidelines for calculating child support withholding

February 3, 2015: Statement in Support of Michigan HB 4119 and HB 4120 - Submitted to the House Commerce and Trade Committee

January 16, 2015: Comments Concerning Flexibility, Efficiency, and Modernization in Child Support Enforcement Programs (NPRM) ACF-2014-2014-0004-0001 - Submitted to OCSE

October 22, 2014: Comments supporting Michigan HB 5390 and HB 5391 - Submitted to the Senate Committee on Reforms, Restructuring and Reinventing

July 28, 2014: Response from Hon. Robert J. Colombo, Jr.

June 27, 2014: Letter to Hon. Robert J. Colombo, Jr., Chief Judge, Third Judicial Circuit of Michigan

June 4, 2014: Comments supporting Michigan HB 5390 and HB 5391 - Submitted to the House Commerce Committee

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