By Elizabeth Lower-Basch and Ashley Burnside:

We support the proposed rule and believe it is well-formulated to curtail misuse of TANF funds on services and programs that are not reaching “needy” individuals or that do not accomplish one of TANF’s statutory purposes. The proposed rule will also prevent states from shifting their responsibility to provide for needy residents onto non-governmental third parties, and provide several valuable clarifications to ease administrative burdens on states. However, the Department has an opportunity to further clarify some key provisions to aid states in implementing these proposals and prevent unintended consequences on needy individuals.

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