# Why the SNAP/Child Support Cooperation Bad for Children

- Link: https://thechildsupporthustle.com/why-the-snap-child-support-cooperation-mandate-is-horrible-for-children/
- Published: 2024-05-06T14:23:34+00:00
- Author: MsRockMon

[⌊\"Meme\"⌉⌊\"Meme\"⌉[

 

 

> Kenya N. Rahmaan

Many people know the mandatory cooperation with child support enforcement requirements
imposed on parents when applying for Temporary Assistance for Needy Families (TANF)
and Medicaid.  Less known is that states can also mandate this exact requirement
in exchange for Supplemental Nutrition Assistance Program or SNAP benefits.  Currently,
only six states take advantage of the provision outlined in Section 6 of the Food
and Nutrition Act, 7 U.S.C. of 2015.  The United States Department of Agriculture(
USDA) recently released a memo reminding states that this mandate was an available
option for SNAP applicants.  The SNAP/Child Support requirement, according to Cornell
Law School (2019), reads in part that:

 

> _No natural or adoptive parent or other individual who is living with and exercising
> parental control over a child under the age of 18 who has an absent parent shall
> be eligible to participate in the SNAP program unless the individual cooperates
> with the state agencies administering the program established under Part D of 
> Title IV of the Social Security Act (42 U.S.C 651, et seq.)._
>  

Food insecurity refers to the household-level economic and social condition of limited
or uncertain access to adequate food (Feeding America).  With the SNAP program designed
to assist with replacing food deficiencies for those struggling to meet this life-
sustaining need, it is counterproductive for states like Florida to make it more
challenging to access these benefits.  During Fiscal Year (F.Y.) 2017, Florida reported
more than 64% of SNAP participants were families with children (Nchako & Cai, 2018).
In comparison, Utah, Iowa, and Nebraska are three states that provide at least 70%
or more of their families with children SNAP benefits.  These states, unsurprisingly,
have reported the lowest rates of impoverished children.

 

With the SNAP program reaching just over 3 million during F.Y. 2017 in Florida, 
including almost 39% of families with elderly or disabled members and more than 
44% of working families, it is a wonder that legislators would not simply remove
the cooperation mandates altogether.  This removal would undoubtedly assist in curbing
the hunger crisis being experienced by the most unprotected Floridians.  According
to Feeding America, it would take over $1.5 billion more per year to meet the food
needs of Florida residents.  The USDA obviously is not considering these realities
when urging states to enforce the SNAP/Child Support mandate.

 

Mississippi is a state that has had its share of problems, including both record-
high unemployment and poverty rates.  In fact, according to Adam Barone of Investopedia(
2019), Mississippi is ranked #1 for being the poorest State in the country when 
considering the median household income, poverty rate, and unemployment rate.  Yet,
the state legislators force its food-insecure citizens to cooperate with child support
enforcement when seeking benefits.  States enforce this requirement whether someone
needs assistance once or for a few months.

 

The requirement has proven destructive to Mississippi children, as they ranked #
4 in child food insecurity in 2017 at 22.5% (Feeding America).  The average child
food insecurity rate within the United States was slightly lower during the same
year at 17%.  Several known benefits are offered by the SNAP program, including 
food security and better health outcomes for the most financially disadvantaged 
children.  Officials must consider how removing the cooperation mandate will benefit
these children.  This is because Mississippi ranked among the highest in the nation,
with 92,036 needy children in 2017.

 

Instead, according to an article by Dal Kalsi (2019), the USDA claims that enforcing
this cooperation will encourage non-custodial and custodial parents to provide more
children with the support they deserve.  This idea has been debunked by many experts,
as most parents receiving public benefits have shown that failing to provide is 
not based on a blatant unwillingness to offer but due to a lack of resources.  Unfortunately,
it does not seem to matter who provides vital information or what the report uncovers,
and officials will proceed in a manner that financially benefits the government.

 

The Federal Office of Child Support Enforcement (OCSE) has provided proof that most
non-paying, non-residential parents suffer from a lack of income.  In a blog written
by Joey Arthur of the OCSE (2018), he reported that 60% of debtors with more than
$100,000 in arrears (debt) had no reported income in the National Directory of New
Hires (NDNH).  The child support agency routinely fails to count the financial support
parents provide to their children by dismissing the monies spent as ‘gifts.’ Hence,
the mandates will not increase collection amounts significantly enough to justify
states implementing the requirement nationwide.

