Secure Our Children Act¶
Implementation Timeline¶
Published February 2026¶
Based on Rev 2.5 of the Secure Our Children Act
Timeline Overview¶
SOCA implementation unfolds across three distinct phases over approximately 30 months from enactment, with ongoing operations thereafter. The phased approach allows IRS systems to scale progressively while ensuring families receive benefits as quickly as administratively feasible.
Implementation Phases at a Glance¶
| Phase | Timeframe | Primary Objectives |
|---|---|---|
| Standup | Months 1-6 | Regulatory framework, system development, portal design |
| Launch | Months 6-18 | Birth Support Payments begin, monthly CTC advance begins, contribution collection starts |
| Stabilization | Months 18-30 | First full tax year reconciliation, automatic adjustment mechanism activates |
| Ongoing Operations | Month 30+ | Steady-state administration, triennial reviews, program optimization |
Critical Milestones¶
| Month | Milestone |
|---|---|
| Month 0 | Enactment |
| Month 6 | Interim final regulations issued |
| Month 12 | Birth Support Payments begin (January 1 following enactment) |
| Month 12 | Child Security Contribution takes effect |
| Month 18 | Monthly advance CTC payments begin (July 1 following enactment) |
| Month 24 | First full tax year reconciliation complete |
| Month 30 | First solvency ratio assessment with adjustment potential |
| Month 36 | First GAO triennial review |
Effective Date Architecture¶
Immediate Upon Enactment¶
The following provisions take effect immediately:
- Family Security Stabilization Account establishment authority
- Treasury rulemaking authority for Child Security Contribution collection
- IRS rulemaking authority for child tax credit amendments
- Non-filer portal development authorization
- Outreach grant authorization ($250 million annually for five years)
- Interagency coordination directives (Treasury, HHS, USDA, SSA)
Month 6 -- Regulations and Guidance¶
| Deliverable | Responsible Agency | Dependencies |
|---|---|---|
| Interim final regulations (comprehensive) | Treasury/IRS | None |
| Child Security Contribution collection procedures | Treasury/IRS | None |
| Birth Support Payment verification protocols | Treasury/IRS | None |
| Non-filer portal specifications | IRS | None |
| Healthcare provider attestation standards | Treasury/HHS | None |
| State data-sharing agreement templates | Treasury | None |
Month 12 -- First Program Launch¶
| Provision | Effective Date | Dependencies |
|---|---|---|
| Birth Support Payments begin | January 1 following enactment | Regulations, verification systems |
| Child Security Contribution collection begins | Taxable years after enactment | Regulations, business guidance |
| Family Security Stabilization Account operational | January 1 following enactment | Account establishment |
| Non-filer portal live for Birth Support claims | January 1 following enactment | Portal development complete |
Month 18 -- Full CTC Implementation¶
| Provision | Effective Date | Dependencies |
|---|---|---|
| Monthly advance CTC payments begin | July 1 following enactment | Prior year return processing |
| Child tax credit amendments fully operational | First full taxable year after enactment | IRS systems update |
| Safe harbor provisions active | First reconciliation cycle | Regulations |
| Un/underbanked payment options fully deployed | July 1 following enactment | Bureau of Fiscal Service coordination |
Year 2+ -- Stabilization and Ongoing¶
| Timeframe | Provision | Dependencies |
|---|---|---|
| Month 24 | First full tax year reconciliation complete | Filing season completion |
| Month 24 | First quarterly transparency report published | Account operational data |
| Month 30 | First annual solvency ratio assessment (October 1) | 12+ months revenue data |
| Month 30 | Automatic rate adjustment eligibility begins | Two consecutive assessments outside 1.10-1.50 range |
| Month 36 | First GAO triennial review | 24+ months operational data |
Sequencing Requirements¶
Dependency Chain¶
Enactment
|
+---> Rulemaking Initiation (Month 1)
| |
| +---> Child Security Contribution Rules
| |
| +---> Birth Support Payment Rules
| |
| +---> CTC Amendment Implementation Rules
|
+---> Family Security Stabilization Account Setup (Months 1-6)
| |
| +---> Initial Capitalization Structure
| |
| +---> Reserve Accounting Protocols
|
+---> IRS System Development (Months 1-12)
| |
| +---> Non-Filer Portal Development
| |
| +---> Monthly Payment Infrastructure
| |
| +---> Safe Harbor Calculation Logic
|
+---> Partner Coordination (Months 1-12)
|
+---> SSA Birth Registration Data Sharing
|
+---> State Vital Records Integration
|
+---> Bureau of Fiscal Service Payment Rails
|
+---> Healthcare Provider Attestation Systems
Critical Path Items¶
The following items are on the critical path -- delays cascade throughout implementation:
-
Interim Final Regulations (Month 6): All program components depend on regulatory framework. Cannot launch Birth Support Payments or Child Security Contribution collection without finalized rules.
