DCL-99-97, Follow-up to Federal Offset Conference Calls

DCL-99-97

Date: Sep 13, 1999

TO ALL STATE IV-D DIRECTORS

RE: Follow-up to Federal Offset Conference Calls

Dear Colleague:

The Office of Child Support Enforcement (OCSE) Special Collections Branch thanks each State for participating in our recent conference calls. We hope the calls were beneficial in explaining the requirements for submitting new cases for Processing Year (PY) 2000. OCSE realizes that these instructions are a change from our original plans, but we believe we'll provide a better service because of your efforts.

Attached to this letter is a list of questions States asked during the conference calls. We have also included the action items from the conference calls and have identified those action items we have completed.

Also attached is a replacement for the current Exhibit N "Input File Specification." The last record, "State Control Record Specification," was inadvertently omitted when OCSE issued DC 99-75. Please replace the three page Exhibit N currently found in DC 99-75 with the four page Exhibit N included with this letter.

The most current version of OCSE's Pre-Offset Notice is also included. Based on conversations with States during the Conference Calls, OCSE has changed the wording relating to the Passport Denial Program.

If you have any questions or need assistance, please call Scott HaleHH, Technical Liaison, at (202) 401-9390 or Sueanne Dennard, Program Coordinator, at (202) 401-5556.

Thank you for your continued support and cooperation as we work to improve the lives of our nation's children.

Sincerely,

David Gray Ross
Commissioner
Office of Child Support Enforcement

Attachments

cc: Regional Program Managers
Federal Offset Contacts

NOTES FROM CONFERENCE CALLS

July 29 - August 4

Background

When will the new User's Guide and Action Transmittal be issued?

They will be issued this fall. Our target time is early October.

Submittal Process

Are there any technical specification changes for the input format?

No.

What is the minimum amount that can be submitted for Offset?

A new case must have an arrearage of more than $25 or it will be rejected.

What code should go in Position 73 Exhibit N for the PY2000 submittal file?

Position 73 should be blank for the entire file.

What code should be used for Process Year (Position 80-83, Exhibit N)?

Processing year only relates to State Payments; because the field is a required numeric field, fill it with "0000".

What States need to submit Exhibit A; those who issue their own Pre-Offset Notice (PON), or those that have OCSE send out their PON?

All States need to submit Exhibit A.

How long is Exhibit A good for?

Exhibit A covers all new submittals for PY2000, including cases that will be sent via weekly updates.

What will be in the Priority Code Field (Exhibit J, Position Numbers 76-77)?

Priority for cases previously submitted will be the same as they are now. Priority for new cases will be determined by the order in which OCSE receives them.

Do States need to continue to send in a fax with weekly updates (AT 98-17 Exhibit E)?

OCSE is eliminating this step. States do not need to fax their totals to OCSE, because the totals are included in the control record.

Do States need to update the exclusion indicators on the submittal file?

Yes. It is important that the exclusion indicators reflect how you want the case to be handled. If there are no exclusion indicators for the case, it will be subject to all offsets and passport denial if it meets the criteria.

What will the States receive after the records are processed?

OCSE will send out Exhibit H, Reject file.

How long will cases remain active on the OCSE Master file?

Cases will remain active until the balance goes to zero or the case is deleted by the State.

How long does OCSE hold new cases before they are sent to FMS?

All new cases for the submittal process will be sent to FMS on December 15, 1999.

Pre-Office Notices (PON)

When can the unaccountable files be expected?

September submittal States should receive their files in October.

November submittal States should receive their files in December.

What is considered a new case for PY2000 that would receive a PON?
1. Any case not previously submitted in PY1999
2. If a collection in PY1999 on a case resulted in the arrearage equaling a zero balance,
3. If the State submitted a modification in PY1999 which brought the arrearage balance to zero, or
4. If the State deleted the case in PY1999.

If OCSE sends out a State's PON, who will identify cases that need a notice?

OCSE will follow the State's instructions per Exhibit A. If a State selects "mail notices only on new cases," OCSE will identify which cases meet the criteria for a new case.

How often do State/Local addresses have to be updated?

Whenever they change; submit changes via Exhibit D (DC 99-85).

How is the PON affected if an obligor has both a TANF case and a Non-TANF case?

