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In October, the Administration for Children and Families (ACF) released a Notice of Proposed Rulemaking (NPRM) that outlined substantial changes to the Temporary Assistance for Needy Families (TANF) program.

At America Forward, we remain concerned about persistent inequities and ineffectiveness stemming from the design and implementation of the current TANF program – issues that were raised by several bipartisan witnesses during a recent hearing before the House Ways and Means Committee. TANF provides block grant funding to states to serve several purposes. According to ACF, “The Temporary Assistance for Needy Families (TANF) program provides states and territories with flexibility in operating programs designed to help low-income families with children achieve economic self-sufficiency.  States use TANF to fund monthly cash assistance payments to low-income families with children, as well as a wide range of services.” Authorized in 1996, TANF replaced the prior Aid for Families with Dependent Children (AFDC) program and provided states with broad flexibility for use of funds while imposing new requirements on participants, including more stringent work requirements. Today TANF accounts for about $16 billion in federal funding, alongside about $10 billion in required, complementary state spending. 

The recent NPRM represents the most significant rulemaking on TANF in a decade, including several reforms we believe could strengthen implementation within the current statutory limits. This NRPM follows changes to the TANF statute in the debt ceiling deal earlier this year. Those legislative changes included two promising provisions: expanded data reporting on TANF participant outcomes, and a new pilot testing outcomes-based accountability that could improve on the existing work requirements regime.

Together with America Forward Coalition members Big Thought, LIFT, Social Finance Inc., Third Sector Capital Partners, and UpTogether, America Forward submitted comments to ACF in response to the recent NPRM, highlighting key priorities to ensure that TANF functions effectively and reaches those in greatest need. 

• Appropriately define key terms, including “needy” and “family.” We supported ACF’s proposal to define “needy” as families earning up to 200 percent of the federal poverty guidelines, so as to effectively target benefits without creating a “cliff” or disincentivizing higher earnings for families working their way out of poverty. And we advocated for a revised definition of “family” in the statute, in order to address state-level policies that artificially limit benefits for participants. 
• Determining when an expenditure is ‘‘reasonably calculated to accomplish a TANF purpose.” We appreciate ACF’s intent to shift TANF funds to more appropriate expenditures that support families with low incomes. As part of efforts to ensure that TANF funding is used effectively to support families in need, we urge policymakers to adopt an evidence and evaluation framework that: 

1. 1. Reflects the need for innovation to identify and scale effective new approaches to family support; 
   2. Adopts culturally competent evaluation methods that are meaningfully connected to the lives experiences of the communities and individual families involved; and, 
   3. Supports continuous improvement efforts that enable program customization based on place, people, and circumstance. 

And we encourage policymakers to explicitly recognize that “tuition assistance and other education and training supports” that “specifically support the economic advancement of parents with low incomes” can meet TANF’s purposes, because such need-based financial assistance has clearly shown positive impact on the economic wellbeing of families. 

• Exclude third-party, nongovernmental spending as allowable maintenance of effort spending. America Forward Coalition organizations provide TANF-related services across the nation – both in partnership with State and local governments and through private funding – and we agree with ACF’s reasons for this change and don’t foresee any impact on partnerships.

This NPRM represents a vital opportunity to strengthen TANF and ensure that billions in critical assistance is reaching families in need across the country. Collectively, America Forward and our partners in the America Forward Coalition have decades of experience engaging with TANF and supporting the families it’s intended to help. We believe that, by embracing the recommendations above, policymakers can help ensure TANF’s effectiveness, sustainability, and positive impact for the long term.