In Hinckley v. Hinckley, 812 P.2d 907 (Wyo. 1991), the Court considered a case where the children began receiving social security benefits because their father was granted social security disability after a divorce. When discussing the issue of that case the Court noted: "The question is whether we should allow the obligor to unilaterally apply Social Security benefits that are received by his children to fulfill his obligation." Id., at 911. After acknowledging that a number of courts allowed a credit to the non-custodial parent for social security benefits paid to the children, we adopted the rule that "the receipt of payments from Social Security by the children of one obligated to pay child support may constitute a change of circumstances giving rise to justification for a petition for modification of the decree." Id. at 911. The Court then held that those benefits are one factor to be considered by the district court in determining whether a material change of circumstances has occurred, but that other changes must also be considered. Id. The primary message of our decision, however, was that the obligor must petition the court for modification instead of unilaterally reducing his payment. Id. at 912 The Court recognized that when determining child support, a court must consider social security benefits received by the child as a factor. Id. at 912. However, the Court did not dictate how a district court must account for these payments and seemed to largely leave it as a matter of district court discretion.