OCSE sends two notices out at the same time, one for each case.

Is it possible to have only one address on the PON? Having two addresses sometimes confuses obligors.

The notice requires two addresses; one of these addresses shows through the window of the envelope when it is mailed. However, the addresses may be the same if the contact address is the same as the return address. See Exhibit S (DC 99-82).

Can OCSE use the State address on the PON?

Yes. The State has the choice on which addresses are placed on the PON. See Exhibit S (DC 99-85).

Do States have to send PONs Annually?

There is no Federal requirement for States to send PONs annually. However, OCSE recommends that States send an annual notice. OCSE will follow the State's instructions per Exhibit A of DC 99-75.

What happens to cases that received a PON in PY1999?

The State can determine if previously certified cases that do not meet the criteria for a new case will receive a PON. If OCSE sends your PON, annotate the appropriate block on Number 3 of Exhibit A of DC 99-75.

Does the PON have to be cleared by the Regional Directors if it hasn't changed?

No, but OCSE strongly encourages you to add language similar to the first paragraph of our PON (Exhibit C, DC 99-75) letting the obligor know that if they were previously submitted, they are subject to immediate offset.

Can OCSE guarantee that the local codes will be correct?

OCSE will do our best to ensure the correct local codes are placed on the letters. For OCSE to ensure that correct addresses are used, please be certain to update local codes using Exhibit D, DC-99-85.

What if a State does not want to send out a PON on a previously certified case?

If a State sends their own PON's the State must include in the file the date the PON was originally sent. The PON date is used for new cases to insure that the PON notice was sent. If OCSE sends out a State's PON, we will follow the instructions provided by the State per Exhibit A, DC 99-75.

Will OCSE send a new PON for a case that had a significant change in the balance?

Only if the State notifies OCSE to send the notice on Exhibit A.

Will the name that was on the PY1999 PON be the same on the PY2000 PON?

Yes, because FMS cannot accept name changes at this time.

Why does FMS send out PONs for offsets?

FMS sends out warning notices only when there is a match for an Office of Personnel Management (OPM) retirement payment. OPM requires that a 60-day and a 30-day Warning Notice be sent to an obligor before Federal retirement payments can be offset.

NOTE: This applies only to OPM Federal retirement payments.

Addresses

What will be on the unaccountable tapes?

Cases where OCSE was not able to obtain an address.

OCSE will attempt to obtain the address information for both OCSE sent PON's and State sent PON's from these sources in the following order:

State submittal file
OCSE's address file based upon an offset or certification in PY1999, or
OCSE will send the case to the IRS in an attempt to obtain an address.

If OCSE is still unable to obtain an address, we will submit the SSN to SSA to try and find a corrected SSN. If a corrected SSN is found it will be sent back to the States. States should then resubmit that case using the corrected SSN.

If OCSE mails a State's PON and is unable to obtain an address to send a Notice, the case will be rejected. If a State issues their own PONs and no address is obtained, OCSE will still forward the case to FMS. However, if the individual is receiving a payment and no address is associated with the payment, FMS will not offset the payment. This is because there must be an address to mail the offset notice.

States will only receive two error codes on the unaccountable file. Error Code 18, "SSN not on IRS file," and Error Code 31, "SSN did not verify, however a corrected SSN was located by SSA."

Why does FMS need an address from the State?

When FMS offsets an obligor, they must send them an offset notice, even if it is an electronic payment. Generally there is no address associated with an electronic payment.

What if FMS offsets an obligor and they have a more current address from a payment agency?

FMS will use the address on the payment to mail the offset notice. OCSE will use the payment address on the collection report to update the Master file, then forward that address to the State. OCSE does not forward any other addresses back to the State at this time.

Reconciliation with OCSE and FMS

Why can't OCSE just delete what States currently have on file, and accept a whole new file?

OCSE could do this, but FMS can't. Once a file is established at FMS, it is never deleted, it is only inactivated. In order to be sure that the files are the same, we must match each file, to include all exclusion indicators, and send the corrected information to FMS.

Will States have to reconcile every year with OCSE?

Hopefully we will be able to get our files in sync, and not have to do this again. We will review this issue as PY2000 progresses.

