The father appeals the denial of his New Jersey motion for retroactive modification of child support. Agreeing with the trial court that work-related child care expenses should be treated as child support for purposes of applying the prohibition in N.J.S.A. 2A:17-23a against retroactive reduction of child support, the Appellate Division affirms the decision to apply the reduction in child support as of the date of plaintiff's motion, not retroactively to the date the child began school. Cushman v. Losasso, New Jersey App. Div., September 24, 2009