WASHINGTON, WEST VIRGINIA

Automating Quarterly Wage Income-withholdings

Building on the successes of Vermont, Virginia, and Delaware, West Virginia and Washington have automated the generation of income-withholdings based on Quarterly Wage data. Both States have experienced some significant success with the automation of this data, despite some initial concerns that the age of the data might limit its usefulness. Descriptions of the West Virginia and Washington processes and selection criteria used for the automation of Quarterly Wage data follow below.

WEST VIRGINIA

West Virginia has developed an automated process to generate income-withholdings (AIW) on matches that occur with their State Directory of New Hires (SDNH) as well as on new hire and quarterly wage matches received from the National Directory of New Hires (NDNH). The process is run daily for the SDNH matches and upon receipt of matched information from the NDNH. The following is a description of the process for completing an automated income-withholding on the quarterly wage matches.

General criteria

West Virginia maintains a database that contains the employer's Federal Employer Identification Number (FEIN), name, address and contact number. As the employer data from the NDNH is added to West Virginia's NDNH screens, a program also loads the employer data from the quarterly wage matches to the State's employer database. Then, the automated system checks for cases with orders for child/spousal support, medical support, arrears or a combination of these obligations and updates the case with the NDNH quarterly wage match.

The case matches to be considered in the AIW process are checked against the noncustodial parent (NCP) employment screens to determine if the FEIN is or has been known to the case. If the FEIN is known to the case and a current or a past income-withholding has been issued against the FEIN, the system will not generate another income-withholding. If the FEIN is known to the case, but no current or past income-withholding has been issued, the system will generate an income-withholding. If the FEIN is not known to the case, the system will automatically add the FEIN to the employment screen and issue an income-withholding.

Exceptions

The above process brings the case to the point of automatically issuing the income-withholding. However, a match may meet all the general requirements for an automated income-withholding, while more specific circumstances about the case may not allow the income-withholding to generate without worker intervention. West Virginia has identified the following as exceptions:

• Any matches where the NDNH Date of Address is greater than four-months-old are excluded from the AIW process. However, even in those cases where the date of the address is greater than four-months-old, the NCP employment screens are checked to see if the FEIN is or has been known to the case. If the FEIN is known to the case and a current or a past income-withholding has been issued against the FEIN, the system disregards the match. If the FEIN is known to the case, but no current or past income-withholding has been issued, the system adds the information to a worker's alert list. If the FEIN is not known to the case, the system adds the information and alerts the worker.

• If a case is an interstate initiating case, it is excluded from AIW. The worker is alerted and determines whether the responding state is enforcing the order and decides if direct income-withholding is appropriate.

• If there are multiple employer accounts, the case will be excluded from AIW. There are instances where employers operate more than one business under the same FEIN and, in these circumstances, the worker must review the case to ensure that the income-withholding is generated to the appropriate employer.

• If family violence flags are set on the CP/Child, the case is excluded from AIW. The worker receives an alert and reviews the case to assess the appropriateness of an income-withholding.

• If immediate income-withholding has been suspended for some reason (e.g. language in the court order), the case is excluded from AIW, but the worker reviews the case to assess the appropriateness of an income-withholding.99

Reports generated

Upon completion of the AIW routine, the system generates the following reports to workers:

• All cases in their caseload that had an income-withholding automatically generated. This provides the worker with the opportunity to review the cases to ensure that income-withholdings were appropriate and accurate.

• All cases in their caseload that met the general criteria for income-withholding, but fell into one of the exception categories. This work list is structured to maintain a two-day timeframe for completion of the income-withholding.

• All other obligated cases in their caseload that did not meet the general criteria for income-withholding, but may need to be reviewed for other enforcement activities.9

Lessons learned

There were a number of issues that occurred during the process of automating that West Virginia had to resolve. In the initial process, the State did not check to see if an income-withholding had been previously generated and subsequently terminated before issuing an income-withholding on a quarterly wage match. Many times with quarterly wage, an employee comes and goes before the information is received. The system now checks for a past income-withholding to the same employer before processing the match any further.

Employers operate multiple businesses with the same name, but different FEINs. If a worker received the employer information prior to receiving information regarding the correct FEIN, s/he may select the employer by name from the employer table and use the wrong FEIN. When the NDNH quarterly wage match is received, it would generate an income-withholding under the new FEIN. This may confuse the employer because s/he now has two income-withholdings. In order to minimize this problem, West Virginia now includes those employers with multiple FEINs in the exception criteria.

Initially, West Virginia did not generate an income-withholding automatically if an income-withholding already existed on another employer. The State tried to prevent double dipping from a part-time employer. The state soon realized that workers were not reviewing these reports quickly enough and they were missing their two-day timeframe. Additionally, and mainly for new hire matches, the State found that the larger percentage of matches were for new employment and not part-time employment. West Virginia now generates the income-withholding automatically if the criteria are met even though there is an existing income-withholding to another employer. The worker receives a message that this has been done and can terminate it if necessary. The State found this to be a much more proactive and cost-effective approach.

For further information on the West Virginia process contact Jim Dingledine at (304) 558-3582 or at jimdingeldine@wvdhhr.org.

WASHINGTON

Washington chose to have its automated system query a case and make determinations regarding whether or not to issue a wage-withholding form based on a number of specific selection criteria. For example, the source of the data must be either in-state or NDNH quarterly wage. The employer must be a new employer to the system and must be the most recent on the system. (There is logic in the system to determine if the match provided contains more recent information than other employment data on the case.) The wage-withholding indicator on the statewide system must equal "yes." No payment, other than Federal Offset payments, can have been received in the previous 62 days. No payment from Unemployment Compensation or Labor and Industries (Workmen's Compensation) can have been received in the previous 90 days. The enforcement services code on all cases associated with a particular noncustodial parent must equal a value that indicates enforcement for child support and/or medical support is appropriate. An order must have been served.

The event status on the statewide system must indicate that the case is in enforcement, locate for assets, or maintenance category. Arrears rolled up from all cases must be greater than $500 and three times the total monthly amount due on all cases. A wage-withholding form must not have been sent to any employer in the previous 15 days. The noncustodial parent must have only one Social Security number. Initiating interstate cases as well as cases referred to the Prosecuting Attorney for contempt are excluded.

After the system processes cases through these selection criteria, the system automatically prints a wage-withholding form. The wage-withholding form orders payment for current support and the total arrears amount if the arrears are less than $100; or current support and $100 for arrears up to $1,000; or, if the arrears are over $1,000, current support and 10% of the arrears amount, with a maximum of $250. In addition, the system stores the employee address information identifying the source as either in-state or NDNH quarterly wage information.

Once the wage-withholding form is generated, the system sends an informational alert to the worker. If the system was unable to generate a wage-withholding, the system will generate a different alert to tell the worker that action needs to be taken on the case but the system cannot automatically complete the action.

For further information on the Washington process contact Carl Tiller at (360) 664-5397 or at ctiller@dshs.wa.gov.