 

Bear in mind that there are different criteria that a non-custodial parent must 
meet to be deemed eligible to receive SNAP benefits.  Individuals over 18 and under
50 without dependents are limited to three months of SNAP benefits every three years
unless they are working or in a work or training program 20 hours a week (CBPP, 
2018).  Research shows that most parents receiving TANF and Medicaid benefits are
already enrolled in the mandated child support program, so the additional SNAP requirement
is a burden instead of an advantage.  Especially considering that the average monthly
SNAP benefit for each household member is $115 or $1.26, the federal government 
might consider encouraging the banning of the SNAP mandate so that more people can
afford food.

 

A common denominator with all states that mandate the SNAP/Child Support cooperation
is that none of the child support collected on behalf of ‘welfare’ families is ‘
passed-through’ or distributed to those families.  The National Conference of State
Legislatures, or NCSL (2017), explains that states can allow some child support 
payments to be passed through from the government to the parent and the child.  
Less than half of the states have decided to pass through total child support payments
to families.  Instead, they pay a portion between $50 and $200.  The $200 amount
applies when a family has two or more children and only occurs in six states.  Distributing
at least a portion of these collections would be paramount in helping to raise low-
income and work for low-income families out of poverty.

 

Ohio is the other State to use as an example of why states should not mandate the
SNAP/Child Support requirement.  Not only does The Buckeye State refuse to pass 
through any child support to its rightful owners, but the State also missed a chance
to change this rule and the cooperation mandate in its new child support ‘reform’
laws.   Arguably, recycling is a more appropriate term.  Unsurprisingly, Ohio lawmakers
did not consider the high number of children living in poverty and chose to rescind
the SNAP/Child Support mandate while drafting and implementing the ‘new’ law.

 

Paige Pleger (2018) wrote that about one in five Ohio children, roughly 513,000,
lived in poverty in 2016.  When these statistics are dissected based on children
living in extreme poverty, the numbers become even more unsettling.  According to
the Children’s Defense Fund, Ohio reported that 11.7% of its children under six 
lived in extreme poverty.  The numbers increase staggeringly when separated by White,
Hispanic, and Black children, reaching 13.8%, 34.3%, and 42.1%, respectively.  This
number will only increase with the state\’s enforcement of the SNAP/Child Support
cooperation mandate.

 

Since states are free to pay all or at least part of the child support collected
by its rightful owners, the USDA must transfer its gentle nudge to an area that 
will better help the entire situation.  A nudge in a different direction would greatly
uplift the people residing within the Greater Cleveland Area.  Cuyahoga County has
18.6% of its citizens reported as being food insecure.  This population of people
struggling with hunger is quite a bit higher than reported for the State and nationally,
at 15.1% and 12.9%, respectively (United Way Cleveland).  The USDA has decided to
turn a blind eye to these startling numbers.

 

One issue that needs to be addressed by legislators when demanding that states rescind
the SNAP/Child Support mandate is quashing the stereotype that people receiving 
government benefits are lazy minorities, unwilling to contribute to their households
and their children.  The typical Ohio household receiving SNAP is White and headed
by a working single parent (United Way Cleveland).  Another statistic that raises
questions about why Ohio enforces the SNAP/Child Support cooperation is the cost
it takes to feed an Ohioan.  According to CBPP (2019), it costs a person an average
of $1.35 daily or $123 monthly, with average monthly SNAP benefits for all households
reported at $244.  Even with this amount being on the lower side, experts claim 
this is insufficient to feed most hunger insecurity citizens.

 

According to Feeding America, the State of Ohio would require a little over $797
million more per year to meet food needs.  Considering this, the USDA needs to find
ways to feed and not starve the people needing this money.  Parents and citizens
must fight back and let lawmakers know that SNAP benefits sustain hunger, barring
extraordinary circumstances, and should be provided without child support cooperation
mandates.  By fighting back, the citizens will help ensure that the nearly billion
needed to meet food needs are at least acknowledged and may be addressed at the 
state level.  When examining the amount of money the State generates through child
support collections, legislators must consider investing the money into ensuring
that more families can eat.

