A fix that could help more families

Michigan parents who apply for food assistance through the Supplemental Nutrition Assistance Program (SNAP) or who apply for a child care subsidy are required to cooperate with child support collection efforts if the other parent of their child is not living in the home, or to show good cause (i.e. domestic violence or fear for the child’s safety) for not doing so.

Federal rules require families to cooperate with child support in order to receive cash assistance or Medicaid, and give states the option to add a similar requirement for SNAP and subsidized child care. That option is not popular, however. Michigan is one of only eight states that make receipt of SNAP benefits contingent on cooperation with child support efforts.

To many, the requirement might seem reasonable on its face. If a noncustodial parent is supposed to be supporting his or her children and is not doing so, the custodial parent must either cooperate with the state to collect that money or show good cause.

However, as a recent paper by the Center on Budget and Policy Priorities shows, the requirement is problematic for a number of reasons:

•  Custodial parents who do not engage with child support collection often have a good reason for not doing so (such as fear of abuse), but may not know how to apply for a good cause exemption, may fear the child support agency and/or the noncustodial parent will be contacted anyway, or may have a general fear of getting involved with the court system.
• Custodial parents who have informal payment arrangements with the noncustodial parent may fear that opening a formal child support case may damage the relationship with the other parent.
• One study shows that, while a cooperation mandate takes a significant number of households off SNAP food assistance, few of those households actually receive funds from child support payments, thus ending up with fewer resources — and with children more vulnerable.
• The requirement increases the administrative burden and expense for the state.

These problems are not just hypothetical. The Michigan League for Public Policy was recently informed by one of its partners that some income-eligible parents are not applying for the child care subsidy out of concerns it will trigger a court case on child support. Some parents have specifically mentioned that they have an informal arrangement with the noncustodial parent that works for them, and fear that applying for the subsidy will create a child support court case they want to avoid.

The center’s report, which focuses on SNAP, points out that child support participation among SNAP households is already strong and nearly one-fifth of all SNAP households with children receive child support payments, so this requirement is fixing something that isn’t broken. Furthermore, states can encourage noncustodial parents with low incomes to keep up with their child support payments by deducting those payments from their gross household income when calculating their benefit level, resulting in a higher benefit level for the payor. This “carrot” incentive may be one reason only eight states have adopted the punitive “stick” incentive of barring parents from food assistance for noncooperation.

A former federal official overseeing the child support program has written that the policy is very expensive for states, as it forces child-support agencies to create or maintain bureaucratic infrastructures to identify SNAP recipients and manage, track and monitor the cases, while not significantly increasing child support collections. Indeed, Michigan’s Auditor General recently found that the state Department of Health and Human Services did not make timely determinations of “good cause” in 55% of its public assistance cases in which good cause for noncooperation with child support collection was claimed. With Michigan’s tight budget and the department’s myriad responsibilities, it would be prudent to relieve the department of that burden and expense.

Food assistance and child care subsidies are an important component in the safety net that helps vulnerable families and children in short- or long-term need. Food assistance can improve school outcomes in children by helping make nutritious food more affordable and ensuring they do not go to school or go to bed hungry, and child care subsidies help parents with low wages get and keep their jobs and reduce the likelihood of their families falling into poverty.

To save the state money, to preserve the safety of parents and children in fragile domestic situations, to increase food security among families with low incomes, and to increase access to child care, let’s bring Michigan in line with the 42 states that do not include a child support requirement in determining eligibility for food assistance and let’s eliminate it for child care subsidies, as well.

Those are common-sense policy fixes that will make the lives of everyone involved a little bit easier.