Utah’s child support statutes—now consolidated under Title 81, Chapter 6 of the Utah Code use the term “verification” repeatedly when describing a parent’s duties to provide proof of child health insurance coverage and the costs of that coverage, uninsured medical or dental expenses for children, and work-related child care costs.
Despite how often this term appears, many parents and even practitioners misunderstand what qualifies as adequate verification, when it must be provided, and the consequences for failing to provide it.
This post explains the statutory framework governing written verification in three contexts:
- proof of health insurance coverage;
- child medical and dental expenses that were uninsured and thus paid out of pocket; and
- proof of incurred work-related child care expenses.
1. Verification of Child Health Insurance Coverage
Utah Code § 81-6-208(10)(a) requires that:
“The parent maintaining health care coverage or insurance shall provide verification of coverage to the other parent … upon initial enrollment of the child, and after initial enrollment on or before January 2 of each calendar year.”
The statute does not define what constitutes “verification,” but the common practice, and what courts expect, includes documents such as:
- a copy of the insurance card showing the child’s name;
- an employer or insurer’s enrollment confirmation;
- a benefit eligibility summary listing the covered dependents; or
- an annual open-enrollment confirmation statement.
2. Notice of Insurance Changes
Under § 81-6-208(10)(b), a parent must also notify the other parent within 30 days of learning of:
- any change in insurance carrier,
- any change in premium, or
- any change in benefits.
3. Verification of Uninsured Medical and Dental Expenses
When a parent pays for uninsured or unreimbursed medical or dental expenses, Utah Code § 81-6-208(10)(c) provides:
“A parent who incurs medical expenses shall provide written verification of the cost and payment of medical expenses to the other parent within 30 days of payment.”
The statute identifies two written components: verification of cost and verification of payment.
4. Proof of Work-Related Child Care Expenses
Utah Code § 81-6-209 governs work-related child care costs. Section 81-6-209(2)(a) provides:
“If an actual expense for child care is incurred, a parent shall begin paying the parent’s share upon presentation of proof of the child care expense.”
Ongoing Duty to Provide Verification
Under § 81-6-209(2)(c)(i):
“In the absence of a court order to the contrary, a parent who incurs child care expense shall provide written verification of the cost and identity of a child care provider … upon initial engagement of a provider and thereafter on request of the other parent.”
And § 81-6-209(3) provides that “[t]he court may deny a parent incurring child care expenses the right to receive credit for the expenses or to recover the other parent’s share of the expenses if the parent incurring the expenses fails to comply with Subsection (2)(c).”
Proof, Notice, and Verification
Did you notice the differences between Utah Code § 81-6-208(10)(a) and (b) and § 81-6-208(10)(c) and § 81-6-209(2)(a) and (b)?
§ 81-6-208(10)(a) requires “verification of coverage” but does not define what form that verification must take.
§ 81-6-208(b) requires that a parent “notify” the other but does not define what form that notice must take.
§ 81-6-209(2)(a) provides that a parent is obligated to pay his/her share of work-related child care on a monthly basis “immediately upon presentation of proof of the child care expense,” but does not define what form that proof must take.
§ 81-6-208(10)(c) requires that a parent seeking reimbursement for the other parent’s half of child medical expenses paid “shall provide written verification of the cost and payment of medical expenses to the other parent within 30 days of payment.”
Finally, § 81-6-209(2)(c) provides that a parent who incurs child care expense must provide written verification of the cost and identity of a child care provider to the other parent.
Practical Best Practices for Providing Verification, Notice, and Proof
The statutes set the minimum requirements. Meeting those minimums in a consistent and well-documented manner is what prevents reimbursement disputes, contempt allegations, and unnecessary litigation. The following best practices reflect what I believe courts cannot reject when issues of compliance with §§ 81-6-208 and 81-6-209 arise.
