PURSUANT TO THE PROVISIONS OF THE State Administrative Procedure Act, NOTICE is hereby given of the following proposed rule:
Proposed Action:
Amendment of sections 346.2 and 347.17 of Title 18 NYCRR.
Statutory authority:
United States Code, section 654(6)(B)(ii) of title 42; Code of Federal Regulations, sections 302.33 and 303.2 of title 45; Social Services Law, sections 20(3)(d), 111-a, 111-c(4)(a) and 111-g(3)(a) and (b); Family Court Act, section 453(a)
Subject:
Child Support.
Purpose:
To address child support services applications and notification requirements and the imposition of an annual service fee; and set forth requirements concerning the provision of legal services and the recovery of associated costs.
Text of proposed rule:
Section 346.2 of Title 18 of the NYCRR is amended to read as follows:
§ 346.2 Application for services to individuals not otherwise eligible.
(a) Individuals not otherwise eligible may apply for child support services by signing and providing to a local child support enforcement unit an application form prescribed by the Office.
(b) Any petition, written application or written motion to a court for the establishment of paternity or the establishment, modification and/or enforcement of a child support obligation for persons not in receipt of [aid to dependent children] public assistance and care or foster care or continuing to receive services as provided in section 347.13 of this Title which contains a signed statement requesting child support [enforcement] services[,] as provided under Title 6-A of the Social Services Law, constitutes an application for such services pursuant to section 347.17 of this Title. However, where a court proceeding resulted in an order for child or child and spousal support payable through the [SCU] support collection unit, based upon a paternity or support petition filed prior to September 30, 1990, such petition and/or moving papers are deemed to be an application for child support [enforcement] services.
[(b) The SCU must require all petitioners in child support cases referenced in subdivision (a) of this section except public officials acting in their official capacities, to provide the following data:
(1) their names;
(2) their addresses, except that a post-office box will not be accepted unless the U.S. Postal Service does not make residential delivery to the petitioner’s home;
(3) the name(s) and date(s) of birth of all children under the subject order;
(4) their social security numbers;
(5) a statement by the petitioner whether he or she is in receipt of, or has applied for, home relief or aid to dependent children; and
(6) such other information as the department may require.]
(c) [For the purpose of this section, child support enforcement services do not include legal services or field investigative services.] Where an individual has made application for child support services pursuant to subdivision (b) of this section, the support collection unit must obtain a copy of the petition, written application or written motion to the court which clearly indicates a request for services. The support collection unit must advise such individual to provide any information the support collection unit deems necessary to provide services.
(d) The support collection unit must provide all individuals applying for child support services pursuant to subdivisions (a) or (b) of this section information describing all available child support services, the individual’s rights and responsibilities, and the State’s fees, cost recovery and distribution policies on a form prescribed by the Office. The support collection unit must provide such information to all applicants or recipients of public assistance and care and foster care within 5 days of referral to the child support enforcement unit.
Section 347.17 of Title 18 of the NYCRR is amended to read as follows:
§ 347.17 Child support services available to individuals not otherwise eligible and to individuals who become ineligible for public assistance and care or foster care.
(a) All child support services under this Part and Part 346 of this Title must be made available to any individual not otherwise eligible upon receipt of either (1) a signed application on a form prescribed by the [department] Office and filed by such individual with [the] a child support enforcement unit or support collection unit [of the county where such individual resides], or (2) an application made to a court, as set forth in section 346.2 of this Title, and to individuals who become ineligible for public assistance and care or foster care. Services are available only for the [purpose] purposes of locating parents, establishing paternity and/or [obtaining] establishing, modifying or enforcing child support. Such services cannot be provided in the absence of an application, as set forth in this subdivision. [Application must be made for all necessary services that are rendered free of charge, as indicated in subdivision (f) of this section.] Application for legal services [that are rendered for a fee], for which costs are recovered as indicated in subdivision [(g)] (d) of this section, is optional. Application forms for child support services must be:
(1) readily accessible to the public;
(2) provided to an individual on the day the individual makes a request in person, or sent to an individual no later than [five] 5 working days after a written or telephone request. The support collection unit must ensure [All] all such application forms [must be] are accompanied by information describing available services, the individual's rights and responsibilities, fees, cost recovery and distribution policies, as provided in subdivision (d) of section 346.2 of this Title; and
(3) accepted as filed on the day received.
