Tavitas, J.

Case Summary

Michael DeGrado (“Father”) filed a petition to modify his child support payments to Kari DeGrado (“Mother”). The trial court granted Father’s petition but did not reduce Father’s child support obligations by as much as Father requested. The trial court also refused to consider the issue of the parents’ division of the children’s extracurricular expenses.

Father appeals and claims that the trial court erred by: (1) failing to consider Father’s claims regarding expenses for the children’s extracurricular activities; and (2) considering Father’s reimbursed out-of-pocket work-related expenses as part of Father’s income when determining Father’s child support obligation. We agree with Father that the trial court should have permitted him to present argument and evidence regarding the extracurricular expenses, but we conclude that Father has failed to establish clear error with regard to the issue of his reimbursed expenses. Accordingly, we affirm in part, reverse in part, and remand.

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The first issue we address is whether extracurricular expenses are considered “child support” for notice purposes in a petition to modify child support. In other words, is a parent who files a petition to modify child support required to specifically state all aspects of child support the parent seeks to modify? In addressing this question, we first look to the Child Support Guidelines. Extraordinary extracurricular expenses are specifically delineated in Child Support Guideline 8…

Thus, extracurricular expense payments are indeed child support. The parties here have previously agreed to pay for extracurricular expenses according to their child support percentages denoted on the child support worksheet; the trial court granted Father’s petition to modify child support which modified the child support income percentages for each parent. We have no difficulty finding that these extracurricular expenses, which had been previously agreed upon and approved by the court, are indeed child support.

II. Father’s petition to modify his child support put Mother on notice that the extracurricular expenses were at issue.

Father argues that the trial court erred by preventing him from presenting evidence and argument on the children’s extracurricular wrestling expenses. Mother argued, and the trial court agreed, that this issue was beyond the scope of Father’s petition to modify child support. [Footnote omitted.] We disagree.

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Here, the parties had previously agreed to pay extracurricular expenses according to their child support income percentages. [Footnote omitted.] Father subsequently filed a petition to modify his child support obligation. Given the interrelated nature of Father’s child support obligation and the parties’ corresponding share of extracurricular expenses, Mother was put on sufficient notice of this interrelated issue of extracurricular expenses based upon the parties’ prior agreements.

Child support determinations and modifications are not meant to be considered in a vacuum, with one portion of child support considered at one hearing and related portions of child support at another hearing. Nor do we believe that family law practitioners read the Child Support Guidelines as separate sections, requiring piecemeal litigation. Such piecemeal litigations breed inefficiency, costly litigation, and costly appeals. Rather, the Child Support Guidelines should be read as a whole.

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The same is true here. The allegations in Father’s petition to modify child support were sufficient to raise the interrelated issue of the parents’ respective share of extracurricular expenses. Put differently, the issue of the parents’ share of extracurricular expenses, which are a form child support, was part of the broader issue of child support raised in Father’s petition to modify. The trial court erred by concluding otherwise and forbidding Father from presenting evidence and argument on the issue extracurricular expenses. [Footnote omitted.] We therefore reverse the trial court’s judgment to the extent that it refused to consider this issue and remand with instructions that the trial court consider the issue of the parents’ share of extracurricular expenses.

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Conclusion

The trial court abused its discretion by forbidding Father from presenting evidence and argument on the issue of the parties’ division of extracurricular expenses. Father, however, has failed to show that the trial court clearly erred by including Father’s employer-reimbursed expenses in his income when calculating Father’s child support obligation. Accordingly, we affirm in part, reverse in part, and remand.

Affirmed in part, reversed in part, and remanded.

Crone, J., and Bradford, J., concur.