Memorandum by Families Need Fathers (CM 2)
CHILD MAINTENANCE AND OTHER PAYMENTS BILL
1. This is a brief by Families Need Fathers for the Committee Stage of the Child Maintenance And Other Payments Bill. For convenience we attach at appendix A our general brief, circulated before Second Reading, and at appendix B the results of a survey carried out amongst FNF members on the costs of Non-Resident Parenting.
2. Families Need Fathers (FNF) exists to promote an aspect of child welfare: the need of children whose parents live apart to have the full involvement of both their parents unless, in exceptional cases, this would be against the child's interest. As is proper for a charity our first task is social care work. We support parents to get, and to use for the best, adequate parenting time with their children. We have a raft of services to help and advise such parents. We are the most important single source of help for them. The total number of 'contacts' with them is now some 400,000 pa. We get core funding for this work from the DFES. They and other funders support particular projects. There remains a lot of unmet need. Some 2.5 million parents live apart from some 4 million children.
Summary at FNF's general position on the Bill
3. The Bill in general looks unlikely to solve the problems that have occurred during the years the Child Support Agency has existed. It is punitive, draconian and internally contradictory in character and very short on positive solutions, except in a few areas. FNF would like the Bill to promote shared parenting - encouraging both parents to play a full part in their child's life after the parents separate or divorce, including both making appropriate financial provision for their child's upbringing. Instead the Bill contains measures that are likely to reduce parents' desire to co-operate with the new body, C-≠MEC, because the Bill ignores the costs of parenting 'non≠resident parents' (NRPs). The formula will in some respects be even more arbitrary than the current one.
4. In all other respects law and policy puts the welfare of the children as the first and paramount consideration. It is significant that this Bill does not mention this. The first need of children is for good and loving parenting. In the normal run of things that will be from both parents. There should be a strategy for the parenting of children of separated parents and then a policy for financing it. This Bill reverses this priority. The finance is put before the parenting. It is this that has caused much of the resistance to previous policies. A child support policy predicated on the assumption that one parent is excluded from caring for the children, but must support the other parents household, will be resisted in the future as it has been In the past A policy predicated on the joint upbringing of the children and joint financial support will win the consent of caring parents. It will separate them from irresponsible ones for whom some sanctions may be appropriate.
5. We do support a few proposals in the Bill.
Brief on Bill clauses
6. For convenience our commentary on clauses follows the order of the Bill; We only cover clauses which we believe raise important issues.
Shared parenting and the Bill
Clause 2(1) The phrase "the number of those children who live apart from one or both of their parents" Is the first indication that DWP has far too crude a model of family relationships in mind in drafting the Bill. In reality an increasing number of such children live in two homes e.g. where their parents have a shared residence order, increasingly common. Others have contact, so will stay with one parent though they spend the majority of their time with the other. Only a minority of children genuinely have only one home, because they see nothing of their other parent or do not know who their other parent is.
Suggested amendment: Delete "who live apart from one or both of their parents". Insert "whose parents have separated or divorced"
Clause 2(2): we strongly support this sub-clause. 2(2)(a) is especially important since the more that parents can be encouraged to make realistic provision for the costs of bringing up their children via private and voluntary arrangements, the better for the children. It allows both parents to assess their own finances, including the costs of each when bringing up their child.
It is clear that many parents in the C-MEC target market will need support if they are to be able to do this effectively. They should not be put in the hands of either the legal profession or C-MEC if at all possible. The Government will therefore have to finance some of this support preferably by mobilising the resources of the voluntary sector and using private sector resources e.g. call centres, where appropriate. Ministers should be asked to spell out what funding they plan to make available for this purpose. The Bill is otherwise silent on this important subject so 2(2) is the only opportunity to raise it (though the subject is implied by Clause 5(1).
We also support 2(2) (b), with the proviso spelt out above: these applications should only be used as a last resort, where it has not been possible to reach voluntary arrangements and implement them successfully.
Clause 4: We support 4(a) and appropriate funding for it. Our comments on 2(1) apply to 4 (b).
Suggested amendment: Delete 4(b) or amend as 2(1).
Punitive aspects and the Parenting costs of the Non-Resident Parent
Clause 6: We believe that the main significance of the powers taken here is that they will allow C-MEC to charge non-resident parents'. (NRPs) (a misleading phrase in itself, for the reasons already given) for "the use of its services", In the White Paper's words. The White Paper went on to make it clear that "the clear burden of charging should fall on the non-resident parent and not the parent with care."
