Poverty & Safety Net
Article

Strengthening Temporary Assistance for Needy Families (TANF) as a Safety Net and Work Program

January 5, 2024
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

Director Flagg,

The Center for Community Solutions thanks the Administration for Children and Families for the close review of regulations for the Temporary Assistance for Needy Families (TANF) program with the goal of refocusing on those families most in need. By and large, we think that these proposed changes will move the program in a positive direction, but ultimately a comprehensive overhaul of TANF will be needed to see marked change.

Our comments will be focused on the first three proposed changes:

Proposed change #1, “establish a ceiling on the term “needy””

We support this change. Capping the definition of “needy” at 200 percent of the federal poverty level aligns with our general understanding of the focus of TANF. The expectation that those who provide services using TANF dollars focus on families living below 200% FPL is reasonable. Our hope with this rule change is that there is continued engagement from ACF with states to explore the programs that they are supporting with TANF dollars and assess the value they provide to needy families. Ultimately, only effective programs that are truly assisting families should continue to be supported.

Proposed change #2, “clarify when an expenditure is “reasonably calculated to accomplish a TANF purpose”

This is an important change for TANF but must be carefully implemented. There are certainly programs currently supported with TANF dollars that are providing impactful services and support to families that may not immediately show themselves to be aligned with a TANF purpose or perhaps have aligned themselves with one purpose but should be aligned with another. States should be given sufficient time and support from ACF to engage with TANF fund recipients and for those that are clearly helping low-income families, help them walk through the process of showing their connections to TANF and its purposes.

In Ohio, we have seen scrambles for TANF dollars through the state’s biennial budget process. While many of the recipients of these TANF dollars are certainly doing TANF-aligned work, we do not have much insight into the actual accounting or use of these funds. Support from ACF to the states and TANF funded agencies would be helpful in better understanding the programming that is supported with TANF dollars.

Proposed change #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”

We understand the impetus for this change, and while we know that Ohio is not at much risk if this shift occurs, we do foresee some issues that should be explored. For states that count a significant amount of third-party contributions toward MOE, does ACF expect that these states will be able to easily make up this gap with state dollars? And ultimately, we want states to continue to invest in programs that support families who are low-income, is this the way to encourage that? Or will we just see shuffling around of existing state dollars? At a minimum, we recommend a long off-ramp for this change, if it is to go into effect, to allow time for states to adjust.

In Ohio, allowing the ability for third-party MOE has created strong and enduring partnerships with organizations that are committed to helping Ohio families who are struggling. While we recognize this may not be the case in other states, the opportunity for the state to partner with third parties has strengthened Ohio’s ability to provide meaningful services to low-income families.

Overall, we are always appreciative for a chance to explore making improvements to the TANF program. It is something our organization has spent significant time with, including making recommendations for improvement. The desire through these proposed rules to refocus the program and support more families is positive. We strive to move this program from one of box-checking and barely reaching any families to a program that brings impactful investments to families and communities.

Thank you,

Tara Britton
Director of Public Policy and Advocacy
The Center for Community Solutions

RE: Docket ID number 2023-21169, RIN 0970-AC97

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