INCOME WITHHOLDING                            

CS 720P-5 Administrative Withholding Error

11/85 Revised 08/25/14 Training Completed 09/05/14 Last Reviewed 09/03/25

45 CFR 303-100

 

 

Responding to an Administrative Withholding Error

 

If the noncustodial parent’s (NCP’s) income has been withheld due to a CSS administrative error, you must promptly refund the money to the NCP, even if the money has been sent to the custodial parent (CP). For example, the NCP has no current support due, all arrears are paid in full, and income withholding was not terminated promptly, resulting in the NCP's case being overpaid. Consult with your management chain (Manager, Associate Regional Director, Regional Director, and CSS Director) if you need to refund money to the NCP due to an administrative error.

 

Income that has been withheld and disbursed in good faith is not an administrative error and should not be returned to the NCP. However, you may offset what the NCP has overpaid to the CP by reducing the amount of current support on an existing Notice to Withhold Income (NTW) until the “overpaid” amount has been recovered. The ordered current support amount (CRS) cannot be temporarily reduced or ended in ORSIS to make up for an overpayment. If there is an NTW in place and ORS is receiving payment via the NTW, contact the CP and explain the problem and attempt to arrive at an agreement about how much and for how long the current support amount will be reduced on the NTW. Notify the Senior Agent of the overpayment and the agreed upon reduced payment plan. The Senior Agent is then responsible to account for the overpayment in ORSIS by placing a hold on the case, refunding the difference between the ordered CRS and the reduced CRS per the agreed upon payment plan and adjusting the arrears balance. For more information and detailed procedures, refer to CS 450P-8 Child Support Awards – Downward Modification Results in Overpayment of Current Support Due. If the CP does not agree to a reduced amount to account for the overpayment, consult with your management chain about the next course of action to take. For example, you could inform the NCP that s/he will need to make arrangements directly with the CP to recover the money.

 

EXAMPLE: The NCP or the CP in a Non-IV-A case did not inform CSS that their support order for $500.00 per month was modified downward to $300.00 per month. CSS continued to collect and disburse the prior higher amount of $500.00 per month until three months later when the NCP notified CSS of the downward modification. Since the NCP had been current under the old order, he had overpaid the CP a total of $600.00 ($500.00 - $300.00 = $200.00 x 3 = $600.00.) You contact the CP and NCP and arrange to have the Notice to Withhold (NTW) reduced by half ($150.00) for 4 months ($150.00 x 4 = $600.00) so that at the end of this period the NCP is again current. The ordered current support amount in ORSIS should not be adjusted to account for the overpayment. The senior agent would follow procedures outlined in CS 450P-8 to account for the overpayment.