This principle ignores the very real costs of parenting for the NRP, very often. We quoted some figures from a small survey we did of FNF Members on these costs in our Second Reading brief, the results of which are attached as appendix B. Since this point will recur on the Bill, and it is a very important point we repeat them here (and we can supply further material on request):
∑ Travelling times varied widely but of those who had contact and responded, 27 out of 38 were travelling 10 miles or more to collect and deposit their child. 23 of the 27 were travelling more than 100 miles. In a flexible labour market and a global economy, resident parents often travel a long way to start a new life after divorce, and NRPs parents' travelling costs, for them and their children, rise accordingly.
∑ It is difficult to generalise about parenting time, but it is worth noting that very short periods of parenting time can involve significant journeys (see 1,3,10 etc etc). 19 were seeing their children weekly or more than 52 nights a year.
∑ Adding these together travel costs are considerable. Of the 30 who responded to this question, 20 had expenses above £400 a year, 17 above £1000.
∑ We did not get a complete set of responses on accommodation costs, probably because of the difficulty of estimating them when a child stays In the NRP's home. But it is clear that the child has to have a bedroom. Looking at UK house prices, the cost of an extra bedroom alone, in terms of rent or mortgage/purchase, Is likely to be a significant sum if we consider the costs over the life of the child until it is 18 or 21.10 of the 15 who responded have annual accommodation costs above £500 a year, with the peak at £5400.
∑ Feeding hungry children does not come cheap, as every parent knows. Of the 28 respondents, 3 were spending more than £1000 a year, 9 £500-1000 and 13 more than £100.
∑ NRPs often spend money on their children's clothes. 24 respondents did so regularly, enough to provide annual costings. All but four spent over £100 a year, with the peak at £2400.
∑ Entertainment is a very big expense, unavoidable when lively children are staying with you. 22 respondents provided annual costings. Everyone spent more than £100 a year, five spending £1000 or more.
∑ Then there is a host of other expenses, including the child's mobile phone (often vital for staying in touch with the NRP), medical bills, pocket money, presents etc. 25 respondents provided costings, with 20 spending more than £100 a year.
Amending Clause 6 would not meet our concerns, since it is drafted in such a general way. What we would like to see is a statement from Ministers that these powers will be used sparingly and fairly, and not be solely directed at NRPs. If a 'parent with care' made a malicious application, when well aware that the NRP was willing to agree a voluntary arrangement, should the 'parent with care' not be charged?
Clause 8: this is far too widely drafted. As it stands, it could allow C-MEC to contract out the taking away of passports, or applications to the Court, to jail, apply a curfew or confiscate driving licenses. This cannot be right. The Clause should be confined to administrative matters where there is a case on value for money grounds, not applied to the core functions of the Commission. Ministers should be asked to table a Government amendment to achieve that.
Clause 11(2): this is another clause that needs amending in the light of our points on 2(1).
Suggested amendment: delete "as living apart from a parent." Insert "as receiving insufficient financial support from his or her parents."
Parents on benefit
Clause 15: we strongly support this clause, which means that 'parents with care' on benefit will no longer be referred automatically to C-MEC, as they are with the CSA. This will encourage voluntary arrangements and mean that no longer will both parents be caught by the system entirely against their will.
Clause 16: detail discussed under Schedule 4 below. In general the changes proposed here continue the 'one size fits all' approach of the CSA, and most importantly they ignore the costs of the 'NRP', discussed above.
Punitive aspects (ii): Collection and enforcement
Clause 19: in general, the use of deduction from earnings orders as a basic method of payment seems reasonable, where 'NRPs' are genuinely able and unwilling to pay appropriately. We hope that the new 23(4) of the 1991 Act means that NRPs who are willing but unable to pay will not be pursued by C-MEC. It would be good to ask Minister to confirm that.
We would like the House of Commons to vote on the regulations provided for under 32B. See Clause 50(6), which says it will be subject only to a negative resolution procedure.
Clauses 19-23: Again, all these powers may be reasonable in some cases. But C-MEC, judging by its predecessors woeful record, will make mistakes (witness the criticism of the CSA by the Information Commissioner in his 2007 Annual Report, and many other criticisms from the PAC and others). None of these clauses specify any right of redress. There should be a clause providing that mistakes will be appropriately redressed.
