The Children’s Home Society of America (CHSA) advocated for flexible TANF fund usage in their comment letter to the Administration on Children and Families (ACF), emphasizing the need to prevent families from entering the child welfare system due to insufficient resources. CHSA contributed as one of over 7,100 comments and signed on to the National Child Abuse Coalition’s (NCAC) letter. The deadline for comments was December 1, 2023.

Issued on September 28, 2023, the ACF’s Notice of Proposed Rulemaking (NPRM) aims to ensure that TANF funds comply with statutory requirements, reduce administrative burdens, and enhance program effectiveness. CHSA comments focus on the proposals that would give states the flexibility and guidance necessary to achieve TANF’s four primary goals. Of particular note is TANF’s first goal: “to provide assistance to needy families so children can receive care in their own homes or with relatives.” CHSA also endorses efforts to ensure that state agencies and governments use TANF funds for their designated purposes.

CHSA responded to the ACF’s proposal limiting the “needy” designation to no more than 200 percent of the federal poverty guidelines by proposing a more flexible definition. This flexibility would prevent negative outcomes like benefit cliffs and the exclusion of kinship caregivers and families at risk of child welfare involvement due to neglect. CHSA also recommended that the final definition account for geographic income variations and local living costs, offering families facing financial upheavals support without the obstacle of strict income criteria.

Furthermore, CHSA suggested raising the minimum cash assistance percentage, highlighted the need for kinship caregivers to access TANF, and requested clearer rules defining expenditures that are “reasonably calculated to accomplish a TANF purpose,” especially those preventing child welfare involvement.

CHSA remains committed to monitoring and reporting on the final regulations the ACF will establish.