(b) Fees and cost recovery for child support services are as follows:
(1) The application fee for child support services [not listed under section 347.13(e) of this Part] for individuals applying pursuant to section 346.2 of this Title shall be $1, which shall be paid by the [department] Office. [For the services specified in subdivision (d) of this section, a “Right to Recovery” agreement shall be required and the district shall recover the actual cost of such services from the collections made on behalf of the applicant.]
(2) An annual service fee of $25 shall be imposed for any individual receiving child support services who has never received assistance pursuant to Title IV-A of the federal Social Security Act if at least $500 of support has been collected in the federal fiscal year on the individual’s child support case. Where a custodial parent has children with different noncustodial parents, the order of support payable by each noncustodial parent shall be a separate child support case for the purpose of imposing an annual service fee. The annual service fee shall be deducted from child support payments received on behalf of the individual receiving child support services pursuant to section 347.13 of this Part. In international cases under section 111-g (3) (b) of the Social Services Law which meet the criteria for imposition of the fee under this paragraph, the annual service fee shall be imposed but may not be collected from the country requesting services or from an individual living in another country unless permitted by federal law or regulation.
(3) (i) For legal services in subdivision (d) of this section, execution of a "Right to Recovery Agreement for Legal Services” shall be required and the social services district shall recover either standardized costs for attorneys provided by the social services district or actual costs of such services if legal services are provided by contract attorneys.
(ii) If the applicant for legal services is the support obligee, the applicant shall assign to the social services district twenty-five percent of the current support obligation pursuant to the order of support. If there is no current support obligation pursuant to the order of support, the applicant shall assign an amount equal to twenty-five percent of the former current support obligation. If there never was a current support obligation pursuant to the order of support, the applicant shall assign an amount equal to twenty-five percent of the additional amount determined pursuant to section 347.9(e) of this Part. The assigned amount for legal services shall be satisfied by collections received by the support collection unit on behalf of the child(ren) pursuant to section 347.13 of this Part until the total assigned costs for those legal services provided are reimbursed.
(iii) If the applicant for legal services is the support obligor, the applicant shall pay an additional amount equal to twenty-five percent of the current support obligation pursuant to the order of support. If there is no current support obligation pursuant to the order of support, the applicant shall pay an additional amount equal to twenty-five percent of the former current support obligation. If there never was a current support obligation pursuant to the order of support, the applicant shall pay an additional amount equal to twenty-five percent of the additional amount determined pursuant to section 347.9(e) of this Part. The amount to be paid for legal services shall be paid separately to the support collection unit until the total costs for those legal services provided are reimbursed.
(4) The attorney for the social services district may seek recovery from the noncustodial parent of the assigned cost of legal services, counsel fees, and expenses when authorized by law. Sums recovered for the cost of legal services shall be credited against the amounts due pursuant to the “Right to Recovery Agreement for Legal Services.”
(c) The child support services available upon application or pursuant to subdivision 347.13(e) of this Part without a “Right to Recovery Agreement for Legal Services” are:
(1) assistance in the location of [absent] putative fathers and noncustodial parents, including the processing of the name of the [absent parent] putative fathers and noncustodial parents through the State Parent Locator [files] Service and Federal Parent Locator [files] Service in accordance with section 347.7 of this Part;
(2) assistance in establishing paternity and establishing and modifying child support obligations including the preparation and filing of [support,] paternity, [violation] support and modification petitions as required in accordance with sections 347.6 and 347.8 of this Part;
(3) collection, distribution, and disbursement of child support payments in accordance with federal and State law and section 347.13 of this Part;
(4) enforcement of support obligations, through the use of all available administrative enforcement remedies, as provided in Parts 346 and 347 of this Title [including the mandatory implementation of income executions when absent parents default on their support obligation], and if necessary, judicial enforcement remedies, consistent with the provisions of section 347.9 of this Part; and
(5) [collection of delinquent child support payments and arrears through the Federal, New York State and/or New York City tax refund offset process in accordance with section 346.9 of this Title; and] the review and cost of living adjustment of orders of support.
[(6) the review and adjustment of child support orders, except for legal representation related to such activity.]
(d) (1) A “Right to Recovery Agreement for Legal Services” signed by the applicant shall be required where [the following] legal services are requested.
[(i) field investigation; and/or
(ii) legal representation.]
