Poverty & Safety Net
Article

Comments on proposed TANF regulations due December 1

November 13, 2023
Read time:
Download Fact Sheets
Register now
Share this resource
Subscribe to our Newsletter
By subscribing you agree to with our Privacy Policy.
Thank you! Your submission has been received!
Oops! Something went wrong while submitting the form.
Download this as a PDF

Perhaps one of the wonkiest activities as a nonpartisan think tank is submitting comments in the rulemaking process, both at the state and federal levels. Right now, there is an opportunity to comment on some significant changes proposed for the federal Temporary Assistance for Needy Families (TANF) program. Last month, the Administration for Children and Families (ACF) within the Department of Health and Human Services, issued a notice of proposed rulemaking (NPRM) related to TANF in the Federal Register. Comments on the proposed changes are due December 1, 2023.

Right now, there is an opportunity to comment on some significant changes proposed for the federal Temporary Assistance for Needy Families (TANF) program.

Funding for the Temporary Assistance for Needy Families has remained unchanged since 1996  

The TANF program has been largely unchanged since it was established under President Bill Clinton in 1996, with some adjustments in the early 2000s under President George W. Bush. Namely, the funding levels for TANF, which is funded by the federal government as a block grant, have remained stagnant since its inception and the program is now worth 50 percent less than it was in 1996. States must contribute a maintenance of effort (MOE), which is comprised of both state dollars and dollars spent and services provided by third-party partners who support families living in poverty, food banks for example. And this brings us to one of the proposed changes to the TANF rules…disallowing counting of third-party contributions toward MOE. This shift away from third-party MOE could impact contributions to Ohio’s MOE and that of other states.

Seven proposed changes to the TANF rules

These proposed changes were captured directly from the notice of proposed rulemaking, NPRM.

  1. Establish a ceiling on the term “needy”
  2. Clarify when an expenditure is “reasonably calculated to accomplish a TANF purpose”
  3. Exclude as an allowable TANF maintenance-of-effort (MOE) expenditures cash donations from non-governmental third parties and the value of third-party in-kind contributions
  4. Ensure that excused holidays match the number of federal holidays, following the recognition of Juneteenth as a federal holiday
  5. Develop new criteria to allow states to use alternative Income and Eligibility Verification System (IEVS) measures
  6. Clarify the “significant progress” criteria following a work participation rate corrective compliance plan
  7. Clarify the existing regulatory text about the allowability of costs associated with disseminating program information

There is a thorough description in the federal register of ACF’s reasoning for these particular proposed changes. In a nutshell, ACF cites a general underinvestment by states in “work, education and training for parents with low incomes as well as critical work supports.” In addition, ACF states “instead of a focus on cash assistance, work, and critical work supports like childcare, states are spending TANF and MOE funds on a wide range of benefits and services, including some with tenuous connections to a TANF purpose and, in some instances, providing supports for families with incomes up to 400 percent of the federal poverty guidelines.”

The Administration for Children and Families (ACF) cites a general underinvestment by states in “work, education and training for parents with low incomes as well as critical work supports.”

Under TANF, each state developed its own detailed program. We have written extensively about Ohio’s program, including more recently based on the current state budget and in the spring during the federal budget deliberations. These resources can offer more insight into Ohio’s TANF program, but each state’s program looks different and ACF’s general description of the current issues applies differently to each state. Each state will be impacted differently if these changes were to go into effect, some significantly, others less so.

Comments on the TANF proposed changes are due December 1, 2023

These can be submitted electronically, and the instructions are included below:

  • Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for submitting comments.
  • Email comments to: TANFquestions@acf.hhs.gov.
  • Instructions: All submissions received must include the agency name and docket number (2023-21169) or RIN (0970–AC79) for this rulemaking. All comments received will be posted without change to https://www.regulations.gov, including any personal information provided.

We will have more to say soon about this in the comments we’re developing. Right now, we hope to raise awareness of the opportunity for comments to be submitted. Wondering how others are weighing in? Read the comments here.

Download Fact Sheets

Lake County

Download

Geauga County

Download

Cuyahoga County

Download

All Municipalities Geauga County

Download

All Municipalities Lake County

Download

All Municipalities Cuyahoga County

Download

Thompson

Download

South Russell

Download

Russell

Download

Parkman

Download

Newbury

Download

Munson

Download

Montville

Download

Middlefield Township

Download

Middlefield Village

Download

Huntsburg

Download

Hambden

Download

Claridon

Download

Chester

Download

Chardon Township

Download

Chardon City

Download

Burton

Download

Bainbridge

Download

Auburn

Download

Willowick

Download

Willoughby Hills

Download

Willoughby

Download

Wickliffe

Download

Waite Hill

Download

Timberlake

Download

Painesville City

Download

Mentor-on-the-Lake

Download

Mentor

Download

Madison

Download

Lakeline

Download

Kirtland Hills

Download

Kirtland

Download

Eastlake

Download

Concord

Download

Highland Heights 2018

Download

Garfield Heights 2018

Download

Fairview Park 2018

Download

Euclid 2018

Download

East Cleveland 2018

Download

Cleveland 2018

Download

Cleveland Heights 2018

Download

Cities in Cuyahoga County Combined 2018

Download

Brooklyn 2018

Download

Brook Park 2018

Download

Broadview Heights 2018

Download

Brecksville 2018

Download

Berea 2018

Download

Bedford 2018

Download

Bedford Heights 2018

Download

Beachwood 2018

Download

Bay Village 2018

Download

Westlake 2018

Download

Warrensville Heights 2018

Download

University Heights 2018

Download

Strongsville 2018

Download

South Euclid 2018

Download

Solon 2018

Download

Shaker Heights 2018

Download

Seven Hills 2018

Download

Rocky River 2018

Download

Richmond Heights 2018

Download

Pepper Pike 2018

Download

Parma 2018

Download

Parma Heights 2018

Download

Olmsted Falls 2018

Download

North Royalton 2018

Download

North Olmsted 2018

Download

Middleburg Heights 2018

Download

Mayfield Heights 2018

Download

Maple Heights 2018

Download

Lyndhurst 2018

Download

Lakewood 2018

Download

Independence 2018

Download

Woodmere

Download

Westlake

Download

Warrensville Heights

Download

Walton Hills

Download

Valley View

Download

University Heights

Download

Strongsville

Download

South Euclid

Download

Shaker Heights

Download

Seven Hills

Download

Rocky River

Download

Richmond Heights

Download

Pepper Pike

Download

Parma Heights

Download

Orange

Download

Olmsted Falls

Download

Olmsted

Download
Thank you! Your submission has been received!
Oops! Something went wrong while submitting the form.
Download report

Subscribe to our newsletter

5 Things you need to know arrives on Mondays with the latest articles, events, and advocacy developments in Ohio

Explore the fact sheets

Lorem ipsum dolor sit amet, consectetur adipiscing elit. Suspendisse varius enim in eros elementum tristique.

No Related Fact Sheets

Explore Topics

Browse articles, research, and testimony.

Poverty & Safety Net
Article

Barriers and access to resources in the Union-Miles Neighborhood 

Tamikka James-Haygood
November 24, 2024
Poverty & Safety Net
Article

ARPA 3 Years later: Lessons learned in Ohio

Dylan Armstrong
November 18, 2024
Poverty & Safety Net
Article

New Human Services Chamber launching in December

Emily Campbell
November 17, 2024
Poverty & Safety Net
Article

U.S. Census to halt publication of state-level hardship data

John R. Corlett
November 11, 2024