Federal Scrutiny Leads OCSE to Propose Rescinding Child Support Employment Services Rule
The Office of Child Support Enforcement (OCSE), a division of the Department of Health and Human Services (HHS), has formally proposed to rescind a significant 2024 regulation that allowed federal financial participation for employment and training services aimed at noncustodial parents. This notice of proposed rulemaking (NPRM), published on June 9, 2026, marks a substantial shift in federal policy regarding how child support agencies can support noncustodial parents in meeting their obligations. The public now has until August 10, 2026, to submit comments on this proposed change, which could reshape a program intended to bolster both parental employment and the regularity of child support payments.
Background of the Original Rule
On December 13, 2024, OCSE issued a final rule titled 'Employment and Training Services for Noncustodial Parents in the Child Support Program'. This rule amended various sections of 45 CFR, specifically parts 302, 303, 304, and 309. Its core purpose was to enable state and tribal child support agencies to claim Federal Financial Participation (FFP) under Title IV-D of the Social Security Act. This funding was designated for the cost of providing certain optional employment and training services to eligible noncustodial parents who were part of the child support program. The intent behind the 2024 rule was clear: by enhancing the economic stability of noncustodial parents, it was believed that the regularity and reliability of their child support payments would improve, ultimately benefiting children and families.
Driving Forces Behind the Rescission Proposal
OCSE's proposal to rescind the 2024 rule stems from a re-evaluation process initiated following the issuance of several Executive Orders by President Trump. These include Executive Order 14219, known as the 'Ensuring Lawful Governance and Implementing the President's 'Department of Government Efficiency' Deregulatory Initiative', issued on February 25, 2025; Executive Order 14278, 'Preparing Americans for High-Paying Skilled Trade Jobs of the Future', from April 28, 2025; and Executive Order 14303, 'Restoring Gold Standard Science', issued on May 29, 2025. These orders collectively directed federal agencies to review regulations for necessity, effectiveness, and cost-efficiency.
Upon this review, OCSE concluded that the foundational evidence and analysis supporting the 2024 rule were insufficient. The agency now argues that the previous policy approach is neither the most cost-effective nor the most efficient method to achieve Title IV-D objectives related to child support enforcement and family well-being.
Key Concerns Driving OCSE's Decision
OCSE's rationale for the proposed rescission is multifaceted, addressing several critical areas:
Projected Federal Expenditures
The most significant concern cited is the substantial projected federal expenditure associated with the 2024 rule. Initial estimates indicated an increase in federal costs of $17.8 million in Fiscal Year 2025, the first year of analysis. This figure was projected to rise dramatically, reaching an estimated $98.5 million per budget year by Fiscal Year 2034. OCSE emphasizes that these figures represent only the federal costs for providing employment and training services and do not reliably quantify potential federal benefits, such as reduced child support enforcement costs or decreased reliance on means-tested programs, which are deemed speculative. Given these substantial costs, OCSE argues that rescinding the rule is in the best interest of both the child support program and the broader federal budget.
Limited Evidence of Effectiveness
OCSE also reassessed the evidentiary basis for the 2024 rule, finding that it provided only modest and inconsistent evidence of effectiveness. While some studies, such as the Child Support Noncustodial Parent Employment Demonstration (CSPED), showed a three percent increase in employment rates and a four percent increase in earnings for participants in the first year, they did not consistently demonstrate improvements in the regularity or amount of child support paid. For instance, CSPED data indicated an eight percent increase in the likelihood of paying child support through income withholding in the first year but did not show an increase in the actual amount paid. Other evaluations, like the Families Forward Demonstration, were explicitly noted as not being designed to attribute causality, thereby limiting the conclusions that could be drawn about sustained employment impacts. Many studies relied on pre-/post-enrollment analyses or quasi-experimental designs without contemporaneous control groups, which OCSE now deems methodologically insufficient for drawing reliable causal conclusions on a national scale.
Overlap and Administrative Complexity
The 2024 rule's approach was designed to create a new service-delivery and funding pathway within child support agencies. However, OCSE identified that this pathway significantly overlaps with numerous existing federal workforce programs. While the original rule included features to prevent duplication and encourage coordination, OCSE now believes these measures were insufficient. The agency concludes that this overlap increases administrative complexity and fragmentation across federal efforts to support workforce development and employment, rather than streamlining them.
Adherence to Gold Standard Science Principles
A critical component of OCSE's re-evaluation is its adherence to President Trump's Executive Order 14303, 'Restoring Gold Standard Science', and subsequent guidance from the White House Office of Science and Technology Policy (OSTP). This guidance emphasizes disciplined study design, transparency, clear communication of error and uncertainty, and cautions against speculative claims. OCSE determined that the evidence cited in the 2024 rule, with its reliance on short-term outcome measures, limited external validity, and designs that often failed to isolate the independent effects of IV-D funded activities, does not meet these 'gold standard' principles. This lack of robust, causally attributable evidence makes it difficult to confidently conclude that Title IV-D funding for these services would reliably or sustainably improve employment stability or child support payment regularity nationwide.
Broader Implications
The proposed rescission could have significant implications for state and tribal child support agencies, as well as for noncustodial parents. If finalized, it would eliminate a funding stream that some agencies may have been preparing to utilize or were already exploring to provide employment and training services. This decision reflects a federal emphasis on fiscal prudence, evidence-based policy making, and reducing perceived governmental redundancy. It also signals a more stringent approach to how federal funds are allocated for social programs, demanding clearer and more robust evidence of direct impact before significant financial commitments are made. The debate will now shift to how best to support noncustodial parents' employment and child support obligations without this specific federal funding mechanism, likely pushing agencies to rely more heavily on existing workforce development programs and inter-agency coordination.