(2) (i) The attorney for the social services district may appear in any court proceeding brought by or on behalf of an applicant for legal services. The attorney appearing on behalf of the social services district shall represent the interests of the social services district and not the interests of any other party. The interests of the social services district shall include, but not be limited to: establishing paternity; establishing and modifying orders of support in accordance with the Child Support Standards Act; and enforcing orders of support.
(ii) The appearance by the attorney for the social services district in any action or the provision of services pursuant to Title 6-A of the Social Services Law or section 580-307 of the Family Court Act does not create an attorney-client relationship between the social services district or its attorneys, and any party. The social services district shall inform any applicant for child support services in writing that providing such services, including legal services provided by an attorney, does not create an attorney-client relationship with the applicant.
(3) The social services district shall make [these] legal services available upon request and shall have sufficient [investigators and] attorneys to provide these services[.]; provided, however, that nothing herein shall require the social services district to provide services it determines to be without substantial merit or contrary to law.
[(3) The district shall, pursuant to the "Right to Recovery" agreement, deduct an amount no larger than 25 percent from each child support payment received on behalf of the applicant until the actual costs of the above services are reimbursed.
(4) When a child support enforcement client signs the "Right to Recovery" provision of the application for child support enforcement services and a hearing is held for the establishment of paternity and/or a support order, the Child Support Enforcement Unit or the Support Collection Unit representative must request the court to make the order of support payable to the Support Collection Unit, for the purposes of recovering field investigation and/or legal representation costs.]
(e) The [State Office] Division of Child Support Enforcement and each [local] social services district's child support enforcement/support collection unit shall regularly and frequently publicize the availability of child support [enforcement] services. This information shall be made available through a variety of media services including public service announcements. All publicity must include information on any application fees which may be imposed for such support collection services and a telephone number [and] or postal address where additional information about such services may be obtained.
Text of proposed rule and any required statements and analyses may be obtained from:
Jeanine S. Behuniak, New York State Office of Temporary and Disability Assistance, 40 North Pearl Street, Floor 16C, Albany, NY 12243-0001, (518) 474-9779, email: Jeanine.Behuniak@otda.ny.gov
Data, views or arguments may be submitted to:
Same as above.
Public comment will be received until:
45 days after publication of this notice.
Regulatory Impact Statement
1. Statutory Authority:
Social Services Law (SSL) § 20(3)(d) authorizes the Office of Temporary and Disability Assistance (OTDA) to promulgate regulations to carry out its powers and duties.
SSL § 111-a requires OTDA to promulgate regulations necessary to obtain and retain approval of its child support state plan, required to be submitted to the federal Department of Health and Human Services by Part D of Title IV of the federal Social Security Act.
Title 42 of the United States Code (42 USC) § 654(6)(B)(ii), also known as § 454(6)(B)(ii) of the federal Social Security Act, provides that in the case of an individual who has never received assistance under a state program funded under Part A of Title IV of the federal Social Security Act and for whom the state has collected at least $500 of support, the state shall impose an annual fee of $25 for each case in which services are furnished.
Title 45 of the Code of Federal Regulations (45 CFR) § 302.33(a)(1)(i) provides that states must make available all child support services under their state plans to any individual who files an application for the services with a child support agency.
Federal regulations at 45 CFR § 302.33(d) allow states to recover the costs of various child support services beyond an application fee by recovering either the actual cost or a standardized cost for the services.
Federal regulations at 45 CFR § 303.2(a)(2) provide, in part, that information describing available services, the individual’s rights and responsibilities, and the state’s fees, cost recovery, and distribution policies must accompany all applications for services, and be provided to applicants/recipients of Medicaid and assistance under Parts A and E of Title IV of the federal Social Security Act.
Family Court Act (FCA) § 453(a) gives a support collection unit the authority to originate and prosecute support proceedings on behalf of persons in receipt of public assistance or in receipt of services pursuant to SSL § 111-g.
SSL § 111-c(4)(a) provides that a social services district represents the interests of the district in performing its functions and duties, and not the interests of any party. The interests of a district include, but are not limited to, establishing paternity, and establishing, modifying and enforcing child support orders.