Clause 25: We are strongly opposed to C-MEC being able to obtain the disqualification for holding or obtaining travel authorisation without having to apply to a Court. The contrast with driving licenses is startling. In a global economy a passport may well be vital to someone's work and therefore their ability to pay maintenance. We have a number of members whose ex-partners have taken their children abroad. This would stymie their efforts to see them. And it seems oppressive to be able to take away someone's ability to travel merely by bureaucratic fiat, without recourse to a court. Offering a right to appeal to a court is not enough. C-MEC should be made to think carefully before proposing such a drastic step' and not put the onus on the NRP to appeal.
Suggested amendment: Delete "The Commission may make an order" insert "The Commission may apply to the court for an order". The Government should be asked to propose any consequent amendments to this clause.
Clause 26: The introduction of curfews takes the sad saga of disproportionate punishments in the field of family maintenance a step further. How will curfews be policed? Why cannot the place' be someone's home, if they have one? If they are viewed as a cheap alternative to jail, there is a huge danger that they will be abused. They criminalise a civil issue. The threat to send someone to prison for breaching a curfew drives this home.
The Bill seems to mean that someone could be compelled to live anywhere in their country of domicile, depending on where in Great Britain they live. Why cannot it be worded more precisely? 26(4) does not provide a 100% insurance policy that curfews will be operated sensibly, in so far as they can be.
Clause 27: though confirming an existing sanction, the power to send someone to prison has to be seen as part of the wider punitive regime.
Clause 27 also has a subsection, at 2(D). There are similarly worded subsections in other clauses, but it is particularly objectionable here, for it takes a way the Court's ability to examine the facts of the case in depth. Why is someone willing to risk prison? He may be irresponsible. He may, as in the Cox case, wish to make stand against injustice. He may be genuinely in financial difficulty. Why can the Court not look at all this?
Clause 28: it is welcome, though odd, that the Court has to be involved before C-MEC can confiscate a driving license, given that passports and ID cards can be confiscated administratively. But even with that safeguard, we know from the CSA's history that this power is misused. FNF has members whose driving licenses have been confiscated whilst working, or seeking to work, as drivers. This does nobody any good, least of all the child.
Clause 33: Additional Special Cases. We welcome that C-MEC will be able to recognise that sometimes both parents are, in the Bill's jargon, 'parents with care' and will be able to net off payments.
This points up however that the Bill takes inadequate notice of the shared parenting that often takes place, and the associated costs.
Clause 37: This raises the prospect that some 19 year olds will be in 'approved training' while in full time employment yet the NRP will be compelled to pay child maintenance for them. It would be useful for the Minister to be asked to confirm that this is not their intention.
Clause 50: As noted above 50(6) is drawn too widely. At a minimum the Clause 19 32B Regulations should be subject to a positive procedure and we would argue that only Regulations on administrative aspects should be under the negative procedure.
Clause 51(1) defines C-MEC as a body corporate. The CSA was an executive agency. Both models give very similar managerial freedom to the body. The only obvious reason for the change is that it will be more difficult for MPs and others to get Ministers to answer correspondence and Parliamentary Questions on C-MEC. This reduction in transparency should be resisted. It would be helpful if the Minister made a commitment on the extent to which Ministers will be willing to answer Questions and correspondence about C-MEC.
This Schedule makes the appropriate arrangements for transferring CSA functions to C-MEC. As the table on page 73 of the Explanatory Notes makes clear, C-MEC will be handling three regimes, the original 1991 one, the 2000 regime and the new one. Our members are already
telling us that the CSA is losing its institutional memory of the 1991 regime, highly complex as it is. How will C-MEC cope, when adding a new regime?
Ministers should be asked to confirm that they intend to move all existing cases onto the new regime as soon as practicable after C-MEC comes into operation, preferably within the first six months, except for those cases where parents opt to reach a private agreement instead.
4(1) This embodies the Bill's major change to the current formula for determining child maintenance: in future it will be based on gross earnings, not net earnings. Yet the income tax system has a number of allowances, including some introduced or modified by the last Chancellor of the Exchequer, for policy reasons. The new approach will ignore all these reasons. This is a case of simplification leading to arbitrary treatment.
4(3) DWP officials have told FNF that the changes will be neutral in their effects on payments. We have been unable to replicate that result it would be helpful if the Minister could be asked for a note spelling out that arithmetic.