Provide Third-Party Documentation, Not Self-Generated Claims
Whenever “verification,” “proof,” or even “notice” is required, parents should rely on documents generated by a third party—not merely a self-generated descriptions of what they assert to be true. Examples include insurance enrollment confirmations, explanations of benefits (EOBs), provider invoices, receipts showing payment, daycare billing statements, and payroll withholding summaries. These records are created by third parties (i.e., the insurance company, the employer, the child care provider) in the ordinary course of business and are therefore considered inherently more reliable than a parent’s personal assertions. Courts favor these—and must accept them as admissible evidence (See Utah Rules of Evidence 803(6))—because they were not created to advance either parent’s litigation position.
Supply Both Required Elements: Cost and Payment
Where the statute requires verification of both cost and payment—such as for a request for reimbursement of uninsured child medical or dental expenses—a parent should always transmit two documents: the bill showing the amount due, and the receipt, canceled check, or credit-card record showing that the amount was actually paid. Each document performs a different evidentiary function. A bill alone proves nothing about whether the expense was incurred; a receipt alone proves nothing about what service was purchased. Submitting both prevents disputes and establishes a clear reimbursement obligation.
Meet the Statutory Deadlines
Verification must be provided within the deadlines specified: annually by January 2 for insurance coverage; within 30 days for changes in insurance terms; within 30 days of payment for uninsured medical costs; and “upon presentation” or on request for child-care expenses. Parents who miss these deadlines can lose the right to reimbursement.[1] Timely notice ensures expenses are transparent, predictable, and not sprung on the other parent months retroactively.
Use Written, Time-Stamped Delivery
Verification, notice, and proof should always be sent in a form that can later be demonstrated to a court—email with attachments, a co-parenting app that preserves message logs, or text messages transmitting original documents. Verbal statements, hand-offs in parking lots, or “I told you last month” arguments create factual ambiguity that courts cannot reliably resolve. Time-stamped and verifiable written delivery protects both parents and creates an audit trail if reimbursement is contested.
Provide Complete Documents, Not Cropped Images
Full invoices, full receipts, and full insurance summaries should be provided. Partial screenshots, redacted portions that obscure context, multi-image fragments, or even vague/ambiguous documentation create confusion and open the door to disputes over authenticity or completeness. Courts expect to see the entire record, not excerpts.
Identify Child-Care Providers Clearly and Consistently
For work-related child-care expenses, the statute requires written verification of both the provider’s identity and the cost. Parents should supply the provider’s full legal name or business name, address, contact information, and tax ID when available, along with monthly invoices or billing statements.[2] These details establish that the expense is legitimate, ongoing, and tied to employment, as required by § 81-6-209.
Keep Explanations Brief, Factual, and Non-Argumentative
If context is needed (for example, identifying the purpose of a medical visit or explaining a one-time child-care charge), the explanation should be short and factual. Avoid argumentative narratives, editorializing, or custody commentary. Courts expect verification to be administrative, not adversarial, and they are quick to discount documentation buried inside accusations or emotional commentary.
Maintain an Organized Record-Keeping System
Parents should maintain digital files organized by year and category (insurance, medical, dental, child care). Courts heavily favor parents who can promptly produce well-maintained and complete records; likewise, courts grow impatient with parents who rely on disorganized screenshots or cannot produce proof when asked. Good record-keeping is not only a courtesy to the other parent, it is a pragmatic litigation safeguard.
Respond Promptly When Verification Is Received
When the other parent provides proper verification, the receiving parent should pay the owed share promptly or request clarification within a reasonable time. Delay without explanation often becomes evidence of noncooperation. Courts typically favor the parent who treats reimbursement obligations as routine administrative duties, not as opportunities for leverage.
Err on the Side of Over-Documenting, Not Under-Documenting
When unsure whether an expense has been sufficiently verified, parents should err on the side of supplying more documentation rather than less. No court has ever faulted a parent for providing too much third-party proof; many courts have denied reimbursement because the parent provided too little. When in doubt, attach the bill, the receipt, the explanation of benefits, and a brief note identifying the child and date of service.
