NonSub Change - Add back 2020 materials for transition period

To: Kelsi Feltz

Office of Information and Regulatory Affairs (OIRA)

Office of Management and Budget (OMB)

From: Lynnetta Thompson

Office of Child Support Services (OCSS)

Administration for Children and Families (ACF)

Date: September 18, 2023

Subject: Non-Substantive Change Request – Income Withholding for Support Order (IWO) (OMB #0970-0154)

This memo provides an overview of proposed non-substantive changes to the approved information collection, Income Withholding for Support Order (IWO) (OMB #0970-0154).

Background

OMB approved the IWO for an additional three years on August 23, 2023. During the OMB review period, OCSS found references to “child support enforcement (CSE) agencies” that were not updated to “child support agency (CSA)” as intended. As a result, the IWO program team submitted the forms for additional quality review, which resulted in additional minor edits to the form and instructions.

States are required to use the IWO form to issue income withholding orders. OCSS would like to give states the option to use the previously approved IWO form for an additional 12 months so that child support agencies remain compliant with federal law while making any system changes to accommodate the proposed edits to the IWO form. States will be required to use the proposed form once programming is complete. The original submission and the recently approved materials do not reflect an extension request for this transition.

Overview of Requested Changes

OCSS requests an extension of the previously approved IWO form for an additional 12 months to allow states to program their systems to accommodate the recently approved revisions to the IWO form and instructions.

OCSS made the following changes as a result of the additional quality review and to clarify instructions around forms during programming transitions:

1. Revised all “child support enforcement (CSE) agencies” references to “child support agencies (CSA)” on the IWO form, instructions, and sample IWO form

2. Made minor edits to simplify the language in the instructions

3. Added an explanation under #1.d of the instructions to clarify that the “Expiration Date” pertains to OMB approval of the form and is not the date enforcing the withholding order expires.

4. Added an explanation under #1.d of the instructions notifying state to issue orders using the previous form while programming to use the new form.

The IWO Record Specifications did not change.

Time Sensitivities

OCSS seeks approval of the revised forms as soon as possible to allow OCSS to quickly post the instruments on the OCSS site so that users may begin immediately accessing the correct forms.