-
Non-Filer Portal (Month 12): Reaching non-filing families for Birth Support Payments requires functional portal. Directly affects take-up rates among lowest-income families.
-
SSA Birth Registration Data Sharing (Month 12): Automatic Birth Support Payment functionality depends on receiving timely birth data. Manual application-only model increases administrative burden and reduces take-up.
-
Monthly Payment Infrastructure (Month 18): Cannot deliver advance CTC payments without IRS systems capable of monthly disbursement to millions of households.
-
Solvency Ratio Calculation Systems (Month 24): Automatic rate adjustment mechanism requires accurate projections and account tracking. First assessment occurs October 1 of Year 2.
Parallel Workstreams¶
The following activities proceed concurrently to compress timeline:
Regulatory Track (Months 1-6): - Draft regulations with public comment - Coordinate with HHS on APSA interaction rules - Develop identity verification protocols
Technology Track (Months 1-12): - Non-filer portal development and testing - Monthly payment batch processing systems - Reconciliation and safe harbor calculation engines - Child Security Contribution collection integration
Partnership Track (Months 1-12): - SSA birth data sharing agreement - State vital records MOUs - Healthcare provider attestation network - Bureau of Fiscal Service payment coordination - Community organization outreach partnerships
Outreach Track (Months 3-18): - Multilingual materials development - Community organization training - Tribal government coordination - Non-filer identification using SNAP/WIC/Medicaid data
Institutional Standup¶
New Institutional Entities¶
SOCA creates one new institutional entity:
Family Security Stabilization Account
| Attribute | Specification |
|---|---|
| Legal status | Treasury account (not independent entity) |
| Administration | Secretary of the Treasury |
| Oversight | Congressional oversight through existing committee structure |
| Reporting | Quarterly transparency reports, annual reports to Congress |
| Staff requirement | Integrated into existing IRS/Treasury operations |
The Account does not require creation of a new agency, board, or commission. All administrative functions integrate into existing IRS and Treasury operations.
Existing Agency Responsibilities¶
Department of the Treasury
- Child Security Contribution rulemaking and policy
- Family Security Stabilization Account management
- Solvency ratio calculation and automatic adjustment administration
- State coordination for top-on programs
- Quarterly and annual reporting
Internal Revenue Service
- Child Security Contribution collection (as additional income tax)
- Child tax credit administration (amendments to existing Section 24)
- Birth Support Payment processing and verification
- Non-filer portal development and operation
- Monthly advance payment disbursement
- Annual reconciliation and safe harbor administration
- Outreach coordination
Bureau of Fiscal Service
- Direct Express card program for un/underbanked recipients
- Check payment production and distribution
- Payment file processing
Social Security Administration
- Birth registration data sharing
- SSN issuance coordination with Birth Support Payment applications
Department of Health and Human Services
- APSA coordination (ensuring credit/payment disregards function)
- Outreach coordination through existing programs (WIC, Medicaid)
Department of Agriculture
- SNAP recipient outreach coordination
- Data sharing for non-filer identification (where authorized)
Staffing Estimates¶
| Agency | Estimated Additional FTEs | Primary Functions |
|---|---|---|
| IRS | 400-800 | Portal operations, payment processing, verification, outreach |
| Treasury | 50-100 | Account management, policy, solvency monitoring |
| Bureau of Fiscal Service | 50-100 | Card program expansion, check processing |
Note: Estimates assume IRS baseline systems exist for monthly payments from 2021 experience. Actual requirements depend on portal sophistication and automation level achieved.