SSL § 111-g(3)(a) provides that a person who is receiving child support services pursuant to this section who has never received assistance pursuant to Part A of Title IV of the federal Social Security Act shall be subject to an annual service fee of $25 for each child support case if at least $500 of support has been collected in the federal fiscal year. Where a custodial parent has children with different noncustodial parents, the order payable by each noncustodial parent shall be a separate child support case for the purpose of imposing an annual service fee. The fee shall be deducted from child support payments received on behalf of the individual receiving services.
SSL § 111-g(3)(b) provides that in international child support cases under 42 USC § 654(32) that meet the criteria for the imposition of the annual service fee, the annual service fee must be imposed upon, but may not be collected from, the country requesting services or a person living in another country unless collection is permitted by federal law or regulation.
2. Legislative Objectives:
It was the intent of the Legislature in enacting the above statutes that OTDA establish rules, regulations and policies so that child support enforcement services are provided to eligible persons to ensure that, to the greatest extent possible, parents provide financial support for their children.
3. Needs and Benefits:
The amendments to 18 NYCRR § 346.2 are being made to ensure the state’s compliance with the child support application and notification requirements provided in federal regulations. Pursuant to 45 CFR § 302.33, states must make available all services to any individual who files an application with the child support agency. Pursuant to 45 CFR § 303.2, information describing available services, the individual’s rights and responsibilities, and the state’s fees, cost recovery, and distribution policies must accompany all applications for services, and be provided to all applicants/recipients of Medicaid and assistance programs under Parts A and E of Title IV of the federal Social Security Act. Existing state regulations at 18 NYCRR § 346.2 allow an individual to apply for child support services through court proceedings to establish paternity, or establish, modify, or enforce a child support obligation, and not necessarily through a form prescribed by OTDA. The proposed amendments will require local support collection units (SCUs) to obtain a copy of the request for child support services made in any petition, written application or written motion to a court to ensure the individual has in fact applied for services in a manner authorized by law, and to advise such individuals to provide the SCU with any information the SCU deems necessary to provide services. The amendments ensure that all federal notification requirements are met.
The amendments to 18 NYCRR 347.17 are being made as a result of federal changes requiring the imposition of an annual service fee. Section 454(6)(B) of the Deficit Reduction Act (DRA) of 2005 amended 42 USC § 654 and Chapter 57 of the Laws of 2008 amended SSL § 111-g to require the service fee. The DRA of 2005 requires that states impose a mandatory fee of $25 for a family that has never received assistance pursuant to Title IV-A of the Social Security Act and for whom the state has collected at least $500 of support during the federal fiscal year. Enabling legislation amending SSL § 111-g was enacted in the state’s 2008 Budget requiring that the fee be withheld from support collected. The enabling legislation also provided that in international child support cases under section 454(32) of the federal Social Security Act which meet the criteria for the imposition of the annual service fee, the fee must be imposed but may not be collected from the country requesting services or the recipient living in another country unless permitted by federal law or regulation. The proposed regulatory amendments will set forth the procedure by which New York State will impose the federally required annual service fee.
In addition, Chapter 343 of the Laws of 2009 amended the Family Court Act (FCA) § 453 and SSL § 111-c to clarify certain roles and authorities of a local social services district in providing child support services. The amendments to FCA § 453 clarified that a support collection unit has the authority to originate and prosecute proceedings under FCA § 422 on behalf of persons receiving public assistance or in receipt of services pursuant to SSL § 111-g. The amendments to SSL § 111-c provided that a social services district represents the interests of the district in performing its duties and not those of any other party. Providing child support services, including legal services, does not constitute or create an attorney-client relationship between the individual receiving services and the attorney representing the district. In addition, the district may appear in any action to establish paternity, or to establish, modify, or enforce an order of support when an individual is receiving child support services. The proposed amendments to 18 NYCRR § 347.17 will make state regulation consistent with state statute.
Federal regulations at 45 CFR § 302.33(a) require that services under a state plan must be made available to any individual who files an application for services. Legal services, therefore, must be made available to all individuals who file an application pursuant to SSL § 111-g, and in addition, request legal services by signing a “Right to Recovery Agreement for Legal Services.” Pursuant to 45 CFR § 302.33(d), states may recover costs beyond an application fee, either by recovering the actual cost of the services or a standardized cost. The proposed amendments provide clarification to the existing state regulation concerning the provision of legal services and the manner used to recover the associated costs.