 

Based on the OCSE (2016), the cost-effectiveness ratio is the total amount of child
support collected on behalf of families in the child support program divided by 
the amount spent.  Ohio has reported a substantial return on investment (R.O.I.)
between 2013 and 2017.  Although there was a decrease from $7.50 to $6.51, that 
is still an extremely profitable R.O.I.  Not to be outshined by Ohio, Mississippi
touts its R.O.I. in 2017 at $9.50 (OCSE, 2018).  Based on the $5.51 profit yielded
by the R.O.I. by the Ohio government, it would have been beneficial to reduce the
nearly $1 billion needed to feed the hungry.

 

R.O.I. is the only source of revenue that states can benefit from regarding the 
child support system.  They receive incentive monies as long as they meet the five
performance goals mandated by the Federal government.  Ohio, for instance, received
$28 million every year between 2013 and 2017 (OCSE, 2018).  States are supposed 
to spend this money in specific areas based on Section 458(f) of the S.S.A.  The
Act,

 

> _allows states to use their incentive payments to either “carry out the state 
> plan” or  “for any activity” (including cost effective contracts with local agencies)
> approved by the Secretary, whether or not the expenditures for the activity are
> eligible for reimbursement under this part, which may contribute to improving 
> the effectiveness or efficiency of the state program operated under this part._

 

Unfortunately, Ohio does not reinvest money into its low-income children, parents,
or families.  The opposite was discovered as accurate when reported by a non-profit
policy research institute.  Ohio lawmakers have reduced state investment in programs
to support struggling families (Policy Matters Ohio, 2019).  Even though reductions
occurred, legislators enforced the SNAP/child support cooperation requirement that
was made available by the federal government.

 

Ohio would rather spend the money on tax cuts, tax breaks, and growing the State’s
rainy day fund (Policy Matters Ohio, 2019).  The State has money to benefit its 
wealthy residents.  That money can help SNAP families when they cannot, for whatever
reason, meet the requirements to qualify for SNAP benefits.  By implementing real
solutions and using the incentives, R.O.I., and the money stashed in the rainy day
funds, vulnerable people will be helped and not go hungry.

 

Staying with the Midwest, Michigan’s SNAP/Child Support mandate is particularly 
burdensome on its low-income children.   Yes, the R.O.I. is quite impressive, reaching
$5.56 in 2017, but something particularly interesting is happening with the pass-
through policy.   Previously, the State passed through $50 per month of child support
collected on behalf of financially vulnerable families.   However, this amount decreased
from $341 in 2013 to -$2 in 2017 (OCSE, 2018).   The reasoning behind this decrease
to a negative amount is that Michigan officials decided to claim the child support
collected for other reasons besides the children.   Yet, there was no overturning
of the SNAP/Child Support mandate, which may have saved the State some money.

 

Due to budgetary constraints, Michigan legislators discontinued implementing its
$50 pass-through and disregarded the statute effective 10/1/2011 (NCSL, 2017).  
It’s a wonder that officials would break the pass-through policy to increase budgets
when there are so many other ways that the State collects and retains money off 
children’s backs.  Michigan can obtain other revenue streams by using the undistributed
child support collections.  To be clear, Michigan handles undistributed child support
collections as if they were unclaimed property after a specific time has elapsed.
Based on the Michigan Legislature Act 29 of 1995, 567.234, Section 14,

 

> _Property held for the owner by a court, state, or other government, governmental
> subdivision or agency, public corporation, or public authority that remains unclaimed
> by the owner for more than 1 year after becoming payable or distributable is presumed
> abandoned._

 

A process is in place when child support payments have been determined escheatable.
According to the Michigan State Disbursement Unit or MiSDU (2015), escheatable is
the transmission of unclaimed property to the State when the owner of that property
is unidentified or their location is unknown.  The State provides three reasons 
why child support monies will be considered escheatable, and they are the following:

 

 * an issued check is not cashed;
 * an issued check is undeliverable due to a bad address, or
 * the payment is unidentifiable if neither the MiSDU nor the Friend of Court (F.
   O.C.) can identify the sender or the intended receiver of the payment.  (MiSDU,
   2015)

The irony of this undeliverable aspect of the policy is that when the agencies attempt
to locate a person to establish child support cases or arrest someone for allegedly
failing to pay child support debt, there are systems available to find the person.

