Baker, J.
Sherry Barrand (Mother) filed a petition to establish child support from Gary Martin (Father) for their child, M.S.M. (Child). The trial court ordered Father to pay an amount to which the parties had purportedly agreed. Father filed a motion to correct errors because the amount he was ordered to pay did not account for the Social Security retirement (SSR) benefits Child was already receiving based on Father’s retirement. The trial court granted Father’s motion in part, reducing the amount of Father’s child support obligation. Mother now appeals, arguing that the trial court erred by disregarding the parties’ purported agreement and by ordering an incorrect effective date for the child support obligation. Finding no error, we affirm.
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Before reaching the substance of this appeal, we are inclined to discuss the effect of Social Security benefits on child support obligations. The Indiana Child Support Guidelines distinguish between SSR benefits and disability benefits: a trial court may use its discretion to credit SSR benefits to a noncustodial parent’s child support obligation, while disability benefits must be applied as a credit…Ind. Child Support Guideline 3G(5).
Our Supreme Court has provided that
in those situations where the trial court concludes that it is appropriate to give a Social Security recipient parent credit for Social Security benefits paid directly to a child, the trial court should in fact include the amount of the benefits in the recipient parent’s adjusted income for purposes of calculating the parents’ relative share of the total child support obligation.
Stultz v. Stultz, 659 N.E.2d 125, 126 n.2 (Ind. 1995) (holding that non-custodial parent was not entitled to offset child support obligation by the amount of SSR benefits paid directly to his children as a result of his retirement). Our Supreme Court later fully endorsed a flexible methodology that allows a trial court to use its discretion when crediting a non-custodial parent’s child support obligation. As the Court explained:
We recognize that determination of how to apply a child’s receipt of Social Security Retirement benefits in a child support order can be complicated, and present challenges to a trial court—and not applying those benefits poses the risk that the trial court may fashion a child support order under which the children of divorcing parents enjoy a standard of living much greater than that which they enjoyed pre-dissolution. . . .
And we likewise agree—and our Child Support Guidelines now reflect—that a mechanical application of the trial court methodology in Stultz (i.e., a strict denial of credit) would be improper, and the opinion should be applied to provide for the exercise of the trial court’s discretion. Utilizing such a methodology will promote the aims of the Support Guidelines, will treat similarly situated families the same, and will provide for children receiving the same degree of support post-dissolution that they had when their parents’ marriage was intact.
Johnson v. Johnson, 999 N.E.2d 56, 62 (Ind. 2013) (quotation marks and citations omitted).
In the instant case, the trial court, having considered several ways in which the SSR benefits could have an impact on Father’s child support obligation, ultimately followed the flexible methodology endorsed in Johnson and reflected in the Child Support Guidelines. We urge all trial courts faced with this issue to also carefully consider the possible impact of SSR benefits when determining whether to provide a credit to a non-custodial parent for his or her child support obligation.
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The judgment of the trial court is affirmed.
May, J., and Tavitas, J., concur.