When will OCSE accept new add cases?

States can add new cases with their State certification file. If a State submits an add case with the weekly update file, between now and the end of 1999, they will receive Error Code 07 "invalid transaction type." States can add cases beginning in January 2000.

Why can't add cases be accepted until the first of the year?

In order to properly reconcile our caseload, we will not accept any new "add" cases.

What if an obligor's name changes?

FMS has no ability to change a name. If the name and SSN do not match at FMS, the record will be rejected. FMS does, however, have the capability to match against up to 10 different aliases. Even if you don't change the name, the certified name may match one of the aliases on file.

Updates

When can States send in updates?

For September submittal States, updates can be sent in from now until Sep 1, then from Oct 16 – Nov 15.

For November submittal States, updates can be sent in from now until Nov 1.

Updates include: Deletes, Modifications, and State Payments.

Add cases need to be sent in via the submittal file (Sep or Nov) and then after Jan 3.

When can States expect to receive collection files?

Collection files are usually distributed around the 27^th. The money is usually forwarded (EFT) the first week of the following month.

Why does it take so long between receiving the file and the hard copy collection report?

States are really receiving the file about a week earlier than they did in the past because of CONNECT:Direct (C:D). OCSE is considering sending the report electronically. However, all of the information contained in the faxed report is in the trailer record of your electronic file. There is really no need to wait until the faxed copy arrives to process your cases.

Can new cases added on the submittal file be updated?

September States can update their cases between Oct 16 – Nov 15. However, the amount that was on the submittal file will be the amount used on the PON.

Can a State delete cases after the submittal file is processed?

For September submittal States, delete cases can be sent in from Oct 16 – Nov 15.

All States can delete cases in the first three weeks of January to bring their files up-to-date. OCSE doesn't anticipate that any IRS offsets will occur before the end of January.

How will OCSE know when a State has submitted their caseload?

States should call the Special Collections Branch (202) 401-9389 when they send their file. If OCSE doesn't receive the file from your State, we will follow-up.

After the submittal process, how does a State update a case?

Per DC 99-75, submit Exhibit N with a "M" indicator in Position 73, Transaction Type. The "M" will update the balance. To change the Exclusion Indicators, States must use the Transaction Type "R" to replace the Exclusion Indicators. Essentially, to ensure the entire case is updated, the State must send in two transactions for each record.

NOTE: For the annual update, States should send in only one record per case and leave the Transaction Type blank for the entire caseload.

What would happen if a State tried to add a case that was already at FMS?

Once OCSE has reconciled all records through the annual submittal process, the State would receive an error code "18 - Invalid transaction type."

Will OCSE continue to hold the cases for 60/90 days?

OCSE is reviewing its policy of holding cases. We will send further guidance when a decision has been made.

Passport Denial

What happens once a new case reaches the $5,000 threshold?

The case will be forwarded to Department of State (DOS).

What if a case that is at the DOS goes below the $5,000 threshold?

OCSE will do nothing. The case will not automatically be deleted as it was in the past. The State can make the determination to delete the case, or let it remain at DOS. If the determination to delete the case is made, the State must initiate the action via Exhibit N.

When did this process begin?

July 19, 1999; see DC 99-75.

Can States fax requests in to remove obligors from the Passport Denial Process?

Yes, OCSE will accept faxes for those cases that qualify. A case qualifies if it is a "life and death situation." Confirmation from a doctor is needed to verify the life and death situation. OCSE will work with individual States that cannot yet delete cases via C:D.

What if a case had a balance of $5,000 in PY1999, but on the submittal, the balance is now $3,000?

OCSE will forward cases that had previously exceeded the $5,000 threshold to DOS for PY2000. This will occur if the case was previously removed only because the balance went below $5,000, not if they were manually removed or excluded. If a State does not want a case submitted that was previously removed, include the exclusion indicator for Passport Denial with that case.

What if the arrears on a case go to zero?

That case will be deleted from the OCSE Master File and at DOS.

What procedures should States follow, if during the freeze period, the Non Custodial Parent is denied their Passport and the State clears them to receive their passport?

Fax OCSE a Withdrawal Notice and we will process the case and notify DOS.

Miscellaneous

When can the States expect to receive fees that were charged for erroneous on fully reversed offsets?

