The National Council of Child Support Directors (NCCSD), organized in 1978, is an association comprised of the nation's child support directors from the 50 states and 4 jurisdictions.
The Council was established to 1) to promote the development of legislation and or policies which will have a positive impact upon the Title IV-D Child Support Program and upon the operation of the Uniform Interstate Family Support Act or similar acts in states and foreign nations; 2) to provide a forum for State IV-D Child Support Directors to discuss common problems and solutions associated with program administration, interstate and international cooperation and federal-state-local relations and other matters deemed important; and 3) to provide a structured medium for communication with federal agencies the views, opinions or consensus of the Council on issues and maintaining a continuing dialogue with federal agencies..
After serious consideration of H.R. 4469, "The Child Support Distribution Act of 2000", the National Council of Child Support Directors must oppose Title III of the bill for the following reasons:
* Title III increases the risk of data misuse and unauthorized access to confidential information at a time when the general public and their representatives are increasingly concerned about privacy.
* Private child support collection entities and individuals are not regulated under the Fair Debt Collection Practices Act, 15 U.S.C. 1692, thus exposing vulnerable families to abusive practices.
* The IV-D child support program is bound by federal and state laws that prescribe safeguards for using and maintaining the confidentiality of data and ensuring due process for enforcement actions. Title III provides no mechanism for extending these safeguards to private collection entities and individuals.
* Title III does not provide states a true option. If even one state chooses to provide non-IV-D entities and individuals with IV-D information, all other states lose the option to deny this information because non-IV-D entities and individuals can funnel all requests through one state.
* States and the Federal Office of Child Support Enforcement will be called upon to expend resources to respond to states that choose this option. This has the potential to divert resources, thus jeopardizing services to IV-D families.
We recognize that families may seek options outside the IV-D program for collecting lawful child support debt. However, using IV-D data and tools to expand such options must be balanced against other concerns such as maintaining privacy, preserving services for families relying on the IV-D program, and reducing the potential for misuse of established child support tools.
We appreciate the attention the Human Resources Subcommittee continues to give to child support matters and welcome the opportunity for dialogue on the issues. Enclosed for your use is a resolution that NCCSD passed earlier this year, further addressing issues now under consideration.