 

Instead, the State was able to claim, according to the OCSE, $151,089,179 in undistributed
child support between 2013 and 2017.  This money could, very effortlessly, be used
by the government to feed the hungry.  Especially when considering, according to
Feeding Families, in 2017 alone, Michigan experienced an annual food budget shortfall
of $652,838,000.  Yes, the undistributed child support money for the five years 
would be a drop in the bucket; however, if coupled with a lift on the cooperation
mandate, there would have been an impressive decrease in the amount of food-insecure
Michiganians.

 

 

Additionally, Michigan is the only State that requires child support cooperation
in exchange for the more than three aforementioned public benefits.  Custodial parents
must cooperate with the child support program in exchange for State Child Health
Insurance (SCHIP) and child care assistance.  The mandate begs the question of why
the State would end distributing the initial $50 pass-through to its low-income 
parents.  It could only be attributed to greed and the want to cushion its annual
budgets.  Equally as important, why has the state failed to end the SNAP/Child Support
mandate, considering the high child poverty rate?

 

Based on KidsCount, which provided the most recent poverty rates in 2017, the rate
for children living in 100% poverty around the country was 18% compared to 20% in
Michigan.  In addition to the number of Michigan residents participating in the 
SNAP program, legislators are harming their constituents by mandating cooperation
requirements.  During FY 2017, more than 62% of SNAP participants were in families
with children, almost 39% were in families with members who were elderly or had 
disabilities, and more than 46% were in working families (CBPP, 2019).  The assistance
required to help people should and can only be practical without the stipulations
that continuously cripple the effort to become self-sufficient, decrease hunger,
and help curb poverty among the most vulnerable American citizens.

 

Before the release of the USDA memo, the CBPP (2019) published a report explaining
why child support and the mandate for SNAP benefits was a bad deal for states and
low-income households.  The order is a bad deal because thousands of parents are
survivors of domestic violence.  For this reason, every State has a ‘good cause’
clause and must offer a possible waiver within its guidelines explaining public 
assistance programs and mandatory cooperation requirements.  A possibly unhealthy
and dangerous problem occurs when survivors need SNAP benefits but may be unaware
of the possible waiver.  And let’s face it, many caseworkers will not offer that
information during the application process.

 

When exploring North Dakota and its cooperation requirements, there are stringent
criteria for clients requesting a good cause waiver to be excused from suing the
other parent for child support.  The release includes, but is not limited to, proof
of physical and emotional harm to the child or the caregiver applying for benefits.
Unfortunately, according to the North Dakota guidelines (2011), the mere belief 
that cooperation might result in harm is not a sufficient basis for finding a “good
cause.”  The State has reported its share of domestic violence issues over the past
few years.

 

There has been an increase in the number of reported new victim cases, with 4,722
and 5,172 in 2017 (Caws North Dakota).  The increase did not, for some reason, send
a red flag to the policymakers that the ability to receive public benefits, like
SNAP, must be made more accessible for survivors of violent situations.  They should
have made access more friendly and safe for possible recipients.  Not only did the
number of cases reported that impacted children increase, but the number of women
who reported being pregnant at the time of their assault increased by 24.  Unbelievably,
North Dakota said that between 2013 and 2017, no child support cases were opened
with a ‘good cause’ determination (OCSE, 2018).

 

It is unrealistic to suppose that none of the women reporting domestic assault issues
failed to apply for SNAP and other benefits.  On the other hand, it is very realistic
that the State did not grant one person a good cause exemption excusing them from
participation in the child support program simply because a caseworker did not believe
their claims.  We know that SNAP kept 14,000 North Dakotans out of poverty, including
6,000 children, between 2009 and 2012 (CBPP, 2019).  Because of this, it is a wonder
how many children went hungry because caseworkers denied benefits based on personal
judgment.  Unfortunately, the answer to that question will forever be unknown.

