|
INFORMATION MEMORANDUM
IM-06-03
DATE: March 23, 2006
TO:
STATE AGENCIES ADMINISTERING CHILD SUPPORT ENFORCEMENT PLANS UNDER TITLE
IV-D OF THE SOCIAL SECURITY ACT AND OTHER INTERESTED INDIVIDUALS
SUBJECT: Social Security Administration (SSA) National Garnishment Database titled, "Court Order Garnishment System (COGS)"
BACKGROUND:
Over the past several years, the Federal Office of Child Support Enforcement
(OCSE) has collaborated with the Social Security Administration (SSA) on a
number of nationwide initiatives affecting the missions of both agencies and
the people we serve.
Recently, SSA implemented a national garnishment system, titled “Court Order
Garnishment System (COGS)” that will overhaul current business processes and
improve SSA’s ability to respond to income withholding orders from child
support agencies. As part of the new system, COGS will automatically identify
individuals whose Title II Benefit claims are pending and flag any case for
which an income withholding order has been received by SSA. OCSE appreciates
the consideration SSA has given to the Child Support Enforcement (CSE) program
and looks forward to many years of continuing our productive partnership.
COGS – CSE Contact Information
COGS will rely heavily on up-to-date contact information from CSE agencies.
When SSA receives an income withholding order (IWO), the local SSA office
staff will immediately enter the IWO information and record the contact name,
address, telephone, and internet address for the CSE agency. SSA may also use
the contact information listed in the State Disbursement Unit (SDU) Contacts
matrix on the OCSE Employer Services Website:
http://www.acf.hhs.gov/programs/cse/newhire/employer/contacts/sdu_matrix.htm.
The SDU Contacts matrix is being amended to include contact information for
lump sums and certain income withholding orders. (OCSE will contact CSE
agencies for this information in a separate communication.)
COGS – IWOs/Lump Sum Payments
SSA will review each IWO and if determined to be regular-on-its-face and
benefits are currently being paid, SSA will immediately withhold and remit the
child support payments. However, SSA may need to contact CSE agencies in the
following situations:
• Income Withholding Orders and Pending claims. When an IWO is received, SSA
will review the IWO, and if it determines that the noncustodial parent’s (NCP)
disability claim is pending and no current payments are being made, local SSA
staff will enter the IWO into COGS pending resolution of the NCP’s claim. Once
the claim has been resolved, if it has been more than one year since the IWO
was originally received by SSA, SSA will contact the agency issuing the IWO to
make sure it is still valid before remitting any payments.
• Lump sum payments. SSA’s new system has a built-in tracking system that
should prevent the erroneous release of lump sum payments when an IWO is in
place. If an IWO is on file at SSA, SSA will hold all lump sum payments
totaling more than $500.00 as described below.
o If there are specific instructions on the IWO for handling lump sum
payments, SSA will follow those instructions and automatically withhold up to
the Consumer Credit Protection Act (CCPA) (or state) limit and send the
remainder to the beneficiary.
o If there are no instructions on the IWO regarding the attachment of lump sum
payments, an alert will be issued for the SSA payment center staff to contact
the CSE agency to obtain current information on the amount to withhold from
the beneficiary member’s account. COGS will also withhold the CCPA limit from
the lump sum in this situation.
IMPORTANT NOTE: SSA will hold the lump sum payment and suspend all
ongoing payments until contact has been made with the CSE agency to determine
if there should be a withholding and, if so, what amount. It is critical for
the SSA payment center staff to be able to reach the CSE agency in a timely
manner and receive a verbal or written response with respect to the lump sum
payment. Ongoing payments should resume once this communication has been made.
COGS – Income Withholding Information
Where to send IWOs
All income withholding orders should continue to be sent to any local SSA
office. To identify the nearest SSA field office, go to
https://s044a90.ssa.gov/apps6z/FOLO/fo001.jsp.
Sending IWO’s to a local SSA field office is a change for child support
enforcement agencies in Arkansas, Louisiana, New Mexico, Oklahoma, and Texas
that had previously been notified in IM-05-11, dated November 18, 2005, to
send IWOs to a centralized garnishment unit in Albuquerque. Albuquerque will
no longer be accepting income withholding orders for these five states. All
IWOs for these states should now be sent to any local SSA office.
The local SSA office will enter the case data into the electronic database.
The information will be updated overnight and can be tracked online by the SSA
worker.
OCSE will be in continual communication with SSA during the implementation of
COGS. Conference calls with states will be scheduled as necessary to share
information throughout the implementation.
INQUIRIES:
Please direct inquiries to your state technical support liaison at http://www.acf.hhs.gov/programs/cse/newhire/contacts/fcrtscontacts.htm
or to Pat Driggers at (410) 966-5181 or pdriggers@acf.hhs.gov
or Pat.Driggers@ssa.gov.
______________________________
Margot Bean
Commissioner
Office of Child Support Enforcement
cc: Tribal IV-D Directors
|
