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Driver’s License Suspension: Early Experiences Putting CSB 25-02 into Practice

Driver’s license suspension is a tool available to child support agencies (CSAs) for encouraging child support compliance. However, license suspension may result in unintended negative consequences and policymakers are reconsidering how to use it effectively. In 2025, Wisconsin issued Child Support Bulletin (CSB) 25-02 to curtail driver’s license suspensions when obligors are unable to pay. CSB 25-02 provided parameters for when CSAs should not pursue driver’s license suspension and outlined steps to take before certifying a driver’s license for suspension. This report provides insight into CSA experiences with and perspectives on the change in the year following CSB 25-02’s issuance. It explores staff views on the benefits and challenges related to the policy change; how they interpret key policy elements; questions and concerns; and clarifications and guidance to help support implementation.

Study data come from a statewide web survey of CSA directors (response rate=83.8%), and interviews with asubset of agency staff (n = 10). Topics included beliefs and attitudes about the policy change; perceptions of each component of CSB 25-02; areas of additional guidance desired; and perspectives on local implementation. Interview topics included overall impressions of the guidance; operationalizations of each policy component; and data sources and use of KIDS related to implementation. The survey included closed-ended and open-text questions. Descriptive statistics were generated for close-ended items. Open-text responses and interviews were coded using structured tabular thematic analysis.

Survey findings indicate mixed perceptions on the clarity of CSB 25-02’s goals and expectations of CSAs, as well as concerns  about fairness of the policy change for custodial parents and children.  Survey and interview responses provide insight into these mixed perceptions. Many directors and staff members expressed support for the key ideas underpinning the policy guidance (i.e., that outreach is a core component of case management and agencies should not pursue driver’s license suspension when an obligor is truly unable to pay). Yet, concerns about CSB 25-02 as written also arose. Most participants with concerns interpreted the preamble to the ability to pay screening criteria to mean the driver’s license suspension process can only be used when obligors have employment and formal income observable in administrative systems and cannot be pursued in situations in which CSAs generally find it most useful (i.e., when obligors have gig work, self-employment, or do not cooperate). Many saw the guidance as conflating the idea of  obligors having no formal employment and earnings captured in administrative data with an obligor having no income at all.  Some also interpreted it as prohibiting CSAs from initiating the license suspension process at all.

This interpretation conflicted with some internal CSA policies and shaped concerns about potential consequences. For those with concerns, CSB 25-02 meant losing a key tool for fulfilling their mission—collections for CPs and children, especially those attached to self-payers—and the loss of a crucial outreach tool. Concerns included: for custodial parents and children, lack of compliance leading to material hardship and frustration; for obligors, fast-tracking contempt and other processes with potential for immediate impacts, as well as arrears accrual; and for courts and CSAs, increased burden, costs, and inefficiency.

Findings indicate confusion about the guidance, particularly related to the bulletin’s preamble, and uncertainty about the expectations and intent behind CSB 25-02’s processes. Revisions could help clarify both intent and expectations, and technical assistance could also help support implementation. Findings underscore the challenges in addressing the increasing number of obligors with income outside of traditional data systems. CSA staff and directors consistently identified self-employment and the gig economy as the primary areas where the new policy guidance feels most disconnected from the realities of their work. Specifically, confusion emerged regarding processes for obligors with clear “ability to pay” but no formal wages reported in traditional data systems. Further, some participants expressed that the rollout felt disconnected from agency practice and input, highlighting opportunities for incorporating practitioners’ feedback and expertise.

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Child Support, Child Support Policy Research, Enforcement, Orders & Payments

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