4(4) FNF strongly opposes this increase for NRPs on benefit We understand that there is an argument that all parents should pay something towards their child's upbringing. But these people are among the poorest sections of society, trying hard to stay in touch with their children and play a part in their upbringing. The state should not penalise them for doing so. This proposal is entirely in opposition to the Government's commitment to lift children from poverty. They will be worse off than a childless person on benefit for no good reason. This sub-clause should be removed.
5(3) It is regrettable that so much detail is lacking from the Bill and consequently the Secretary of State is asking for regulatory powers. It is especially regrettable that we do not know how parents will escape or stay in the scheme. This subject deserves a full debate. Encouraging private arrangements will not get very far if one parent can simply block them, secure in the knowledge that C-MEC will step in. Schedule 5(4) strongly implies that
6(1) Raises great fears about the confidentiality of data. As noted above the Information Commissioner has very recently criticised the CSA for its inability to keep data confidential. How much greater will be the risks if C-MEC can pass such data to Its contractors?
Suggested amendment: delete 6(1) and any consequential amendments.
6(2) raises similar fears. Taxpayer confidentiality is a long respected tradition of the UK tax system, contributing to our relatively high degree of compliance. How much confidence can we have that C-MEC will preserve that confidentiality, especially in the light of 6(1)?
CHILD MAINTENANCE AND OTHER PAYMENTS BILL
Parliamentary Brief by Families Need Fathers.
7. This Is a brief by Families Need Fathers on the Child Maintenance And Other Payments Bill.
8. Families Need Fathers (FNF) exists to promote an aspect of child welfare: the need of children whose parents live apart to have the full involvement of both their parents unless, in exceptional cases this would be against the child's interest. As is proper for a charity our first task is social care work. We support parents to get and to use for the best, adequate parenting time with their children. We have a raft of services to help and advise such parents. We are the most important single source of help for them. The total number of with them is now some 400,000 pa. We get core funding for this work from the DFES. They and other funders support particular projects. There remains a lot of unmet need. Some 2.5 million parents live apart from some 4 million children.
9. The main brief makes some general points about the Bill for the Second Reading Debate. We plan to provide a more detailed commentary on individual clauses that raise important points before Committee Stage. We also plan to suggest some amendments.
10. The Bill in general looks unlikely to solve the problems that have occurred during the years the Child Support Agency has existed. It is punitive, draconian and in places contradictory in character. It is very short on positive solutions, except in a few areas. FNF would like the Bill to promote shared parenting - encouraging both parents to play a full part in their child's life after the parents separate or divorce, including both making appropriate financial provision for their child's upbringing. Instead the Bill contains measures that are likely to reduce parents' desire to co-operate with the new body, C≠MEC, because the Bill ignores the costs of parenting for 'non≠-resident parents' (NRPs). The formula will in some respects be even more arbitrary than the current one. The proposed methods of calculation either fail to consider the practical reality of parenting costs or in certain instances Increase the risk of child poverty. We do support a few proposals in the Bill.
11. To illustrate the punitive nature of the Bill, it is worth rehearsing the coercive measures - enforcement measures in the Department's words - introduced in the Bill:
(i) C-MEC can apply to a court to send someone to prison (Clause 27).
(ii) C-MEC can apply to a court to confiscate someone's driving license (Clause 28)
(iii) C-MEC can disqualify someone from holding or obtaining travel authorisation (i.e. a passport or ID card), without having to ask a Court for permission (Clause 25)
(iv) C-MEC can apply to the Court for a curfew order, confining someone to 'a place so specified' for up to 12 hours a day. This place can be anywhere in either England and Wales or Scotland, depending on whether C-MEC is approaching an English or Welsh magistrate or a Scottish Sheriff.
(v) Deduction of earnings orders, including fines for non-compliance (clauses 19)
(vi) Lump sum deduction orders, to collect arrears (Clause 22)
(vii) Power to make administrative liability orders (Clause 23)
(viii) Power to search someone for money owed (Clause 25)
(ix) Power to recover C-MEC's costs of doing (iii) (Clause 25)
12. The Bill is draconian because:
∑ Taken together, the punitive measures area disproportionate and coercive responses to a social issue that needs a much more positive approach;
∑ It shifts some responsibilities into the hands of the new body, C-MEC, that are more appropriately decisions for the courts e.g. the taking away of travel documents.
∑ While we support enforcement of maintenance payments, some individual measures look very disproportionate and wrong-headed. How will curfews be policed? Why cannot the place' be someone's home, if they have one? If they are viewed as a cheap alternative to jail, there is a huge danger that they will be abused. They criminalise a civil issue.