Refunds for fees will be sent to the States after the last collection report. OCSE will inform States as soon as the process has been established.

What types of payments can FMS Offset?

FMS can offset OPM/Federal retirement, vendor & miscellaneous payments. FMS will be adding Federal Salaries and Social Security (SS) benefits in the future, However, Federal law prohibits OCSE from offsetting SS benefits. OCSE will work with the States to determine the feasibility of offsetting Federal salaries before adding them to the offset stream.

ACTION ITEMS

(All Action Items are for OCSE, unless otherwise noted)

OCSE has already begun to work on the action items that were noted during the Conference Calls. Some of the Action Items will be accomplished with the rewriting of AT 98-17; others will be delegated as long-term goals and objectives. OCSE will keep States appraised of the status of these as we complete them.

Determine if addresses are required on Electronic Payments.
Review Exhibit "K" Unaccountable Record Specifications. Clarify and incorporate in new User's Guide.
Review/define error codes better; change duplicate error code (18) if possible.
Review due-process policy of holding cases for 60/90 days; should States hold cases? Or should OCSE hold cases?
Set up a teleconference to discuss the 60-day hold process.
Review wording on PON regarding Passport Denial. As written, leads obligor to believe that they will be removed from the program once the arrearages fall below $5,000. Completed.
Let States know what the processing fees will be as soon as OCSE finds out from IRS/FMS.
Determine how OCSE will refund fees on reversals to States.
Develop Best Practices to share with other States.
Explore developing a way to send addresses back to States if OCSE has one and the State doesn't.
Check to determine if there is a way to notify States which cases were sent to DOS for Passport Denial.
Publish the Date the adds were last sent to FMS. Completed.
Explain the "M" vs. "R" in writing in the next DCL. Completed.
Review the process of deleting a case when the balance falls to zero; consider inactivating the case instead.
FMS will brief the taxpayer assistant line attendees to tell obligors that the money was not sent to the State. In progress.
Review the policy for Injured Spouse Claims with FMS and IRS. In progress.
Review the policy of sending the name change report on the monthly collection report.
Notify the States in advance if OCSE cannot meet the timeframes indicated in DC 99-75.
Confirm $25 threshold with FMS. Completed.
Review States comments on FMS Offset notice and provide feedback to FMS. In progress.
Review correction for State Payment on prior years offsets (CT/OCSE).
Change wording on Exhibit N, Process Year (position 80-83): field is not required for States sending submittal file – it's only needed for a State payment.
Evaluate impact of name changes and "freeze" information on the Financial Institution Data Match (FIDM) program.
Accept a State Payment if the amount is greater than the collection.

INPUT FILE SPECIFICATION

This exhibit includes the layout for records that are accepted by the OCSE Federal Offset Program System. The record layout in this section includes the following information:

Field name;
Position;
Length;
Type (alphabetic, numeric or alphanumeric); and
Criteria.

The Criteria section of the record layout indicates whether the field is required or optional and provides a description of the field and its relationship to other fields. Fields defined as Required must be present on the input record. Additionally, allowable values regarding each field are explained.

The data transmitted to OCSE must comply with the following requirements:

All data must be in EBCDIC format.
All alphabetic data must be in upper case.
All alphabetic and alphanumeric data must be left justified and space filled.
All numeric data must be right justified and zero-filled.
All dates must be in the Year 2000-compliant format of CCYYMMDD.
All Filler fields must be filled with spaces and not low values.

SUBMISSION/UPDATE SPECIFICATIONS FOR FEDERAL TAX REFUND OFFSET, ADMINISTRATIVE OFFSET AND/OR PASSPORT DENIAL

INPUT FILE SPECIFICATIONS

STATE SUBMITS TO OCSE

Submission Requirements

All submissions must use Connect: Direct to send information to OCSE for submission/update to the Treasury Offset Program (TOP) for debt collection.