 

Moving on to homelessness and food insecurity are linked issues that must be addressed
by all when examining the SNAP/Child Support mandate in every State.  Idaho is one
of the six states that have already implemented the cooperation mandate.  As recently
as 2018, there were reports of an increase in homeless students living within the
State.  Data collectors blame rising housing costs for the increased amount of children
living in unstable housing situations.

 

The breakfast and lunch programs are automatically free when a family is enrolled
in the SNAP program.  According to Idaho.gov, between 2017 and 2018, 47% of students
qualified for free or reduced-price lunches.  School meals are the only meal source
for many of these children on weekdays.  National trends show that approximately
10% of students qualifying for free lunch may be living in homeless situations (
Idaho.gov).  The SNAP program also serviced 10% of its state population in 2017.

 

That number of qualifying students grows significantly when exploring the number
of families with children receiving SNAP benefits.  In F.Y. 2017, more than 76% 
of SNAP participants were in families with children (CBPP, 2019).  With the strict
criteria in the SNAP/Child Support striate, the USDA must conduct a study to cross-
reference homeless students and families denied SNAP benefits due to failure to 
cooperate with child support enforcement.  Rescinding the mandate would better identify
who would need help.  By doing this, Idaho legislators could guarantee that homeless
students would not be left hungry simply because a parent could not cooperate for
any reason.

 

Idaho and every other State must make it easier for children to receive SNAP benefits
to help ensure they receive healthy meals daily.  Because the average monthly SNAP
benefit for Idaho households with children is $397 or $1.25 per person (CBPP, 2019).
The meal cost per person is even more critical when considering that Idaho reported
an R.O.I. of $6.13 in 2017.  Idaho government officials could have better utilized
the $5.13 profit to feed the growing homeless population of children.  Or the State
could have helped decrease the alarmingly high child poverty rate among its Black
children reported by the Children’s Defense Fund (2019) at 72.5%.

 

Instead, state leaders choose to enforce guidelines that ultimately further disenfranchise
low-income citizens, especially children.  Idaho forces cooperation with child support
enforcement by refusing to distribute any child support collected to its families
receiving welfare benefits and failing to reinvest any profits or incentives into
uplifting its poor citizens out of poverty.  Experts have proven year after year
that making it more difficult to obtain public benefits, especially SNAP benefits,
is detrimental to children and parents.  The USDA must use these six states as examples
of why the SNAP/Child Support cooperation mandate has to be removed immediately.

 

With all that is known about the harm that the SNAP/Child Support cooperation requirement
causes to families with children, it is equally important to explore the possible
reasoning behind the USDA pushing states to reconsider the imposition of the mandate.
And that is, of course, money.  Since implementing the Personal Responsibility and
Work Opportunity Act (PRWORA) of 1996 and the ‘reform’ of the child support system
under former President William Clinton (along with bipartisan support), several 
new rules were included in the bill. One of the main rules was that the welfare 
program would have time limits determining how long a person could remain on the
welfare rolls.

 

 

While the Federal government has ‘graciously’ permitted the states to determine 
the lengths of time a recipient can receive public benefits, it is specific on the
time limits allowed nationwide.  States cannot provide cash assistance from the 
Federal TANF funds longer than 60 months to a family that includes an adult recipient(
CBPP, 2018).  This time limit may be extended in child-only cases at the State’s
discretion and based on specific criteria.  Because of the five-year time limit,
the number of TANF cases is declining, directly affecting the number of active child
support cases.

 

For example, the number of total caseloads with current assistance status declined
by nearly 472,000 between 2013 and 2017.  Even more substantial is the decline of
over 726,000 in formerly assisted cases.  The difference means a massive reduction
in the State’s money that they can add to their wallet, courtesy of the welfare 
mandate requiring recipients to sign over their rights to child support payments.
When
explicitly identifying the amount of child support collected for current assistance
cases, collections decreased from $908,280,972 in 2013 to $710,521,048 in 2017 (
OCSE, 2017).  Naturally, the amount of distributed child support declined to just
over $300 million during the same years.

 

As previously discussed, the R.O.I. is extremely important to the government\’s 
overall profit regarding child support programs.  This amount has also decreased
nationally from $5.31 to $5.15 during the specified five-year period, which is still
an excellent profit for the $1 spent.  Based on these numbers and collection amounts
on the decline, just like in any business, the government must explore other options
to generate more money when experiencing a profit loss.  The federal government,
through the USDA, has decided that its new income stream should be funded by the
SNAP program.