∑ A lack of uniformity and an inconsistent approach to enforcement will lead to C-MEC being even less popular than the CSA.
∑ The use of bailiffs to seize property may adversely impact on the child's wellbeing;
∑ The Children and Adoption Act 2006 was in part enacted because Ministers and the Courts realised that imprisoning parents for child related matters adversely impacted on children. Such punishments have rarely, if ever been used.
∑ C-MEC will be a Non-Departmental Public Body, not an executive agency of the Department of Work and Pensions. So far as we can see there are no managerial reasons for this. It will simply make it harder to submit C-MEC to Parliamentary and public scrutiny.
13.The Bill is internally contradictory because no rationale is provided for some powers depending on an application to the courts and in other cam not C-MEC can take away travel documents on its own decision, yet must apply to a court to get a driving license confiscated. Yet both are hugely significant decisions. They can damage someone's livelihood and thereby their ability to pay child maintenance. They can both make it more difficult for a parent to stay in touch with their child. They can stop the parent taking a child on holiday. Why should one decision be a matter of administrative flat and the other a Court matter?
14.Taken in the round, the Bill looks far more likely to alienate non-paying and part-paying parents than encourage them to meet their responsibilities as parents. FNF believes that the Bill contains measures which will adversely impact on child wellbeing, encourage resident parents to break contact orders and therefore place an unnecessary burden on the court service. We support punitive measures which address NRPs who wilfully and stubbornly refuse to support their children, but the impact of this Bill as drafted would go much wider than that group.
Positive solution: shared parenting and recognising both parents' parenting costs
15. We are pleased that the Bill mentions, in Clause 2, that one of C≠-MEC's subsidiary objectives will be "to encourage and support the making and keeping by parents of appropriate voluntary maintenance arrangements for their children". The Bill is otherwise silent on how this objective will be achieved. FNF hopes that Ministers will be pressed at Second Reading and thereafter to say more about how this objective will be achieved. In particular they should be pressed to set out C-MEC's budget for this work, compared with its enforcement budget.
16. For Clause 2 contains the grain of a positive approach to encouraging shared parenting and appropriate child maintenance, by aiming towards a system in which both parents accept responsibility for their children's upbringing, in the widest sense.
17. FNF would like to see a system that takes account of the full costs of shared parenting, and the income and assets of both parents, in deciding the appropriate financial arrangements. We believe this would be in the best interests of the child and be fair to both parents. It would be part of a wider system in which shared parenting and finance are handled together, in the best interests of the child. Parents should not be allowed to enforce financial agreements while blocking the child's reasonable contact with the ex-partner.
18. Accommodation and transport are major costs which the system needs to take into account We surveyed a small sample of our membership recently on their parenting costs. Findings included:
(i) Travelling times varied widely but of those who had contact and responded, 71% were travelling 10 miles or more to collect and drop off their child. 60% were travelling more than 100 miles. In a flexible labour market and a global economy, resident parents often travel a long way to start a new life after divorce, and NRPs parents' travelling costs, for them and their children, rise accordingly.
(ii) It Is difficult to generalise about parenting time, but it is worth noting that very short periods of parenting time can involve significant journeys. 50% were seeing their children weekly or more than 52 nights a year.
(iii) Adding these together travel costs are considerable. 66% of respondents' expenses were above £400 a year and 56% had travel expenses of more than £1000 per annum.
(iv) We did not get a complete set of responses on accommodation costs, probably because of the difficulty of estimating them when a child stays in the NRP's home. It is clear that the child has to have a bedroom. Looking at UK house prices, the cost of an extra bedroom alone, in terms of rent or mortgage/purchase, is a significant sum. Of those who did reply, costs accommodation costs were estimated to be between £500 and £5,400.
(v) Feeding hungry children does not come cheap, as every parent knows. 10% were spending more than £1000 a year, 32% £500-1000 and 46% more than £100.
(vi) NRPs often spend money on their children's clothes. 64% respondents did so regularly, enough to provide annual costings. 90% spent over £100 a year, with the peak at £2400. Parents with shared residence often provide a full set of clothing at both households.
(vii) Entertainment is a very big expense, unavoidable when lively children are staying with you. All respondents spent more than £100 a year, 13% spending £1000 or more.
