With regard to the welfare program, the Handbook provisions at Parts IV and V, which were applicable to the old Aid to Families with Dependent Children (AFDC) program, were never fully revoked or codified. Federal TANF funds can likewise be used to provide summer jobs for youth in "eligible/needy families." A State may continue to provide services and assistance to a child placed with a non-relative to the same extent that was permitted under the States Emergency Assistance plan as of the date selected by the State. Q35: The U.S. Department of Transportation's New Freedom Program (49 USC 5317), and the Formula Grants for Special Needs of Elderly Individuals (49 USC 5310) both have a cost sharing requirement. However, a State could enter into a multi-year contract with the agency to provide Federal TANF funds for rental subsidies (paid at a fair market value) on behalf on TANF-eligible families, contingent on the agency purchasing the building with other funds.12 The only expenditures that qualify for Contingency Fund MOE are State TANF expenditures . The AFDC statute and regulation allowed States to use Federal funds for EA and services that the State authorized during one period of 30 consecutive days in any 12 consecutive months, provided ALL EA eligibility criteria had been met. Collection of Information Requirements Based on our initial assessment of Breakthrough Devices applying the characteristics we . Therefore, while entirely the State's decision, it might be prudent for a State to conduct redeterminations no less often than annually. A22: Yes, we mentioned that supplemental unemployment insurance for unemployed workers in needy families is an allowable use of funds in the TANF funding guide (Helping Families Achieve Self-sufficiency). Q18: May States spend Federal TANF funds on health insurance coverage, e.g., for employee health premiums? Q6: May a State use Federal TANF or State MOE funds for adoption assistance? In summary, expenses incurred in the context of improving employee morale, including cash incentives to employees, are allowable if they are consistent with all applicable rules and regulations, including the criteria outlined above. Part 225 are still unallowable in the context of employee morale; for example, costs of alcoholic beverages and entertainment are unallowable. If leasing is being considered, the following criteria will apply: Subject to the limitations described below, rental costs are allowable to the extent that the rates are reasonable in light of such factors as: rental costs of comparable property, if any; market conditions in the area; alternatives available; and the type, life expectancy, condition, and value of the property leased. b. Income generated from any of these activities will be offset against expenses. Rental arrangements should be reviewed periodically to determine if circumstances have changed and other options are available. e. Significant deviations from the established practices of the governmental unit which may unjustifiably increase the Federal award's cost. Congress last reauthorized TANF in the Deficit Reduction Act of 2005 (P.L. Secondly, States may use Federal TANF or State MOE funds to provide "assistance" that addresses a child's needs during a period of temporary absence. Cash Assistance helps families meet their basic needs for well-being and safety and serves as their path to self-sufficiency. Q22: May a State use TANF or MOE funds to provide benefits that could serve as an adjunct to those available through its UI program (e.g., to provide coverage for short-term paid parental leave or to provide benefits for families with insufficient earnings to meet UI thresholds)? TANF funds cannot be used to purchase a trailer or modular building. These principles are also outlined in the federal regulations at 45 CFR 260.30 and 260.33 and the definition of what constitutes an Expenditure. Since these intercepted funds are being used to repay a debt owed to the state, they do not constitute an expenditure of federal TANF or MOE funds. Q9: What happens if the CCDF agency cannot use all the TANF funds transferred to it? Beyond the limited pro-family claiming provision described above, State may only claim for MOE purposes, allowable expenditures for or on behalf of eligible families. In Brief: The TANF maintenance of effort (MOE) requirement is a requirement that a state must spend at least a specified amount of state funds for benefits and services for members of needy families each year. The reason for such a service is to prevent an unwanted pregnancy from creating stress in the marriage. The amendments had to have an effective date of not later than January 1, 1996. Jump To Highlights Full Report GAO Contacts Highlights What GAO Found The Temporary Assistance for Needy Families (TANF) block grant's maintenance of effort (MOE) provisions include specified state spending levels and general requirements on the use of funds. A29: Payments to a developer for construction costs would not be a permissible use of Federal TANF funds. Further, note that all TANF expenditures, including food service expenditures, must be clearly linked to one or more of the four statutory purposes of TANF. When evaluating a request to lease a modular unit with TANF funds, the Tribe must also consider the extent to which the funds expended by the TANF program would represent the proportional cost of the units use by TANF staff and clients. Mothers Day lunch for TANF clients at a local restaurant. This is the state's Maintenance of Effort (MOE) requirements. We remind you, however, that 2 C.F.R. (f) This guide suggests some of the many flexible ways States may expend their Federal TANF and State MOE funds to further the purposes of the TANF program. July 20, 2022 LANSING, Mich. - The Michigan Department of Health and Human Services (MDHHS) is accepting public