4. Costs:
The proposed amendments to the regulations will not require the social services districts to incur any initial capital costs. The anticipated fiscal impact associated with the federally mandated annual service fee is a modest increase in program income that will be shared between the federal, state, and local governments. For federal fiscal years 2008-09 and 2009-10, the first two years the fee was withheld from collections in the state, approximately $4 million was reported as program income in each year as a result of the fee withholding. Any new local district costs of providing legal services will be offset in part by recovery of such costs from child support collected and from federal and state reimbursement for providing services under Title IV-D of the Social Security Act.
5. Local Government Mandates:
The proposed amendments conform the regulations to existing statutory requirements. Local social services districts will be required to ensure that all individuals requesting child support services have made application by one of two ways authorized by state law, and by ensuring all individuals applying for child support services, and all applicants/recipients of Medicaid and assistance under Parts A and E of Title IV of the federal Social Security Act receive notification of child support program information. The proposed amendments concerning child support applications and services are clarifying in nature and are consistent with federal and state laws.
Local social services districts have followed procedural rules to implement the federally required annual service fee since 2008. Local districts must continue to report to OTDA’s Division of Child Support Enforcement their effectiveness and efficiency in providing for the annual service fee and for legal services.
The existing regulations require the districts to make legal services available for requesting individuals based on a signed “Right to Recovery Agreement for Legal Services” and to recover costs for legal services provided. The proposed amendments concerning the provision of legal services and cost recovery are clarifying in nature. To the extent that local districts have not provided for legal services in the past, there may be new or additional requirements imposed on local social services districts.
6. Paperwork:
One new form will be required to be used by local district staff in carrying out their responsibilities for notifying recipients of the option for, and right to recovery of, legal services. Local districts and/or their attorneys providing legal services will be required to keep time records, and notify recipients of legal services of the associated costs. Local districts will be required to provide individuals receiving child support services a new form to satisfy the federal notification requirements.
7. Duplication:
The proposed amendments do not duplicate, overlap or conflict with any existing federal or state law or regulation.
8. Alternatives:
There are no significant alternatives to consider because the proposed amendments are consistent with federal and state statutes and regulations.
9. Federal Standards:
The proposed amendments do not exceed federal minimum standards for the same subject.
10. Compliance Schedule:
Because the state statutes implementing the federal requirements are already in effect, local social services districts should already be in compliance with the proposed amendments on their effective date.
Regulatory Flexibility Analysis
1. Effect of Rule:
Each of the 58 local social service districts in New York State will be affected by the proposed regulatory amendments.
2. Compliance Requirements:
The proposed amendments conform the regulations to existing statutory requirements. Local social services districts will be required to comply with the proposed amendments by ensuring that all individuals requesting child support services have made application by one of two ways authorized by state law, and by ensuring all individuals applying for child support services, and all applicants/recipients of Medicaid and assistance programs under Parts A and E of Title IV of the federal Social Security Act receive notification of child support program information. Districts will also be required to ensure that the federally required annual service fee is accounted for and reported. The fee withholding and reporting process is largely automated, however. Districts will also be required to make legal services available for requesting individuals based on a signed “Right to Recovery Agreement for Legal Services,” and to recover costs for legal services provided.
3. Professional Services:
To the extent local social services districts already comply with the current requirement to provide legal services, no new professional services will be imposed on local districts.
4. Compliance Costs:
The proposed amendments to the regulations will not require the social services districts to incur any initial capital costs. The anticipated fiscal impact associated with the federally mandated annual service fee is a modest increase in program income that will be shared between the federal, state, and local governments. For federal fiscal years 2008-09 and 2009-10, the first two years the fee was withheld from collections in the state, approximately $4 million was reported as program income in each year as a result of the fee withholding. Any new local district costs of providing legal services will be offset in part by recovery of such costs from child support collected and from federal and state reimbursement for providing services under Title IV-D of the Social Security Act.
5. Economic and Technological Feasibility:
The Division of Child Support Enforcement within OTDA continues to assume all administrative cost and responsibility for the systematic programming for implementing the annual service fee. Technological feasibility is not a concern for local social services districts.
6. Minimizing Adverse Impact:
The proposed regulations will not have an adverse economic impact on social services districts.
7. Small Business and Local Government Participation:
The procedure for local social services districts to obtain an application from individuals requesting child support services is not new. The proposed amendments clarify the need to obtain a deeming application in instances where an individual requests child support services through a court. The proposed amendments ensure state regulations are consistent with federal application and notification requirements.
