June 25, 2002
Senator Max Baucus
Chairman
Finance Committee
United States Senate
Washington, DC 20510
RE: "Work Opportunity and Responsibility for Kids (WORK) Act of 2002"
Dear Senator Baucus:
As the Finance Committee considers the "Work, Opportunity and Responsibility for Kids (WORK) Act of 2002" the National Council of Child Support Directors (NCCSD) would request consideration of a recommendation that would revise the definition of "reasonable cost" for medical support.
Several states have implemented or are in the process of implementing the National Medical Support Notice (NMSN) in accordance with the Child Support Performance and Incentive Act of 1998. As states implement the use of NMSN it is imperative that states have a more workable definition of reasonable cost. The current definition issued to states in 1985 fails to consider the changes in employer based health care coverage available today.
The National Council of Child Support Directors would recommend the following for consideration:
States that wish to revise the definition of reasonable cost should have the option to do so. States should have the authority to develop an income-based standard as a definition of reasonable cost, or adopt the 5% definition of reasonable cost, as recommended by the National Medical Support Working Group. A revised definition of reasonable cost would allow state child support agencies to concentrate their efforts on creating enforceable orders and should not result in any revenue loss for state or federal governments,
which have no share in medical support orders. A definition revised according to this proposal can benefit both families and states by ensuring that cash and medical support are provided to children by their parents and by preventing the creation of unenforceable medical support orders.
Thank you for your consideration. If you would wish to discuss further please contact me at 720 947-5050 or e-mail Pauline.burton@state.co.us.
Yours truly,
Pauline Burton
President