Submission Requirements
Field Name	Position	Length	Type	Criteria
Submitting State	1-2	2	Alpha	REQUIRED. Must be valid FIPS 2 character alpha abbreviation for the State, which initially submits the case for offset; must be constant throughout the file. (See Exhibit Y - FIPS Pub 6-4).
Local Code	3-5	3	Numeric	When used it must be three-digit numeric local code. FIPS code is suggested (See Exhibit Y - FIPS Pub 6-4).
SSN	6-14	9	Numeric	REQUIRED. Must be valid Social Security number.
Case Number	15-29	15	Alpha-Numeric	Optional field for State use only; blanks acceptable.
Last Name	30-49	20	Alpha	REQUIRED. Must not be all blanks; start name in column 30, must be uppercase. No imbedded blanks or apostrophes.
First Name	50-64	15	Alpha	REQUIRED. Must not be all blanks, start name in column 50. Imbedded blanks acceptable.
Amount Owed	65-72	8	Numeric	REQUIRED. Whole dollar amounts only. No decimal points, dollar signs, commas or plus/minus signs. Right justify and zero fill (Example: 1500.00=00001500). If amount submitted is at least $150 for TANF/foster care, the case will be subjected to Tax Refund Offset. If amount submitted is at least $500 for Non-TANF, the case will be subjected to Tax Refund Offset. If amount submitted is at least $25, the case will subjected to Administrative Offset.
Transaction Type	73	1	Alpha	REQUIRED. Blank = Initial Submission (Entire Case Load) A = Add New case1 D = Delete L = Change Submitting State Local Code M = Modify Decrease or Increase (indicate Replacement Amount) R = Replace Offset Exclusion Indicator Type2 S = State Payment T = Transfer for Administrative Review to State with the order
Case Type Indicator	74	1	Alpha	REQUIRED. A = TANF/foster care N = Non-TANF
Transfer State	75-76	2	Alpha	Must be valid FIPS 2 character alpha abbreviation; must be constant throughout the file. (See EXHIBIT Y - FIPS Pub 6-4). Required when State submits transfer. Required when transfer State updates a case. ³
Local Code for transfer	77-79	3	Numeric	When used it must be three-digit numeric local code. FIPS code is suggested (See EXHIBIT Y - FIPS Pub 6-4).
Process Year	80-83	4	Numeric	REQUIRED when submitting a State Payment. Year Tax Refund/Administrative payment was offset. For reporting State payment (CCYY).
Address Line	84-113	30	Alpha-Numeric	Non custodial Parent's mailing address line1 if State issues own Pre-offset Notice. Required if State issues own notice.⁴
Address Line2	114-143	30	Alpha-Numeric	Non custodial Parent's mailing address line 2.⁴
City	144-168	25	Alpha	Name of City.
State Code	169-170	2	Alpha	State Abbreviation.
Zip Code9	171-179	9	Numeric	9-Digit Zip Code.
Date Issued	180-187	8	AN	Indicates the date the Pre-offset Notice was sent out. If OCSE issues the notice, we will fill in the date. If the State issues their own Pre-offset Notice the format is CCYYMMDD.
Offset Exclusion Indicator	188-227	40	Alpha	ADM = Exclude all Admin. Offset (RET, SAL,VEN)⁵ RET = Exclude Federal Retirement VEN = Exclude Vendor Payment/Misc. SAL = Exclude Federal Salary TAX = Exclude Tax Refund Offset PAS = Exclude Passport Denial FIN = Exclude Financial Institution BLANK = No Exclusion
Filler	228-245	18	Reserved	Space filled.

If the amount is less than $25, it will be rejected as "invalid amount."
Use transaction Code R to REPLACE Offset Exclusion Indicators.
The term "Transfer State" will be used for interstate cases requiring an administrative review in the State with the order. When a case is referred for the review to the State with the order, the submitting State must notify OCSE through the update process that the case is being transferred. See update section for specific information.
If the State mails their own Pre-offset Notice and does not provide an address, OCSE will forward the case to FMS. However, FMS will only offset if the payment has an address. In other words, there must be an address for FMS to mail the offset notice to. For this reason, States are strongly encouraged to provide addresses, even if they send out their own pre offset notices. If OCSE mails out the Pre-offset Notice for a State, we will try to obtain an address. If we cannot obtain an address, the case will be rejected.
Enter each exclusion indicator and a comma or space. For Example: SAL,PAS,RET. If the Offset Exclusion Indicator is TAX, the Amount Owed must be at least $25.

