Child Support (CSS) Penalty

The CSS Interface communicates non-cooperation and cooperation status of an individual to KEES. KEES then creates or updates non-compliance records as outlined in the Child Support (CSS) Penalty Process below. If KEES is unable to create or update a non-compliance record, an alert task is generated for the Purple Queue. For detailed instructions on how to handle these tasks see Troubleshooting Child Support (CSS) Penalty and/or Troubleshooting when a Child Support (CSS) Penalty is Cured.

Child Support Services (CSS) Referral and Non-Compliance Process

This business process flow shows the high-level steps utilized by KEES to send and receive CSS referrals, non-compliance records, and compliance information between KEES and the CSS System.

Business Process Diagram

Visio depicting the steps outlined in the verbiage below.

Business Process Steps

Eligibility Worker:

Create a CSS referral if:
- At least one parent of a child receiving benefits is not currently in the home. See Adding a Noncustodial Parent Record for detailed steps.
- The consumer meets the Expedited Paternity criteria. See Adding a Noncustodial Parent Record for detailed steps.
Finish processing the case and run EDBC. See Running EDBC – Non-Medical.

KEES:

Send a referral to CSS via the CSS Interface for all individuals who have a Noncustodial Parent Detail record on approved applications.

NOTE: KEES does not send referrals to CSS for denied applications.

Child Support Services (CSS):

Act on the CSS Referral received from KEES and engage the consumer in cooperation with CSS.
Indicate Non-Cooperation in the CSS System if the consumer does not cooperate and is actively receiving Food Assistance, TANF, and/or Child Care in KEES.
Complete the Memorandum form and email it to the DCF Service Center.

Mail Receiver/Imager:

Image the Memorandum form using the following guidance:
- Application Plan: KEES Case
- Basket: Case – No Task
- Document Type: Correspondence

KEES:

KEES creates a record on the Eligibility Non-Compliance page. The type of non-compliance set by KEES depends on the program.

NOTE: Two non-compliances are set for TANF and/or Child Care, one for each program regardless if the consumer is receiving assistance for that program.

See the table below for more information on data used to set the non-compliance record when the program and person are Active.

	TANF	Child Care	Food Assistance
Type	Child Support	Child Support	Child Support
Reason	1st Penalty 2nd Penalty 3rd Penalty 4th Penalty	1st Penalty 2nd Penalty 3rd Penalty 4th Penalty	Food Assistance
Begin Date	First Day of the come up month considering timely notice based on the creation date from CSS	First Day of the come up month considering timely notice based on the creation date from CSS	Creation Date from CSS
End Date	Defaults based on reason selected	Defaults based on reason selected	Blank
Override End Date	12/31/9999	12/31/9999	Blank
Compliance Date	Blank	Blank	Blank
Program Type	TANF/RCA	Child Care	Food Assistance

KEES runs EDBC to discontinue the program or person as applicable for TANF and FA. In addition, a change or discontinuance NOA is sent.

When CSS indicates a consumer’s cooperation in the CSS system, KEES updates the non-compliance record.

See the table below for information on data used to update a Tiered Penalty non-compliance record when CSS indicates a consumer is now cooperating.

	TANF	Child Care
Override End Date	Sets to the End Date used at the time of the tiered penalty creation	Sets to the End Date used at the time of the tiered penalty creation
Compliance Date	Date of Cooperation	Date of Cooperation

See the table below for information on data used to update a Non-Tiered Penalty non-compliance record when CSS indicates a consumer is now cooperating.

	TANF	Child Care	Food Assistance
Override End Date	Last Day of the Month based on the Date of the Cooperation	Last Day of the Month based on the Date of the Cooperation	Last Day of the Month based on the Date of the Cooperation
Compliance Date	Date of Cooperation	Date of Cooperation	Date of Cooperation

If Food Assistance is Active, KEES runs EDBC to re-determine the Food Assistance benefit amount for the following month and come up month (if applicable). A change NOA is sent if applicable as well.

Key Process Considerations

Expedited Paternity:

Expedited Paternity information is captured in KEES. When creating an Expedited Paternity referral:
- Make the relationship of the presumed father and child as unrelated until CSS is able to establish paternity.

Sending a CSS Referral:

A referral is not sent to CSS until EDBC is saved and accepted and the program(s) is approved.
When running EDBC for Non-Medical programs that require a referral to CSS, KEES requires the program to have:
- Two parents in the home
- One parent in the home and one CSS referral for the absent parent
- Two CSS referrals for the absent parents
If the above criteria are not met KEES prevents staff from running, saving and accepting EDBC. There are five known scenarios when the program does not meet the criteria listed above but is eligible to receive benefits. See CSS Referral for Single Adoptive/Severed Rights Parents for the steps to determine benefits for these unique situations.
The Name Type field on the Individual Demographics page is used to give more detail on the name currently being used in KEES and any name previously used. The Name Type field is also included in the information that goes over on the CSS Date Sync interface file.
- Drop-down values for consumer’s current name include:
- - Adopted
  - Birth/Maiden
  - Legally Changed
  - Married
- Drop-down values for consumer’s alias name(s) include:
- - Adopted
  - Birth/Maiden
  - Legally Changed
  - Married
  - Other

Receiving CSS Non-Compliance Information:

If KEES is unable to automatically create a Non-Compliance record, a task is generated for the Purple queue to notify staff the automation failed. In this instance, staff need to verify the cooperation/non-cooperation in the CSS system and manually update the record/run EDBC if appropriate. See Troubleshooting Non-Compliance for more information. Task names include:
- CSS Non-Cooperation Alert was not handled correctly
- CSS Cooperation Alert was not handled correctly
If the consumer is an Active minor parent, they receive a non-tiered penalty.

