Burcham v. Burcham (Nebraska 2016)

An adoption subsidy should not be counted as income to a parent when calculating child support. In this case, the parents received a monthly subsidy for three adopted special needs children. The subsidy was meant to supplement the parents’ incomes and assist with the extra costs that come with raising special needs children. Since it was not meant as an income substitute, it could not be counted as income for child support purposes. The subsidy cannot be used to offset the obligation. An offset would also defeat the purpose of the subsidy as a supplement.