EFT/EDI Child Support Payments

Teleconference

Minutes from the
Federal/State Agencies EFT/EDI Child
Support Payments Project
Teleconference, March 17, 2004

Participants:

The following Federal agencies were represented: Department of the Treasury, Financial Management Service (FMS): Washington, DC Headquarters, and Kansas City Financial Center; Health and Human Services: Office of Child Support Enforcement (OCSE), and Program Support Center; Department of Agriculture, National Finance Center (NFC); General Services Administration (GSA); Department of Interior, National Business Center (NBC); Department of Defense: Headquarters, Arlington, VA, and Defense Finance and Accounting Service - Kansas City, Cleveland, and Denver; U.S. Supreme Court. The following States were represented: Missouri, Montana, Florida, Illinois, Colorado, Oregon, Kentucky, Iowa, California - Los Angeles County, Hawaii, Kansas, Michigan, Wyoming, Virginia, New York. Lovenia Murray of FMS facilitated the teleconference.

FMS Web site for Teleconference Notices

Both FMS and OCSE recommend that federal agencies and states visit the FMS website and subscribe to their notification service: http://fms.treas.gov/csp. Once registered, you will receive an e-mail each time something regarding EFT/EDI for child support is posted, including notice of teleconferences and minutes. When you receive notification of an upcoming teleconference, register for the call so that FMS can gauge how many lines to reserve. OCSE will be sending a message regarding this on the OCSE EFT/EDI listserv.

Status of Federal Agency Conversions

NFC case reconciliation is in full operation. NFC has reconciled with 21 states since sending out the files on March 8.

GSA has fully converted all eligible states to EFT/EDI. California will continue to receive paper checks. GSA is not able to transmit to counties at this time.

NBC has completed reconciliation and is beginning a phased in implementation. They agreed to provide FMS/OCSE and the states a copy of their implementation schedule.

DFAS has three EFT/EDI conversion projects for child support underway. 39 states have been converted for the Retired military; 7 have been converted for the Active Duty (with 30 files returned and need reconciliation); and 35 Reserve files have been received but not yet reconciled. OCSE offered to assist DFAS in making calls to states to ensure all have responded.

OCSE is interested in hearing from any state that wants to report how many case numbers or redirect changes were made. NY reported minimal changes to their files.

Federal Agency Case Reconciliation/Interstate Case Reconciliation

OCSE reported that the large files sent from NFC for reconciliation are arriving at about the same time states are embarking on a significant interstate project. The timing was unavoidable, given NFC's small window of time to devote to EFT/EDI. NFC plays a key role in the OPM e-payroll consolidation effort and is taking on large new clients throughout 2004. OCSE recommends that states do their best to accomplish both their interstate case reconciliation and their NFC reconciliation. The next time NFC can work on EFT/EDI for child support will be in October. Given all that can happen between now and then, it's advised that states look to responding in sufficient time for the June conversion rather than October.

OCSE also reported that they and FMS are tracking the conversion to EFT/EDI closely to ensure as many agencies are converted by December 2004. The SSN will be removed from Treasury checks at that time so it's imperative that agencies and states conduct case reconciliation. While it appears many federal agencies will be converted by December, there may be some that won't be. In any event, case reconciliation needs to occur. Given the level of effort involved in the Interstate Case Reconciliation project.

SSA, with a large number of child support orders, is working with FMS to find a solution to the SSN removal, and EFT/EDI conversion by the December 2004 time frame. SSA is evaluating this internally, and will report back to FMS in May on its preferred approach for conversion.

Technical Discussion

1. DED05 Non-Custodial Parent's Name

Currently the DED05 Non-Custodial Parent's Name field is optional. A federal agency received feedback from a state that was unable to process the file because the last name was not included. It is recommended that states, when reconciling cases with a federal agency, discuss outstanding issues such as reliance on a particular element to prevent errors such as this. OCSE reported that they would be consulting with NACHA on changing this field from optional to mandatory.

2. Date of Receipt

The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 gives states the choice of using "date of withholding" or "date of receipt" to indicate the beginning of the two business days by the end of which states must disburse the child support payment to the custodial family. Most states use "date of receipt" because of problems encountered when using "date of withholding." For example, some employers enter a pay date (date of withholding) but then there is a considerable amount of time before the payment is remitted to the state.

The DED03 Pay Date indicates the date of withholding, and for some federal agency employers, this may be a future date. Entering a future date has caused problems for some state systems. Therefore, most SDUs do not use the DED03 Pay Date to indicate when they received the payment and when they have to disburse payments (i.e., within two business days of date of receipt).

Most SDUs use either the day the electronic payment arrive or the Settlement Date (field 10 on the Company/Batch Header record) to indicate when they received payment and when the "clock" starts ticking on the two-day disbursement rule. The Settlement Date is populated by the ACH operator (Federal Reserve) automatically. It is usually the same as the Effective Entry Date (field 9), which is the date entered by the originator (Treasury's Financial Management Service on behalf of a Treasury disbursing agency, or a Non-Treasury disbursing agency) unless there is an error in the Effective Entry Date, where upon the ACH operator enters a different, corrected Settlement Date. The Settlement Date will NOT be a future date, so SDUs would not have a problem using it as the date of receipt. The Settlement Date should always correspond to the actual payment date of the file, which is when the payment amount is credited to the payee’s (state’s) account.

3. CTX 820 GS03 Field of the GS Segment

There was a discussion on the January 21 Teleconference Agenda Item titled "DFAS CTX 820 Format Issue" that was included on this agenda by Iowa with the intent of a reverse decision from DFAS on the structure or use of the GS Functional Group Segment/GS03 Data Element field. DFAS' justification and decision on this issue remains the same as stated in the January 21 Teleconference Minutes. OCSE/FMS offered to meet off line with the states that wanted to discuss this further.

Teleconference

The next teleconference is scheduled for May 19, 2004 at 2:00 p.m., EST. Please forward your agenda items to Lovenia.Murray@fms.treas.gov by May 12, 2004.