In Focus: Federal TANF Policy
Nov 2, 2012 | PERMALINK »
News Reports Highlight Why TANF Flexibility is Needed
When Congress returns to Washington after the November 6 election, it is possible that the Senate will consider a resolution "disapproving" of the welfare waiver guidance issued by the Department of Health and Human Services (HHS) in July. This guidance addresses work participation rates and "allows states to test alternative and innovative strategies, policies, and procedures that are designed to improve employment outcomes for needy families."
Recent news stories highlight the problems with the current work participation rates and the reasons that HHS is on the right path in inviting states to propose thoughtful alternatives that would more accurately reflect the states' performance in helping clients achieve self-sufficiency through work.
- Louise Radnofsky's story for the Wall Street Journal focuses on the ways in which the work participation rates force clients and caseworkers to spend their time and attention on documenting participation, rather than on finding jobs or building skills. The article quotes Andrea Beske, a program manager for a nonprofit that handles welfare recipients' cases for Minnesota as saying that counselors spend 90% of their time explaining, collecting and reviewing time sheets to prove recipients are seeking work.
- Writing for the Christian Science Monitor, Mark Guarino explains that Ohio has cut thousands of poor families from cash assistance in the past year - a 30 percent decline - in a desperate attempt to come into compliance with the federal requirements. Ohio has failed to meet the target for several years, and faces the loss of as much as $135 million from its block grant unless it achieves the goal this year. While some clients are finding jobs as the economy slowly improves, others are being cut due to time limits or sanctions, as reported by Kate Giammarise for the Toledo Blade earlier this year. It is easier to cut clients off than to help them find jobs - and the work participation rate can be met either way.
Congress has a long list of important work to do before December 31. Blocking HHS from partnering with states that are ready to be evaluated based on their customers' employment outcomes should not be on that list.
Jun 12, 2012 | PERMALINK »
EBT Blocking Rules Should Minimize Harm to Low-income Families
When Congress extended the Temporary Assistance for Needy Families program through the end of fiscal year 2012, it required states to adopt policies and practices to ensure that TANF cash assistance cannot be withdrawn with an Electronic Benefits Transfer (EBT) card from ATMs or point of sale (POS) devices located in liquor stores, casinos, and adult entertainment establishments. CLASP has long-argued that these restrictions are unnecessary, based on misleading and overhyped media reports, and stigmatize needy families
However, given that this requirement has been enacted into law, CLASP has submitted comments to the Administration for Children and Families' (ACF) solicitation for input on how to implement these requirements. In our comments, CLASP urged HHS to consider the following broad principles as it prepares regulations:
- As much as possible, regulations should minimize the burden upon states of implementing these requirements. In the context of a fixed block grant and demand for services that far exceeds available funding, devoting resources to enforcing restrictions on TANF EBT access would take away resources from other services for needy families.
- ACF should make clear that the blocking requirement only applies to funds that are placed onto a state provided EBT card. It does not apply to the use of a debit card to access funds from a bank account that originated as TANF benefits (through a check, direct deposit, or by a client withdrawing funds from EBT and placing them in the bank). The blocking requirement also does not apply to services funded by TANF (including short-term non-recurrent payments and wages for subsidized employment) or non-TANF benefit programs.
- By including the state plan language about ensuring client access to TANF benefits (including low-cost or free access) in this section, Congress recognized that EBT blocking may have adverse impacts on access or cost. ACF should explicitly permit states to make exceptions to EBT blocking in areas where benefits cannot readily be accessed except in restricted locations.
- There is significant variation across states in the fees that EBT vendors and ATM/POS owners may charge to clients for accessing their TANF benefits. These policies should be clearly disclosed to clients and described in the state plan, and states should make public information about the total fees collected. ACF should share best practices in this area with the states, along the lines of the Department of Labor's Unemployment Insurance Program Letter 34-09.
- ACF should encourage states to implement these provisions in a way that minimizes the burden on clients to understand and comply with the restrictions, and that does not put cash register operators in a position of monitoring compliance.
States have until February 22, 2014 to adopt policies implementing the new requirements. HHS has stated that it will issue a proposed rule regulating the requirement for states to report on their policies and practices, and the associated penalty. The proposed rule will be published and subject to public comment before it is finalized. CLASP will provide analysis and comment on the draft rule at that time.
The low-income families receiving TANF assistance struggle with many different things each day, including finding safe child care, transportation to get to work, and having enough to pay the bills at the end of the month. Additional barriers to accessing their TANF assistance shouldn't be added to that list. By adopting these principles, ACF can minimize the resources wasted in implementing this provision, and ensure that needy families are not unduly burdened and do not pay excessive fees in accessing their benefits.
Feb 17, 2012 | PERMALINK »
EBT Restrictions Stigmatize Struggling Families
By Catlin Nchako and Elizabeth Lower-Basch
As part of the payroll tax bill passed today, Congress extended the Temporary Assistance for Needy Families (TANF) block grant through the end of the fiscal year (September 30, 2012). The TANF program was scheduled for reauthorization in 2010, but Congress has not taken it up, instead passing a series of short-term extensions. The bill passed by Congress did include one policy change, however.
Did the bill increase the TANF block grant, which has not been adjusted for inflation since it was created in 1996? No, it did not. Did the bill restore the TANF supplemental grants, which provided additional funding to 17 states with historically low grants per poor child or rising population? No, it did not. Did it require states to raise their benefit levels, which were less than half of the poverty line in every state in the U.S in 2011? No it did not.
Instead, the bill requires states to implement rules to make sure that TANF recipients cannot access their benefits by withdrawing funds from ATMs or point-of-sale devices located at liquor stores, casinos and strip clubs. States that neglect to do so within a two-year period would risk losing a share of TANF funds.
This new provision is part of a growing trend of policies that stigmatize struggling families. They hinge on the stereotype of welfare recipients as vice-ridden and wasteful spenders of taxpayer money. The idea that TANF recipients are using their cash benefits on gambling sprees or drinking them away may make for sensational headlines but is not based on facts. A parent may withdraw funds to pay her rent at an ATM located in a liquor store simply because it is the lowest-cost or most convenient ATM.
The bill did include one helpful provision that CLASP and our partner organizations urged be included. States must revise their TANF plans when they implement this requirement, and when they do so, they must also describe how they will ensure that recipients of assistance have adequate access to their benefits, including opportunities to access funds without fees or surcharges.
Welfare recipients typically are allowed a limited number of no-fee cash withdrawals at an ATM: one per month in states such as Missouri and South Carolina, three in Maryland and New Jersey, four in California and Minnesota. The fees subsequently charged after these no-fee withdrawals vary by state, from as little as 40 cents per cash withdrawal in Kansas and New Jersey to as much as $1.75 per withdrawal in Mississippi. In at least five states, fees are charged from the first withdrawal. In addition, welfare recipients are typically charged a surcharge on top of any fee, as much as $4 or $5 per transaction, if they use an ATM that is not part of the network that operates the EBT system. Recipients may also be charged fees for balance inquiries.
Given that the maximum monthly benefit for a family of three is just $428 a month in the median state - and less than $300 a month in 14 states, this can add up to a significant tax on the lowest income families. Now that this bill is law, states should implement these rules in a way that minimizes the burden on families that are struggling to make ends meet during tough economic times, and allows them to access their funds without traveling large distances or paying fees that eat into their already tight budgets.