TANF and Work Supports

 

CLASP actively comments on federal regulations and guidance regarding the TANF program and other income and work supports, and provides analyses and summaries for state policymakers and advocates.

TANF

The February 2012 extension of TANF requires states to develop policies to restrict access to TANF assistance from ATMs and point of sale devices in certain locations. In June 2012, CLASP responded to HHS' request for comments on how to implement this provision. In April 2016, the Administration for Children and Families (ACF) at the U.S. Department of Health and Human Services issued a “program instruction” to state agencies operating Temporary Assistance for Needy Families (TANF) programs, providing first-ever guidance on the importance of ensuring free or low-cost access to benefits.

CLASP submitted comments in support of the proposed changes to TANF Financial Data reporting including the new proposed ACF- 196R form and related instructions which took effect in the most recent release of 2015 data. CLASP highlighted how the new reporting categories and expenditure reporting requirements would significantly enhance our understanding of the ways that TANF and state funds claimed toward the TANF maintenance of effort requirement are actually being used and increase accountability for use of funds.

For information on the regulations and guidance issued by HHS to implement the TANF components of the American Recovery and Reinvestment Act, see the TANF ARRA page.

SNAP 

In July 2016, CLASP responded to the U.S. Department of Agriculture Food and Nutrition Service’s request for information on SNAP data exchange standardization. CLASP outlined several major principles to consider when developing regulations regarding data exchange standardization. CLASP recommended protections for clients when data matches are erroneous and suggested flexibility for future opportunities for innovation and improvements.

In May 2016, CLASP responded to the USDA Food and Nutrition Service for the proposed rule on enhancing retailer standards in SNAP. CLASP expressed support for proposed rule provisions implementing the 2014 Farm Bill mandate and noted concerns about changes to other provisions that exceed the mandate, which could undercut food access for low-income consumers.

CLASP submitted comments in April 2016 on the SNAP Employment and Training reporting measures interim rule.  Recommendations include additional measures that are critical to understanding the full effects of E&T programs, as well as technical comments on the measures included in the interim rule.

In March 2016, CLASP submitted comments to the USDA Food and Nutrition Service in response to a request for public comment on proposed SNAP photo EBT card implementation requirements. CLASP does not support the implementation of photo EBT cards, but recognizes the importance of providing clear procedures and parameters for states wishing to do so. CLASP outlined recommendations on minimum requirements, voluntary vs. mandatory implementation, issuance procedures, card access and usage, and the implementation plan.   

Child Support

In January 2015, CLASP replied to the Administration for Children and Families, Office of Child Support Enforcement’s request for comments on the Notice of Proposed Rulemaking on flexibility, efficiency, and modernization in the Child Support Enforcement program. CLASP is encouraged by the efforts to modernize the program to better serve families. In addition to several other proposed rule changes, CLASP strongly supports the provision to allow IV-D funds to be used for job services for non-custodial parents, and urge OCSE to encourage states to partner with their workforce and adult education systems to implement these services effectively.

Health Insurance

In July 2015, CLASP submitted comments to the Department of Health and Human Services, Centers for Medicare & Medicaid Services in support of the proposed rule to permanently extend enhanced federal financing of state Medicaid eligibility and enrollment systems.

CLASP commented on the Mental Health Parity and Addiction Equity Act of 2008 and the Application to Medicaid Managed Care, CHIP and Alternative Benefit Plans in June 2015. CLASP highlighted the crucial role that access to mental health and substance abuse treatment plays for low-income individuals and families, including low-income mothers with depression and for parents involved with the child welfare system who need access to behavioral and substance use treatment. And, CLASP strongly urged CMS to maintain the strength of the protections for access in the final rule.

In August 2012, CLASP submitted comments to CMS on proposed data collection for the single, streamlined application mandated in the Affordable Care Act.

CLASP is a member of the steering committee of the Coalition for Access and Opportunity.  In October 2010, the Coalition commented on the planning and establishment of the health care exchanges to be created under the Affordable Care Act. The implementation of these exchanges is a critical component of meeting the Affordable Care Act's goals of universal health care coverage and "no wrong door" for access to benefits. 

In July 2010, CLASP sent this letter to the Affordable Care Act Enrollment Workgroup, recommending the use of health care reform as a platform for benefits access.

Cross-Cutting

CLASP submitted comments to the U.S. Citizenship and Immigration Services in the Department of Homeland Security on the estimated public burden of Form I-485, the Application to Register Permanent Residence or Adjust Status. It is our belief that rather than clarifying the agency’s rules on public charge, the proposed Form I-485 and its accompanying instructions may increase confusion and fear among immigrant families. Immigrant families who already face barriers to accessing publicly funded assistance may be even less likely to apply for critical benefits for which they or their family members might be eligible, which will result in negative social and public health consequences for American communities.

 

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