comment on its plan for spending Temporary Assistance for Needy Families funding from the federal government. The continuation of similar benefits designed to address a specific crisis or episode of need provided beyond the initial four months of non-recurrent short-term benefit receipt, even if provided through a new program, is not consistent with the regulatory definition of non-recurrent, short-term benefits at 45 CFR 260.31(b)(1). The provisions of Financial Accounting Standards Board Statement 13, Accounting for Leases, shall be used to determine whether a lease is a capital lease. To qualify for this financial assistance, a family must include children under the age of 18 and have gross income below 185% of the 2006 Federal Poverty level (FPL). A24: No, ACF-AT-95-9 -- dated September 12, 1995 -- instructed States that, effective January 1, 1996, Federal Financial Participation would not be available for juvenile justice costs and indicated that we would disallow any claims for such costs. DES office locator . A State should identify in its State plan its temporary absence policy as it pertains to assistance funded with Federal TANF and commingled funds, as well as MOE-funded assistance. catered meals during an all-day employment-related training for TANF clients. However, if the intercepted amount was retained by the state, then federal TANF funds or MOE could not cover this amount. Some of the Federal grant rules that should be considered in the formulation of a summer jobs for low-income youth program include: Q11: May a State use TANF funds to help needy families overcome the "digital divide" by providing access to computers and the Internet? In general, funds used to meet Federal cost-sharing requirements in other programs are not allowable as State MOE. In the preamble to the final regulation, we stated: "A family may not receive 'assistance' under the State's TANF program unless the family is needy. However, the repeal of that program and enactment of the Temporary Assistance for Needy Children (TANF) program has rendered the Handbook obsolete -- except in one situation.States that elect to continue programs under the former AFDC plan in accordance with grandfathering clause at section 404(a)(2) of the Social Security Act (e.g., the Emergency Assistance Program) must adhere to the applicable Handbook provisions governing presumptive eligibility (Part IV - 5520), interpretation of the authorization of award (Part IV - 5212), and the prior or simultaneous authorization of assistance (Part IV - 5214). States may use Federal TANF or State MOE funds to provide ongoing assistance and other benefits and services in "kinship care" situations where a child is placed with an adult relative. Q12: What is the status of the Handbook of Public Assistance? For example, the cost of an interpreter who provides program information or performs an employability assessment is not subject to the limitations; however, the cost of an interpreter to elicit family information for an eligibility determination is an administrative cost covered by the limitations. For Federal TANF funds, it is important to consider certain cost principles derived from appropriations law and OMB circulars (see pages 26 through 29 of our guidance). Expenditure means any amount of Federal TANF or State MOE funds that a State expends, spends, pays out, or disburses consistent with the requirements of parts 260 through 265 of this chapter.It may include expenditures on the refundable portions of State or local tax credits, if they are consistent with the provisions at 260.33.It does not include any amounts that merely represent avoided . The TANF statute and regulations, section 409(a)(7)(B)(iv)(IV) of the Social Security Act and 45 CFR 263.6(c), expressly prohibit counting expenditures made as a condition of receiving federal funds in another program toward a jurisdictions maintenance of effort requirement. _________________________________________________11A one-time payment to a family to assist in the purchase of a home (e.g., to assist with the costs of settlement and/or a downpayment) would not be considered assistance either; it would be excluded as a nonrecurrent, short-term benefit.12Such rental subsidies would constitute assistance for families that benefit from them.Q29: Assume a State program provides a deferred payment loan to a developer to assist with the construction or rehabilitation of multifamily housing for TANF families with substantial barriers to workand that the housing assistance is "bundled" with services, such as on-site child care. On March 11, 2021, the American Rescue Plan Act of 2021 (ARPA; P.L. 2 CFR Part 225, App. Please note the language in the PI explaining that a state may not treat foregone revenue as an allowable use of TANF or MOE funds, and that only the portion of the tax credit that the state actually refunds to the taxpayer may be claimed. These are links to the department's site that may answer questions you have about the programs. Selected Items of Cost, A trailer or modular unit is considered real property when the unit and its installation are designed or planned to be installed permanently at a given location so as to seem fixed to the land as a permanent structure or appurtenance thereto. However, we have indicated that costs such as equipment, travel, and office space costs, when directly associated with providing program services, would be treated as program costs (whether provided under contract or otherwise). In deciding whether to use TANF or MOE funds for SCHIP outreach and/or Food Stamp informational activities, States need to keep in mind basic program and cost principles. Therefore, the restriction at 45 CFR 286.45(e) applies. TANF was created in the Personal Responsibility and Work Opportunity Act of 1996 (P.L. . Employee morale, health, and welfare costs. In serving