Service providers occasionally ask whether they can use the Multistate Employer Option for New Hire Reporting.  From the service provider’s perspective, this would simplify their reporting obligations; in some cases making it unnecessary to collect additional data required by certain states.

The answer is generally no.  If a client is already registered in the Multistate Employer Registry or specifically wishes to do so, a service provider may report all of that client’s employees to any one state in which that client has employees.  However, this is a client-by-client question, and a service provider cannot report a client’s employees to a state in which the employer does not have employees.  Service providers cannot unilaterally elect to use the Multistate Employer Reporting system for all clients.

Reporting for New Hires through the Multistate Employer system is intended to facilitate compliance for multistate employers, not service providers, and new hire reports that are directed to the Multistate system through a single state may cause delays in child support orders, adversely affecting families.

For details, see Q&A 26 – 30 of the FAQs on the subject:

https://www.acf.hhs.gov/css/resource/new-hire-reporting-answers-to-employer-questions