OCSE Recognizes Importance of APA Relationship
The federal Office of Child Support Enforcement (OCSE) has acknowledged its collaborative efforts with APA on new hire reporting. As of 2018, employers can report new hire and rehire information on Form W-4, Employee’s Withholding Allowance Certificate, without altering the form [OCSE, “Collaboration Improves New Hire Reporting,” Child Support Report, Issue 8, Vol. 40].
Employers are required to enter an employee’s first date of employment for new hires and rehired employees into the State Directory of New Hires, but until the 2018 Form W-4 change, they did not have a clear means of submitting the information without invalidating the form by altering it. For years, employers were cautioned to add the date of hire only on a copy of Form W-4 and not the original. The need to report the date of hire became law in 2010 through the Claims Resolution Act (Pub. L. 111-291), which amended the Social Security Act.
OCSE, with support from APA and the U.S. Department of Labor, recommended that the IRS add a new field for the date to the Form W-4. The IRS included the “first date of employment” in Box 9 on the 2018 Form W-4, and the box remains for the 2019 Form W-4. With the changes to Box 9, employers can use Form W-4 to comply with new hire reporting requirements.
In addition, the IRS’s instructions explain the requirements for new hire reporting:
Box 9. If the employer is sending a copy of this form to a State Directory of New Hires, enter the employee’s first date of employment, which is the date services for payment were first performed by the employee. If the employer rehired the employee after the employee had been separated from the employer’s service for at least 60 days, enter the rehire date.
OCSE said, “We believe that these changes will help improve employer compliance with new hire reporting and efficiency in the child support program.”
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