(viii) There are many other expenses incurred by Non-Resident parents including the child's mobile phone (often vital for staying in touch with the NRP), medical bills, pocket money, presents etc. 80% spending more than £100 a year.
(ix) The term Non-Resident parent is misleading, as many NRPs have their children live with them for part of the week.
19 We are not optimistic that the present Bill can be amended to come anywhere near a shared parenting model, though we plan to suggest some amendments which would start down that road. We would like to see as an interim measure a simplification so that there would be no C-MEC payments at all in three circumstances:
(i) Where the NRP' is of low or low middle income and has any staying contact at all (any money to be extracted anyway will be modest and cost more to get than it might be worth)
(ii) Where the NRP' has more than a stated and fairly modest amount of parenting time, say 60 nights a year.
(iii) There is an order for shared residence. (This may increase resistance to agreeing such orders, but the argument will be about child welfare and this might have to be accepted).
20. To calculate contributions, we would like a graduated system, day by day, so each day the NRP has the child nets off the payment with a low threshold so all or most couples are involved.
21. We would like to see calculations based on the division of the child's time between the two homes, as set out in either Contact/Residence Orders or a written agreement signed by both parents.
22. Many of our members have experienced the Resident Parent being financially motivated and rewarded when they unilaterally break Court Orders. Applications are then made to the CSA to increase the payments received as the children (illegally) reside with them for a greater number of nights. We would like to see the Bill contain specific measures to address this problem.
23. At a minimum we hope that Ministers will say at Second Reading how they plan to take the NRP's parenting costs into account in the new system. There will be opportunities to do this both as the Bill progresses and In subsequent Regulations made under the Act
24. Given the United Kingdom's poor performance in the UNICEF Child Wellbeing Report, we are disappointed that Government is not taking a more positive approach to addressing child welfare and wellbeing considerations in all of its policies. This Bill is an opportunity to begin to redress that In the UNICEF Report, where the United Kingdom polled at the bottom, three of the top four countries had shared residence as the norm. We believe that the Government should assess the social and financial benefits of a system which treats parents equally, as research supports us in our belief that children thrive under such arrangements. When one parent is marginalised by our current legal system, the Courts and State give an implicit message that the NRP has 'less responsibility' for the child. Such a message is in no-one's best interests.
The calculation of child maintenance
25. The Bill's major change to the current formula for determining child maintenance is that it will be based on gross earnings, not net earnings. Yet the income tax system has a number of allowances, including some introduced or modified by the current Chancellor of the Exchequer, for policy reasons. The new approach will ignore all these reasons. This is a case of simplification leading to arbitrary treatment
26. C-MEC will be empowered to collect income data from HMRC direct This data will be available to C-MEC employees and anyone employed by a third party providing services to C-MEC in connection with child support (Schedule 6, clause 1). This seems to sound a death-knell, frankly, for tax-payer confidentiality. There will be sanctions against anyone from C-MEC or its suppliers who breaches confidentiality, but how much confidence can anyone have that this data will be kept confidential always?
27. It is extremely objectionable that the Bill proposes to raise contributions by NRPs on benefits from £5 to £7 a week. The people are among the poorest sections of society for whom life is already very basic, who are trying hard to stay in touch with their children and play a part in their upbringing. The state should not penalise them for doing so. It is hard to see how people with responsibility for children living with them will be able to pay the associated costs with such a deduction in place. Rather than preventing such parents taking care of their children they should be enabled to do so. A method which does not damage the children and their relationship with their parents should be found. This proposal is entirely in opposition to the Governments commitment to lift children from poverty. They will be worse off than a childless person on benefit for no good reason. This clause should be removed.
28. One severe problem the CSA has is that is running cases calculated in different ways. The pre-2000 formula in particular was very complex and current staff do not always understand it Ministers should be asked to confirm that they intend to move all existing cases onto the new regime as soon as practicable after C-MEC comes Into operation, preferably within the first six months, except for those cases where parents opt to reach a private agreement instead.
29. We welcome several aspects of the Bill, despite its overall character.
∑ It is good that there will not be an automatic referral of resident parents on benefit to C-MEC, as there was with the CSA.
∑ And that there is very limited recognition of shared care, in cases where each ex-partner is the primary carer for one of their children. The proposed netting off is sensible.
∑ For the extremely recalcitrant parents, It is sensible to use attachment of earnings and data supplied by credit reference agencies.
∑ Extension of the £10 disregard to cases on the original child maintenance scheme.