the non-needy, States may use only segregated Federal TANF funds.1 A23: States may set up reserve accounts for this purpose using State funds, but the funds placed in a reserve account would not count as an MOE expenditure until the developer draws them down. Publicly Released: May 17, 2012. The purchase of computer hardware, software or Internet access does not appear to meet the definition of TANF assistance. B. The use of State MOE funds for the program requires that any expenditure be made on behalf of "eligible families." It includes the costs of general administration and coordination of programs including contract costs and all indirect (or overhead) costs. a. State agencies administering the Temporary Assistance for Needy Families (TANF) program, Indian tribes administering approved TANF Plans, and other interested parties. To benefit from current prices and discounts for bulk purchases, a State could contract for computers and Internet access and actually liquidate the current year obligation over the next two years. Therefore, the statute envisions that States would serve only the needy when they are conducting activities or providing benefits that are reasonably calculated to accomplish TANF purpose one or two. This new State Plan is submitted to renew Delaware's eligibility status for the Temporary Assistance for Needy Families (TANF) program provided for in the enactment of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), (P.L. In pertinent part, 45 CFR 233.120 states that EA may only be provided: To or on behalf of a needy child under the age of 21 and any other member of the household in which he is living if: (i) Such child is (or, with 6 months prior to the month in which such assistance is requested, has been) living with any of the relatives specified in section 406(a)(1) of the Act in a place of residence maintained by one or more such relatives as his or their own home. Q7: Is ACF going to work with the auditors to convey the same message about funding flexibility as the TANF agencies are receiving? All MOE funds must be spent on TANF eligible families. Published: May 17, 2012. Response: | 1310 L St. NW, Suite 900 | Washington, D.C. 20005 | (202) 906-8000, Copyright 2023 by the Center for Law and Social Policy, Inc. All Rights Reserved, Work-Based Learning and Subsidized Employment, Still at Risk: The Urgent Need to Address Immigration Enforcements Harms to Children, Expanding Access to Child Care Assistance: Opportunities in the Child Care and Development Fund. The term "eligible families" means that the family must include a child living with a custodial parent or other adult caretaker relative (or a pregnant woman) and be financially needy as discussed in step three. (per section 406(a)(1) of the Act, the child must be living with his father, mother, grandfather, grandmother, brother, sister, stepfather, stepmother, stepbrother, stepsister, uncle, aunt, first cousin, nephew, or niece, in a place of residence maintained by one or more of such relatives as his or their own home. TANF requires states to maintain a significant portion of their own historic financial commitment, called maintenance of effort (MOE), to welfare-related programs. A18: Payments for health insurance coverage would constitute expenditures on medical services. o MOE funds are segregated from the Federal grant funds and expended in the TANF program operated by the State. For example, if the Tribe has or wants to implement an employee morale/cash incentive based on actual employee performance then TANF funds may be used to pay the incentives for TANF employees up to the percentage of effort they work on the TANF program. Drawdown of such Federal funds is governed by the Cash Management Improvement Act.The nature of the benefits provided (rather than the nature of the contractual arrangement with the developer) determines whether the benefits constitute assistance. [M]aintenance payments for foster care, substitute care, and out-of-home placements (except perhaps temporary emergency placements during an investigation of abuse) are not eligible TANF expenditures unless allowable under section 404(a)(2). The TANF and SSP-MOE Data Report instructions were revised to streamline the data collection, reduce the burden on respondents by eliminating unnecessary data elements, and clarify confusing data elements. Q23: Suppose a State provides funds to a developer for a reserve account that will be used to reduce future rents so that they would be affordable for TANF families (e.g., providing an average rent subsidy of $300/month). As we indicated in the TANF funding guide, States may only claim MOE expenditures with respect to eligible families, i.e., families in which a child lives with a parent or caretaker relative (or is a pregnant individual) and that are needy per the financial eligibility criteria (i.e., according to the appropriate income and resource (when applicable) standards) established by the State in its TANF plan. On the other hand, training of staff to perform administrative functions -- such as eligibility determinations, procurement, and payroll -- would be considered administrative costs. We will also reference the guidance document (i.e., "Helping Families Achieve Self-Sufficiency, A Guide on Funding Services for Children and Families through the TANF Program") and briefly explain it in the Compliance Supplements that we prepare to assist auditors during their annual audits of State programs. If you want to request a wider IP range, first request access for your current IP, and then use the "Site Feedback" button found in the lower left-hand side to make the request. Such benefits and services must generally further one of TANFs purposes, which broadly focus on providing financial assistance to needy families; promoting job preparation, work, and marriage; reducing out-of-wedlock