 

Texas can be used as the perfect model to further illustrate why states must refuse
the SNAP/Child Support mandate instead of using the money already collected to assist
families and children.  Texas is one of the states that has decided to pass through
$75 of child support collected on behalf of families receiving TANF grants.  However,
just as the number of current assistance cases has declined, so has the amount of
money distributed.  The State passed through $1,448,754 in 2013.  However, this 
amount drastically dropped to just $619,636 in 2017 (OCSE, 2018).

 

Instead of increasing the pass-through amount by updating the statute to benefit
families, Texas has taken a different, arguably more expensive approach.  Government
officials overseeing child support operations within The Lone Star State decided
it was time to upgrade the computer system used by the child support agencies.  
The computer system upgrade, dubbed T2, began in 2007 and would cost taxpayers $
220 million upon completion.  The upgrade is incomplete, and the cost has ballooned
outrageously.

 

There is no guarantee that child support collections will increase by forcing Texas
to implement the mandate.  Yet, numerous studies have proven that more children 
will fall into the insecure food category.  With an R.O.I. reported in double digits
for the past few years, it would surely be Texas if any state can afford to continue
ignoring the SNAP/Child Support mandate.  The State needs to examine more ways to
assist its low-income, poor, and working families who rely on SNAP benefits instead
of spending hundreds of millions in an attempt to reduce paperwork within child 
support offices.  Hopefully, all states will consider removing the mandate while
ensuring that the SNAP program becomes more family-friendly and cost-effective.

 

In conclusion, the USDA must examine its data before recommending that states enforce
the SNAP/Child Support cooperation mandate.  It is not enough to state that the 
agency thinks enforcing this requirement will force parents to pay child support
and increase the payment amounts.  Statistically, parents are paying what they can
and when they can.  If parents are denied the primary food benefits supplied by 
the SNAP program, most will be unable to provide the little they can still afford
while suffering to provide for their own basic needs.  Food insecurity is an epidemic
plaguing the United States, and every State reports its food shortcomings.  As people
pull themselves out of poverty, the government needs more help, not a metaphoric
rope pulling people back down.

 

References:

Arthur, J. (2018, July 31).  Do parents who owe the most child support debt have
reported income? Retrieved from https://www.acf.hhs.gov/css/ocsedatablog/2018/07/
do-parents-who-owe-the-most-child-support-debt-have-reported-income

Barone, A. (2019, May 5).  America’s poorest states in 2019.  Retrieved May 11, 
2019, from https://www.investopedia.com/articles/markets/080116/americas-poorest-
states-2016.asp

Caws North Dakota.  (2019, April 22).  Facts & stats.  Retrieved May 8, 2019, from
http://www.cawsnorthdakota.org/index.php/resources/factsandstats/

Center for Budget and Public Priorities.  (2018, October 16).  A quick guide to 
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Center of Budget and Policy Priorities.  (2018, May 15).  House farm bill’s SNAP
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Children’s Defense Fund.  (2018, September 13).  Child poverty in America 2017: 
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2018/09/Child-Poverty-in-America-2017-State-Fact-Sheet.pdf

Cornell Law School.  (2019, April 15).  7 C.F.R. § 273.11 – Action on households
with special circumstances.  Retrieved from https://www.law.cornell.edu/cfr/text/
7/273.11

DallasNews.com. (2019, May 17).  After $367.5 million, Texas gets no new child support
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computer-software-just-painful-lessons

Feeding America.  (n.d.).  Health care provider training: Screening for and addressing
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Idaho State Department of Education.  (n.d.).  Title IX-A: Homelessness in Idaho.
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Kalsi, D. (2019, May 1). USDA recommends states require food stamp recipients to
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Kids Count.  (2018, September).  Children in poverty (100 percent poverty) | Kids
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any/321,322

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Michigan State Disbursement Unit.  (2015).  Escheatment of child support.  Retrieved
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Nchako, C., & Cai, L. (2018, May 3).  A closer look at who benefits from SNAP: State-
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United States Department of Agriculture.  (2019).  State flexibilities related to
custodial and noncustodial parents’ cooperation with state child support agencies.
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