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POLICY INTERPRETATION QUESTIONS
PIQ-06-02
DATE: March 29, 2006
SUPERCEDES: PIQ-05-05
TO: State IV-D Directors
FROM: Margot Bean, Commissioner Office of Child Support Enforcement
SUBJECT: Guidance for Sending the National Medical Support Notice (NMSN) to the Defense Manpower Data Center (DMDC)
BACKGROUND: The Federal regulations at 45 CFR 303.32(a) require use of the NMSN to enforce health care coverage where appropriate. PIQ-02-03, issued December 20, 2002, discusses the term “where appropriate” and states that “if the employer does not provide health care coverage for employee dependents, there would be no need for the IV-D agency to send the NMSN for those employees. However, the IV-D agency should make appropriate notation in the individual case record of the unavailability of health care coverage through that employer.” The PIQ is silent on procedures for sending the NMSN to the DMDC concerning health care coverage for dependents of active and retired military members.
QUESTION: Do IV-D agencies need to send National Medical Support Notices to the DMDC for children of active duty military personnel or military retirees?
ANSWER: No. Regulations at 45 CFR 303.32(a) require use of the NMSN to enforce health care coverage where appropriate. We have determined that it is not appropriate to send the NMSN to DMDC to enforce health care coverage for dependents of active duty military or retired military personnel. DMDC is unable to enroll dependents in the military health care program, TRICARE, which is an automatic entitlement for military personnel and their dependents. Therefore, IV-D agencies should not send the NMSN to DMDC for dependents of active duty and retired military personnel.
IV-D agencies can determine whether the children are enrolled or eligible to be enrolled in TRICARE by the following means:
If a child is determined to be eligible for enrollment, as indicated by the DMDC/FCR match or by the FEIN from the New Hire Report or the Quarterly Wage Report, the IV-D agency should instruct the custodial parent to contact the nearest military ID Card issuing facility with the proper documentation to initiate the enrollment for the dependent. The IV-D agency should indicate in the individual case record where it obtained the child’s medical enrollment status and make appropriate case updates from the next quarterly DMDC/FCR match.
Department of Defense FEINs:
Please note that there have been changes with the Health Insurance Portability and Accountability Act (HIPAA) since the publication of IM-96-02.The DEERS Telephone Center at DMDC referenced in PIQ-05-05 can no longer provide enrollment status of military dependents by telephone because of privacy restrictions and should not be used to request the enrollment status of military dependents.
This PIQ does not apply to the Department of Defense civilian personnel.For civilian employees, IV-D agencies must continue to send the NMSN to the Employer Address provided in the NDNH/Quarterly Wage reports.
cc: ACF Regional Administrators
ACF CSE Regional Program Managers
Tribal IV-D Directors
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