Transition Provisions¶
Transition from Current Child Tax Credit¶
SOCA amendments to Section 24 take effect for taxable years beginning after December 31 of the year of enactment. This creates a clean break:
Final Year Under Current Law: - Tax year of enactment (filed in following spring) - Current $2,000 credit with partial refundability - Earned income requirements apply
First Year Under SOCA: - Tax year following enactment - New $3,600/$3,000 amounts by child age - Full refundability without earned income requirement - No income-based phase-out -- every qualifying child receives full credit - Monthly advances begin July 1
Mid-Year Start Accommodation: The statute authorizes transition rules for the mid-year July 1 commencement of monthly advances. Likely approach:
- July 1 payments begin at one-twelfth monthly rate
- Six monthly payments issued July-December of first year
- Standard twelve-month cycle begins January of second year
- First reconciliation covers partial-year advances
Safe Harbor Transition¶
The $2,000 per child safe harbor applies immediately to the first reconciliation cycle. Recipients who receive advances based on prior-year data but experience changed circumstances benefit from the safe harbor in their first SOCA filing.
Child Security Contribution Phase-In¶
The contribution takes effect immediately at the full 1.50% base rate and 3.00% kicker rate -- no phase-in period. This ensures the Family Security Stabilization Account receives full funding from launch.
Timing Coordination: - Contribution effective: Tax years beginning after December 31 of enactment year - First collection: April 15 following first applicable tax year (estimated payments may begin earlier) - First full-year revenue: Approximately 15 months post-enactment
Account Funding Gap: A gap exists between benefit payments (beginning Month 12-18) and contribution revenue (significant inflows beginning approximately Month 15). Options to address:
- Initial capitalization through general fund transfer, repaid from future contribution revenue
- Delayed benefit commencement until Account reaches reserve threshold
- Treasury borrowing authority secured against future Account receipts
The statute authorizes reserve management but does not specify initial capitalization mechanism. This may require clarification in appropriations or technical corrections.
Interaction with 2021 Advance CTC Experience¶
SOCA builds on but does not directly continue the 2021 expanded child tax credit experience. Key differences:
| Element | 2021 Temporary Expansion | SOCA |
|---|---|---|
| Duration | One year (2021 only) | Permanent |
| Legal basis | American Rescue Plan temporary amendment | Permanent Section 24 amendment |
| Funding | General revenue | Child Security Contribution |
| Phase-out | Income-based phase-out | None -- universal benefit |
| Systems | Improvised from existing infrastructure | Purpose-built systems |
| Non-filer portal | GetCTC.org (third-party with IRS cooperation) | IRS-operated permanent portal |
IRS retains institutional knowledge and some technical infrastructure from 2021, which may accelerate development. However, SOCA requires new systems for the Birth Support Payment, Child Security Contribution collection, and solvency management that did not exist in 2021.
