Parents can use the child maintenance system to continue to abuse their former partners, for example by withholding payments or access to children. Written evidence from Gingerbread and the Domestic Abuse Commissioner set out that, for survivors of domestic abuse, the CMS may be the safest and only way to secure maintenance from their ex-partner.34 However, although vulnerable and low-income families, those with disabilities, and those with higher levels of parental conflict are more likely to have no arrangement in place, the Department knows little about separated parents without any form of arrangement.35 It does not know how many cases there are in which domestic abuse or coercive control may be a barrier to setting up and maintaining an effective child maintenance arrangement. The Department’s legislation is designed to encourage parents who do use the CMS to use Direct Pay first to encourage collaboration.36 The Domestic Abuse Commissioner told us that it “would encourage caution in any efforts by the CMS to encourage collaboration between receiving and paying parents. It is vital that an emphasis 27 C&AG’s report, para 3.7 28 Qq 129, 131 29 Qq 129–131; C&AG’s Report, paras 3.7, 3.9 30 Qq 128, 131 31 C&AG’s Report, para 1.19 32 CMS 0044, written evidence submitted by the Domestic Abuse Commissioner, 22 March 2022. 33 Department for Work & Pensions, National Tables Child Maintenance Service Statistics data to September 2021, Table 2 34 CMS 0042, written evidence submitted by Gingerbread, 22 March 2022; CMS 0044 35 Q42; C&AG’s Report, paras 1.22, 1.24, 2.11 and 2.13 36 C&AG’s Report, paras 2.9–2.12 Child Maintenance 17 on collaboration does not lead to CMS staff failing to hear concerns from victims and survivors about the risks the perpetrator poses to them and their children.”37 It further cautioned that Direct Pay arrangements can increase the harm and risk to victims of domestic abuse because they have to ask the perpetrator directly for payments.38