In In the Matter of Tompkins County Support Collection Unit v. Chamberlin (99 N.Y.2d 328 [2003]) the Court of Appeals held that the Family Court Act, section 413-a, authorized the Family Court to review and adjust the underlying support order in accordance with the standards set forth in section 413 of the Family Court Act, not merely to decide whether or not the COLA amount should be applied. Section 413, of course, contains the child support standards act guidelines and establishes the procedures for determining an initial child support amount. The primary questions raised in Chamberlin was whether a party could request a modification of the support order in excess of the COLA could be requested through the 413-a objection process, even though there was no "change of circumstances" under the law otherwise applicable. The Court of Appeals said "yes." As explained in Chamberlin, the Personal Responsibility and Work Opportunity Reconciliation Act of 1996, or "PRWORA" (42 USC 651-669), is the Federal basis for New York's Family Court Act, section 413-a. PRWORA provided the states with three options for reviewing and adjusting child support orders at least every three years, and the State of New York chose the second option-i.e., the application of a cost of living adjustment (COLA) to the existing order. Having so chosen, New York was statutorily required to establish "procedures which permit either party to contest the adjustment . . . by making a request for review and, if appropriate, adjustment of the order in accordance with the child support guidelines established pursuant to section 667(a) of this title (42 USC 666[a][10][A)(ii))" (Chamberlin, p 333). The Family Court Act, ( 413-a[3][c]) provides that such adjustments can be made without first proving a change in circumstances. Clearly, increasing child support by more than the COLA amount when the paying parent has the ability to pay more would normally be in the children's best interests, and as a matter of public policy allowing such an increase makes common sense. Not surprisingly, mandatory periodic review requirements "were enacted to ensure the adequacy of child support orders (see 57 Fed Reg 61559, 61560 [1992])." (Chamberlin, supra, at p 334.)