STATE CONTROL RECORD SPECIFICATION (Last Record on File)
Field Name	Position	Length	Type	Criteria
Submitting State	1-2	2	Alpha	Submitting State Abbreviation.
Control	3-5	3	Alpha	Enter constant "CTL"
TANF Count	6-14	9	Numeric	Total TANF record count. Right justify and zero fill.
Non-TANF Count	15-23	9	Numeric	Total Non-TANF record count, Right justify and zero fill.
TANF Amount	24-34	11	Numeric	Total TANF Amount. Whole dollar amount. No decimal points, dollar signs, commas, or plus/minus signs. Right justify and zero fill.
Non-TANF Amount	35-45	11	Numeric	Total Non-TANF Amount. Whole dollar amount. No decimal points, dollar signs, commas, or plus/minus signs. Right justify and zero fill.
Filler	46-245	200		Blank Fill.

CHILD SUPPORT ENFORCEMENT DIVISION
DEPARTMENT OF REVENUE MS 01550
550 W 7TH AVE 4TH FL
ANCHORAGE AK 99501-6699
INSTATE (800) 478-3300

CHILD SUPPORT ENFORCEMENT DIVISION
W 7TH AVE 4TH FL
ANCHORAGE AK 99501-6699
PHONE(S): (907) 269-6900

CURRENT DATE9 ** CONTACT ADDRESS ABOVE **

MR AND/OR MS JOHN DOE
3331 ANYSTREET BLVD
ANYTOWN USA 99999-0123

SSN          CASE NUMBER   LOCAL ID     PAST DUE AMOUNT CLAIMED 
992-12-3456  933331Z97RN1  99001        $520 (NON-TANF)

The agency identified above has determined that you owe past-due child and/or spousal support. Our records show that you owe at least the amount shown above. If your case was submitted to the United States Department of the Treasury for collection in the past, this amount is subject to collection at any time by Administrative Offset and/or Federal Tax Refund Offset. If your case has not already been submitted to the United States Department of the Treasury and you do not pay in full within 30 days from the date of this notice, this amount will be referred for collection by Administrative Offset and/or Federal Tax Refund Offset. Under Administrative Offset (31 U.S.C. 3716), certain Federal payments that might otherwise be paid to you will be intercepted, either in whole or in part, to pay past-due child and/or spousal support. Under Federal Tax Refund Offset (42 U.S.C. 664; 26 U.S.C. 6402), any Federal income tax refund to which you may be entitled will be intercepted to satisfy your debt.

If you owe arrearages of child support in an amount exceeding $5,000, the agency identified above will certify your debt to the State Department pursuant to 42 USC 654(31). Once you are certified, the Secretary of State will refuse to issue a passport to you, and may revoke, restrict or limit a passport that was previously issued. The amount of your past-due support will also be reported to consumer reporting agencies.

Your debt will remain subject to collection by Federal Tax Refund Offset and/or Administrative Offset until it is paid in full. Important: If you owe current support, any further arrears accruing due to payments missed may be added to your debt and will be subject to collection by Federal Tax Refund Offset and/or Administrative Offset now or in the future without further notice. To determine additional amounts owed or the total amount past-due which the agency has submitted for collection, you may contact us at the address or phone number listed above.

You have a right to contest our determination that this amount of past-due support is owed, and you may request an administrative review. To request an administrative review you must contact us within 30 days of the date of this notice at the address or phone number listed above. If your support order was not issued in our State, we can conduct the review or, if you prefer, the review can be conducted in the State that issued the support order. If you request, we will contact that State within 10 days after we receive your request and you will be notified of the time and place of your administrative review by the State which issued the order. All requests for administrative review must be made by contacting the agency identified above.

If you are married, filing a joint income tax return, and you incurred this debt separately from your spouse, who has no legal responsibility for the debt and who has income and withholding and/or estimated tax payments, your spouse may be entitled to receive his or her portion of any joint Federal tax refund. If your spouse meets these criteria, he or she may receive his or her portion of the joint refund by filing a Form 8379 - Injured Spouse Claim and Allocation. Form 8379 should be attached to the top of the Form 1040 or 1040A when you file, or be filed according to other instructions as indicated on the Form 8379.