Examples of Adequate Verification Under Utah Law
The statutory terms “verification,” “proof,” and “notice” are not self-defining. Utah courts generally look for documentation created in the ordinary course of business by the insurance company, medical/dental care provider, and work-related child care provider—records that are neutral, contemporaneous, and complete. The following examples illustrate the types of documents that reliably satisfy the verification requirements in §§ 81-6-208 and 81-6-209, as well as the preferred methods for transmitting them.
A. Health Insurance Coverage
The requirement to provide “verification of coverage” is ordinarily met through documents generated by the insurer or employer, such as:
- insurance cards listing the child as a covered dependent;
- enrollment confirmations issued by the insurer/employer during open enrollment;
- benefit eligibility summaries from the insurer/employer identifying the dependents; or
- insurer or employer letters confirming coverage changes.
The most reliable means of transmission are email (with PDFs attached), uploads to a co-parenting application that preserves a time-stamped log, or clear scans or downloads from the insurer’s portal. These methods provide a verifiable record of what was sent, when it was transmitted, and—if you request a read receipt (a request that the intended recipient did in fact receive it)—that it was received.
B. Notice of Insurance Changes
The duty to “notify” the other parent of changes in carrier, premium, or benefits can be met by forwarding the official notice received from the insurer or employer—whether a premium-change statement, open-enrollment announcement, or coverage-termination letter. Providing the full document rather than a cropped screenshot eliminates disputes about context or completeness. Email and co-parenting apps again provide a reliable transmission record.
C. Uninsured Medical and Dental Expenses
For reimbursement of uninsured medical or dental expenses, § 81-6-208(10)(c) requires written verification of both cost and payment. Courts expect to see:
- an invoice, bill, explanation of benefits, pharmacy receipt, or other provider-generated document showing the amount owed; and
- a receipt, canceled check, credit-card statement, or other proof demonstrating that the amount was actually paid.
Because these are two separate evidentiary components, providing both is essential. The most effective practice is to send a single email or PDF bundle containing the bill and the proof of payment within 30 days of payment, as the statute requires.
D. Work-Related Child Care Expenses
Proper “proof of the child care expense,” as required by § 81-6-209, typically includes:
- monthly daycare invoices or weekly billing statements identifying the child, dates of care, and charges;
- statements from in-home providers listing the provider’s full name, dates, rates, and total cost; and
- receipts or electronic payment confirmations showing that payment was made.
To satisfy the additional requirement of “written verification of the cost and identity of the child care provider,” parents should supply the provider’s legal name or business name, address, contact information, and tax ID number if available. As with medical expenses, a single PDF containing both the invoice and the payment record minimizes disputes and creates a clean evidentiary record.
E. Preferred Methods of Transmission
Across all categories, the most defensible approach is to provide verification in a form that is both complete and time-stamped:
- email with attachments and read receipts requested,
- uploads to a co-parenting platform with an immutable message log, or
- cloud-stored PDFs accessible to both parents.
These methods preserve a clear record of compliance. By contrast, verbal disclosures, informal statements (“I paid $40 today”), or texts without attached documents rarely satisfy the statutory requirements and are frequently rejected by courts.
Verification Done Right
Parents often treat proof, verification, and notice as casual tasks, but Utah’s statutes expect something far more precise. Proper documentation—complete, third-party records delivered on time and in writing—is what transforms a claim into an enforceable obligation. When parents follow these requirements consistently, disputes shrink, reimbursement becomes routine, and courts can resolve conflicts quickly and fairly. Clear, timely verification is not busywork; it is the backbone of how Utah law ensures transparency, accountability, and predictability in sharing child-related expenses.
Utah Family Law, LC | divorceutah.com | 801-466-9277
[1] Note: I have never, in 29 years of practice, ever seen a parent who provided verification/notice late be denied reimbursement. Perhaps that has happened, and I may even live to witness it myself, but I share this with you so that you know just how rarely—if ever—courts hold parents to the “give timely notice and verification or you may lose your rights to reimbursement.”
[2] It would also be wise to authorize the other parent to communicate and inquire with the child care provider directly.