Contingencies and Flexibility¶
Regulatory Flexibility¶
The Secretary has discretion in several areas to adapt implementation to practical realities:
- Inflation indexing rounding rules
- Non-filer portal data elements and procedures
- Identity verification protocol calibration
- Healthcare provider scope for Birth Support verification
- Safe harbor criteria interpretation for "good faith" determinations
Implementation Date Flexibility¶
The statute uses "no later than" language for key deadlines, providing flexibility:
- Birth Support Payments: "no later than January 1 of the first calendar year beginning after enactment" -- earlier launch possible if systems ready
- Monthly CTC advances: "no later than July 1 of the first calendar year beginning after enactment" -- earlier launch possible
- Regulations: "within 180 days" -- could be completed faster
Graduated Implementation Provisions¶
Section 7(d) provides explicit contingency for funding shortfalls:
Trigger: Projected funding insufficient for full benefits
Response Options: 1. Graduated benefits at uniform percentage (minimum 50%) 2. Priority to monthly payment regularity over amount 3. Birth Support Payments protected at 100% until funding falls below 75% CTC threshold
Notice Requirement: 90 days advance notice to Congress and public
Restoration: Automatic return to full benefits when funding permits, with retroactive payments for prior 12 months of shortfalls
Automatic Rate Adjustment Mechanism¶
The solvency-triggered rate adjustment provides self-correcting contingency:
| Condition | Response | Timeline |
|---|---|---|
| Solvency ratio below 1.10 for 2 consecutive years | Base and kicker rates increase 0.05pp | January 1 following second year |
| Solvency ratio above 1.50 for 2 consecutive years | Base and kicker rates decrease 0.05pp | January 1 following second year |
| Ratio below 0.90 or above 2.00 for 2 years | Secretary reports to Congress | Within 60 days |
| Automatic adjustments hit bounds and ratio stays outside 1.10-1.50 for 3 years | Secretary recommends legislative changes | Within 60 days |
Bounds: Base rate 1.10-1.90%; kicker rate 2.20-3.80%
This mechanism handles moderate funding fluctuations automatically while flagging extraordinary circumstances for Congressional attention.
Potential Bottlenecks and Mitigations¶
| Bottleneck | Risk Level | Mitigation |
|---|---|---|
| IRS systems development capacity | Medium-High | Build on 2021 infrastructure; prioritize portal and payment systems |
| SSA birth data sharing agreement | Medium | Begin negotiations immediately; manual application backup exists |
| State vital records integration | Medium | Phased rollout by state; application-based backup |
| Non-filer outreach reach | High | Partner with existing programs (SNAP, WIC, Medicaid); community organization grants |
| Initial Account funding gap | Medium | Require technical corrections for initial capitalization if not addressed |
| Take-up among eligible non-filers | High | Aggressive outreach; simplified portal; in-person assistance |
Sunset Protection¶
Section 11(b) establishes explicit no-sunset provision. The Act remains permanent unless repealed by subsequent Act of Congress, preventing automatic expiration and the associated uncertainty that affected the 2021 temporary expansion.
Implementation Monitoring¶
Quarterly Reporting Requirements¶
The Secretary publishes quarterly reports on:
- Total enrollments (CTC and Birth Support Payment separately)
- Payments distributed
- Reconciliation outcomes
- Take-up rates by demographic group and geography
- Overpayment and improper payment rates with root-cause analysis
- Time-to-payment metrics
- Portal usability metrics
- Account deposits and outlays (separately by benefit type)
- Account balance and reserve status
- Solvency ratio and pending adjustments
Annual Congressional Reports¶
The Secretary, with HHS and Census, submits annual reports on:
- Child poverty rates
- Food insufficiency measures
- Take-up rates (separately by program component)
- Payment integrity metrics
- Child Security Contribution revenues and projections
- Solvency outlook
GAO Triennial Reviews¶
Every three years, the Comptroller General reports on:
- Program efficacy against stated objectives
- Payment integrity and error rates
- Administrative burden on recipients
- Automatic rate adjustment mechanism performance
- Recommendations for legislative or administrative improvements
Extended Graduated Implementation Review¶
If graduated implementation under Section 7(d) continues for more than 24 consecutive months, the Comptroller General conducts a comprehensive review of Child Security Contribution rates and recommends legislative solutions.
Revision History¶
Revision 2.5 (Current) - Brought into compliance with APAI Document Production Standards Rev 1.6 - Updated header structure, footer, and revision history placement
Revision 2.4 - Updated to reflect elimination of income-based phase-out, recalibrated contribution rates, and universal benefit design - Simplified transition provisions (no phase-out thresholds to transition) - Renamed from "Implementation Architecture" to "Implementation Timeline" per APAI Document Production Standards
Revision 2.0 - Initial publication
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Prepared by Albert Ramos for The American Policy Architecture Institute