births; and encouraging the formation of two-parent families. TANF funds cannot be used to provide food to the Tribal community in general at cultural events. To receive TANF funds , states must meet a maintenance of effort (MOE) requirement under which they continue to spend on programs benefiting needy families a specified share of the funds that they spent prior to welfare reform on the programs that TANF replaced. Hence, as explained above, to claim any MOE expenditures for outreach activities, a State must have a sound methodology that enables it to identify and claim only the portion of total qualified expenditures for benefits that have been provided to or on behalf of eligible families. However, if an employee is providing program services, then the associated salary and benefits (including any employee morale costs) are excluded from the administrative cost limit. A31: Yes, State TANF agencies may use their Federal TANF and MOE funds to provide language services and other services needed by LEP families applying for or receiving TANF benefits. The State's basic MOE level for a fiscal year will be reduced by the same percentage as we reduced the SFAG as the result of any Tribal Family Assistance Grants awarded to Tribal grantees in . [REVISED] Q14: May States use TANF and/or MOE funds for SCHIP outreach and Food Stamp Program (FSP) informational activities? Currently, states spend only slightly more than one-quarter of their combined federal TANF funds and the state funds they must spend to meet TANF's "maintenance of effort" (MOE) requirement on basic assistance to meet the essential needs of families with children, and just another quarter on child care for low-income families and on activities t. Any such expenditures by a State would not count against its administrative cost caps. Is it allowable to use Federal TANF funds to help meet the cost-sharing requirement of either program? A34: Federal TANF funds may be expended on items that are necessary to enable the needy TANF individual to engage in training for positions in the construction field. A30: No. The TANF staff understand that they can't build a facility, but would like to know what can be done to stay within the guidelines for allowable uses of TANF funds. The implementing regulation was 45 CFR 233.120. States must use the same eligibility criteria and the same duration for the assistance and services contained in the approved plan. If a State wishes to supplement a summer jobs for low-income youth program covered under a State WIA youth plan, it may use Federal TANF or State MOE funds to contract with the applicable workforce agency for additional services or summer jobs on behalf of needy, eligible families. The number of payments made by the State to the subrecipient is irrelevant. For more information, contact Kay E Brown at (202) 512-7215 or [email protected]. Tribal TANF programs have the flexibility to establish their own allowable work activities, including, if desired, culturally relevant work activities. This means that TANF expenses incurred in the context of employee morale are allowable if they are consistent with the State, Tribe, or Territorys established personnel practice and policies governing the administration of TANF and other government programs. Services provided to such persons can only be in the form of benefits that do not constitute "assistance".). States may only use Federal TANF or State MOE funds for allowable TANF or MOE expenditures. Non-federal funds used to meet the matching requirement for the HUD homelessness programs cannot count as MOE in the TANF Program. Finally, the State child care agency could receive TANF funds under a contract, grant, or similar arrangement to provide TANF benefits or services on behalf of the TANF agency. Even under prior law, States helped needy families avoid eviction by providing them with funds to cover their rent arrearages. 117-2) was signed into law. Items or services such as clothing, books, tuition, and onsite instruction that are used exclusively for training purposes can be covered with Federal TANF funds. Holiday baskets are allowable if clearly linked to TANF purpose one and thus only provided to families meeting income and family composition criteria; however, providing holiday baskets to the community in general does not meet a purpose of TANF and is thus unallowable. premise includes the requirements for these individuals to comply for three days of Jobs Program requirements prior to TPEP cash assistance approval. The Department's Office of Grants Acquisitions and Management issued OGAM AT 98-2, which provided that A-87 requires that TANF and other government programs must allocate costs to all "benefiting" programs. In short, TANF and MOE expenditures that are not "administrative costs" are not subject to the 15-percent cost limitations. 2 C.F.R. B, section 27 clarifies that the the primary purpose of [the conference or meeting must be] the dissemination of technical information (emphasis added). Section 408(a)(10) does not directly address allowable living arrangements for MOE purposes.3 However, under a State temporary absence policy, it would be reasonable for a State to determine that a child who is temporarily absent is living with a parent or adult caretaker relative. This determination must be based on a sound methodology that enables the State to arrive at a reasonable estimate of the TANF-eligibles benefiting from the service vs. the non-eligible population. There is no language in title IV-A of the Social Security Act which governs the TANF program that prevents Federal TANF funds from being used as matching funds for the above mentioned HUD homelessness programs. For the purpose of this response, food service expenses include food and other related costs (e.g., gratuity, catering staff, delivery charges, renting tables, etc.).