Local social services districts have followed procedural rules to implement the federally required annual service fee since 2008. The implementation of the annual service fee was and continues to be largely an automated process administered by OTDA’s Division of Child Support Enforcement. Local districts must continue to report to OTDA’s Division of Child Support Enforcement their effectiveness and efficiency in providing for the annual service fee and for legal services.
The proposed amendments concerning the provision of legal services and cost recovery policy are clarifying in nature.
The statutes on which these regulatory changes are predicated have been discussed with the local social services districts. OTDA and the social services districts have had ongoing discussions regarding these requirements, and this regulatory proposal will bring state regulations into compliance with federal and state requirements and, at the same time, address the practical, day-to-day needs of the districts.
Rural Area Flexibility Analysis
1. Type and estimated numbers of rural areas:
The proposed regulations will affect the 44 rural social services districts in the State.
2. Reporting, recordkeeping and other compliance requirements; and professional services:
Local social services districts in rural districts will be required to comply with the proposed amendments by ensuring that all individuals requesting child support services have made application by one of two ways authorized by state law, and by ensuring all individuals applying for child support services, and all applicants/recipients of Medicaid and assistance programs under Parts A and E of Title IV of the federal Social Security Act receive notification of child support program information.
Local social services districts in rural areas will also need to be sure that the federally required annual service fee is accounted for and reported. The fee withholding and reporting process is largely automated, however. The Division of Child Support Enforcement within OTDA continues to assume all administrative costs and responsibility for the systematic programming for the annual service fee. Consequently, technological feasibility is not a concern for local social services districts in rural areas.
Lastly, current regulations require social services districts in rural areas to make legal services available for requesting individuals based on a signed “Right to Recovery Agreement for Legal Services” and to recover costs for legal services provided. One new form will be required to be used by local district staff in carrying out their responsibilities for notifying recipients of the option for and the right to recovery of legal services. To the extent local social services districts in rural areas already comply with the current requirement to provide legal services, no new professional services will be imposed on local districts. Local districts will be required to provide individuals receiving child support services a new form to satisfy the federal notification requirements.
3. Costs:
The proposed amendments to the regulations will not require the social services districts in rural areas to incur any initial capital costs. The anticipated fiscal impact associated with the federally mandated annual service fee is a modest increase in program income that will be shared between the federal, state, and local governments. For Federal Fiscal Years 2008-09 and 2009-10, the first two years the fee was withheld from collections in the state, approximately $4 million was reported as program income in each year as a result of the fee withholding. Any new local district costs of providing legal services will be offset in part by recovery of such costs from child support collected and from federal and state reimbursement for providing services under Title IV-D of the Social Security Act.
4. Minimizing adverse impact:
The proposed regulations will not have an adverse economic impact on social services districts in rural areas.
5. Rural area participation:
The procedure for local social services districts in rural areas to obtain an application from individuals requesting child support services is not new. In instances where an individual requests child support services through a court, the amendments clarify the local district needs to obtain a copy of the petition, written application, or written motion to the court which clearly indicates the individual is requesting services. The proposed amendments ensure state regulations are consistent with federal application and notification requirements.
Local social services districts in rural areas have followed procedural rules to implement the federally required annual service fee since 2008. The implementation of the annual service fee continues to be largely an automated process administered by OTDA’s Division of Child Support Enforcement. Local districts in rural areas must continue to report to OTDA’s Division of Child Support Enforcement their effectiveness and efficiency in providing for the annual service fee and for legal services.
The proposed amendments concerning the provision of legal services and cost recovery policy are clarifying in nature.
The statutes on which these regulatory changes are predicated have been discussed with the local social services districts in rural areas. OTDA and the social services districts have had ongoing discussions regarding these requirements, and this regulatory proposal will bring State regulations into compliance with federal and state requirements and, at the same time, address the practical, day-to-day needs of the districts.
Job Impact Statement
A job impact statement has not been prepared for the proposed regulatory amendments because the rule will not have a substantial adverse impact on jobs and employment opportunities in either the public or private sector. The proposed amendments to 18 NYCRR § 346.2 and § 347.17 will have no impact on jobs and employment opportunities in New York State. It is evident from the subject matter of the amendments that the jobs of the child support enforcement personnel and the attorneys representing the local social services districts will not be impacted in any real way by the proposed amendments.
