The National Council of Child Support Directors (NCCSD), as you may be aware, is the professional association of the directors who administer the 54 discrete child support enforcement programs in the states, territories and District of Columbia.

I think you would agree with NCCSD, as would your allies who make up the Child Support Enforcement Council (CSEC), that the provision of child support enforcement services through private agencies has been the subject of considerable controversy over the past few years.

Every NCCSD member is fully dedicated to serving the children who are our clients, in the highest and best possible fashion, through all lawful and effective means. We are not opposed to private sector help, and in fact every program in the United States makes extensive use of such assistance.

That said, we have issues with a number of the disingenuous tactics in which your Coalition and the CSEC have recently engaged: tactics that, as you know, have been heavily criticized and publicized throughout the country, including substantial coverage in newspapers and national news magazines.

To cite an ongoing example, let me mention a few items from recent Coalition and CSEC exertion of political pressure in an attempt to force one of our NCCSD member states to reverse its refusal to redirect all collections (regardless of how obtained and by whom) on cases in which the custodial parents have signed the now-famous "adhesion" contracts with CSEC member firms. Not only that, but CSEC and your Coalition malign the performance of the state and impugn its motives both for refusing to redirect payments and for seeking authority to regulate such private firms.

The example state, as you have probably inferred, is Virginia, which has agreed to be identified because the issues there are similar to those that apply throughout the nation. Virginia is typical of NCCSD members in continually striving to make its program more effective and responsive to its customers. It would stipulate that there is always room to do better.

However, CSEC and your Coalition exhibit little compunction about spinning data to convince unwary legislators or state executives that the child support sky is falling in Virginia and other states, and that only CSEC members can prop it up. To cite just a few examples from the webpage about Virginia that appears on your website, and is entitled “Hall of Shame”1:

* Your Coalition used data out of its correct context to “prove” that the state is unable to collect support for most of its clients. The fact is that, among cases having obligations to pay established and having payments due, Virginia is currently collecting on about 77 percent of them. In 2002 it collected $474 million, and during the past 10 years collections have exceeded $3.1 billion. Some other states do even better.

* Similarly, from the same page, your Coalition indicated that ‘Virginia has engaged in massive “case closures” --- 735,000 child support enforcement cases CLOSED in 1998 alone!’ an implication that Virginia was closing cases “en masse” to deprive custodians of necessary child support. This “proof” is equally out of context, and in fact is just plain wrong. Please note that Virginia only had 404,870 cases at the end of FY 1997.

* Your Coalition fails to note that the main strategies for improving total collections involve establishing more paternities and more payment obligations: functions not performed by the CSEC member firms you support. For FY 2001 paternities were established nationwide for 1.6 million children born out of wedlock.

* Even not considering the issue of the legality of having states redirect child support collections to private firms, the fact is that in many instances, child support payments reaching children’s custodians actually decrease after the custodian signs a contract, due to the deduction of fees from collections which, by the way, often come through tax intercepts or other measures taken by the states, not the private firms. Your Coalition’s writings neglect to mention that the CSEC members are enriched by collections, such as these, for which they have taken not a single action.

Statistics can be used in any number of ways. Your Coalition has chosen to use them to portray the IV-D program in a manner that indicates help being received by very few clients that apply for IV-D services. But the reality is that for the nation as a whole, during FY 2001, $19 billion in child support payments were collected. Between FY 1997 and 2001 there has been a 41.9 percent increase in the amount of the collections, and a 76.8 percent increase in the number of cases for which a collection was made.

One last set of statistics about Virginia. For FY 2001 Virginia was the 6th most cost effective program in the nation ($6.12 collected for $1.00 spent). Virginia also earned the 8th highest incentive award for that year, ($16.9 million) and chose to put the money back into child support program.

NCCSD joins you in wanting children to receive the support due them, but we are disturbed at efforts to distract state child support agencies from their crucial mission of obtaining child support payments for families in order to refute the misleading information provided by your Coalition. This is not in the best interest of children. There are certainly plenty of real improvements to be made in child support enforcement. NCCSD members will continue to partner with the private sector to achieve those improvements to ensure that children receive all the support to which they are entitled.

1 Note that this page is available to the public through the Google search engine. National Coalition for Child Support Options