NOTE: Two non-compliances are set for TANF and/or Child Care, one for each program.

See the table below for more information on data used to set the non-compliance record when the program and person are not active, or if the person is an Active minor parent.

	TANF	Child Care	Food Assistance
Type	CSS Non-Cooperation	CSS Non-Cooperation	Child Support
Reason	CSS Non-Cooperation	CSS Non-Cooperation	Food Assistance
Begin Date	Creation Date from CSS	Creation Date from CSS	Creation Date from CSS
End Date	Blank	Blank	Blank
Override End Date	Blank	Blank	Blank
Compliance Date	Does Not Display	Does Not Display	Blank
Program Type	TANF/RCA	Child Care	Food Assistance

When TANF is discontinued, KEES generates a task for the Work Programs queue to notify the Career Navigator of the change in program status. The Career Navigator needs to research the case determine if the program was discontinued due to a CSS Non-Compliance.
When a FAET participant is discontinued on Food Assistance, KEES generates a task for the FAET queue to notify the Career Navigator of the change in person or program status. The reason for the discontinuance is noted in the task details of the task.

Receiving CSS Compliance Information:

CSS information is received by KEES through the CSS interface nightly. If a consumer were to comply the same day they apply, an update cannot be seen in KEES until the next day. Staff should not manually update the record, as this would cause the automation to fail and a task to generate.

General Considerations:

At initial application, the Eligibility Non-Compliance page must be checked to verify the consumer is in cooperation status with all absent parents.
Use the guidance below when a consumer has a CSS Non-Cooperation penalty for another program at initial application and has not cured the penalty within the required time frame:
- Food Assistance:
- - If there is a record for TANF and CC, but not Food Assistance, create a new Non-Compliance record with type of Child Support and reason of Food Assistance and process the application.
- TANF/Child Care
- - If there is a record for Food Assistance, but not for TANF and CC, create a new Non-Compliance record with type of CSS Non-Cooperation and Reason of CSS Non-Cooperation to deny the TANF and/or Child Care application.
  - If the family applies for CC, the non-cooperation should be evaluated to determine if the non-cooperation is for a child that is applying for care.
Use the guidance below when a consumer has a Child Support penalty for TANF or Child Care, because the two programs are not linked:
- When processing an application for either TANF or Child Care, or a review for Child Care, view the Non-Compliance page to determine if a Child Support non-compliance has been applied since 7/1/2023 and which programs were active when that non-compliance was applied. If both programs were not active, remove the record from the inactive program. If the person is still in non-cooperation, add a non-compliance record of CSS Non-Cooperation for the program that was not active. This does not count as a tiered penalty but will prevent KEES from approving benefits while the client is in non-compliance.
- - Example: if a Child Support non-compliance record is applied while the family is Active on TANF only, a Child Support non-compliance will be created for both TANF and Child Care. Remove the record for the Child Care case, as it was not Active when the penalty was incurred. Add a CSS Non-Cooperation record for the Child Care program.
- If the penalty is for a child that is not requesting child care assistance, remove the penalty before running EDBC. After running EDBC through the come up month, add the penalty back to KEES.
- - NOTE: CSS Non-compliance records do not include information on the Absent Parent (AP) or child when the record comes over from CSS. Staff should add a note to the comments box identifying the child/AP that the Non-compliance record is tied to when using this process to approve Child Care benefits.
- When processing a Child Care review, in addition to the steps above:
- - If the person is still in non-cooperation, edit the dates on the Child Support non-compliance record for Child Care to match the Begin Date of the non-compliance to be the first day of the month following the end of the review period. This will set the penalty to the correct time frame.
  - If the person is now cooperating, the Child Support non-compliance record for Child Care can be removed.
If a Non-Cooperation penalty is retracted by Child Support Services:
- Food Assistance: Remove the Child Support Non-Compliance record after a Compliance Date is received by KEES, re-run EDBC for the months the individual did not receive benefits and create an underpayment for those months. See Processing Underpayments.
- TANF and/or Child Care: Remove the Child Support Non-Compliance record after a Compliance Date is received by KEES, rescind the program block(s) and re-run EDBC. See Rescind Program – Non-Medical.
NOTE: CSS does not have the ability to remove a non-compliance from their system. Instead, they indicate the consumer is complying in the CSS system and a Compliance Date is sent to KEES. CSS information is received by KEES through the CSS interface nightly. The update cannot be seen in KEES until the next day. Staff should not manually update the record, as this would cause the automation to fail and a task to generate.
The CSS process is to verify the consumer is actively receiving benefits in KEES prior to indicating non-compliance information in the CSS system. However, if that process is not followed, the CSS interface will send non-compliance information to KEES and a non-tiered penalty record will be created. If staff think CSS applied a penalty in error, they will need to contact CSS.