| From its original promulgation UIFSA determined that the |
| duration of child-support obligation should be fixed by the |
| controlling order, see Robdau v. Commonwealth, Virginia Dept. |
| Social Serv., 543 S.E.2d 602 (Va. App. 2001). If the language |
| was insufficiently specific before the 2001, the amendments |
| should make this decision absolutely clear. The original time |
| frame for support is not modifiable unless the law of the |
| issuing State provides for modification of its duration. Some |
| courts have sought to subvert this policy by holding that |
| completion of the obligation to support a child through age 18 |
| established by the now-completed controlling order does not |
| preclude the imposition of a new obligation thereafter to |
| support the child through age 21 or even to age 23 if the |
| child is enrolled in higher education. Subsection (d) is |
| designed to eliminate these attempts to create multiple, |
| albeit successive, support obligations. Consistent with this |
| principle, if a domestic violence protective order has been |
| entered with a child-support provision that has a duration |
| less than the general child support law of the State that |
| issues the controlling order, the law of that State determines |
| the maximum duration. In sum, absent tribunal error the first |
| child-support order issued under UIFSA will invariably be the |
| initial controlling order. The initial controlling order may |
| be modified and replaced by a new controlling order in |
| accordance with the terms of Sections 609-615, but the |
| duration of the child-support obligation remains constant, |
| even though virtually every other aspect of the original order |
| may be changed. This is also the standard in situations |
| involving multiple valid child-support orders--a problem that |
| will progressively decrease over time as RURESA multiple |
| orders expire or a determination of the initial controlling |
| order is made under Section 207, supra. Once a controlling |
| order is identified under these standards, the duration of the |
| support obligation is fixed. |
