Comments sought on proposed change to Temporary Assistance for Needy Families (TANF) regulations

The U.S. Department of Health and Human Services (HHS), Administration for Children and Families (ACF) recently proposed changes to improve the effectiveness and integrity of Temporary Assistance for Needy Families (TANF) regulations. This Notice of Proposed Rulemaking (NPRM) is meant to help families experiencing the greatest economic hardships benefit from the services that Congress intended for the TANF program to provide, but there are a number of proposed changes that could have the unintended effect of significantly reducing access to support services for families with school-age children.

Of particular concern to the afterschool community is the fact that the proposed rule might put funding for afterschool supports in jeopardy. TANF funding currently supports afterschool programs in eight states, ensuring school-age youth from TANF-eligible families have a safe and productive place to go while parents or guardians are at work or participating in workforce training. 

The proposed rule puts forward for public comment seven changes to the current regulations, intended to increase program integrity, clarify allowable uses of TANF, and reduce obstacles for individuals trying to access support. Among them are:

• Establish a ceiling on the term "needy"

• Clarify when an expenditure is "reasonably calculated to accomplish a TANF purpose"

• Exclude as an allowable TANF maintenance-of-effort (MOE) expenditure cash donations from non-governmental third parties and the value of third-party in-kind contributions

The Afterschool Alliance is concerned that language in the proposed rule may cause afterschool and summer programs to miss the criteria for expenditures that are reasonably calculated to accomplish a TANF purpose. However, based on data from more than 30,000 households in the America After 3PM (2020) survey, we know that more than eight in ten parents agree that afterschool programs “give working parents peace of mind, knowing that their children are safe and supervised” and “help working parents keep their jobs.” Afterschool programs for families in need ensure that young people have a supportive place to go to while parents or guardians are at work. These programs have demonstrated positive outcomes through evaluations, as well as program level reporting. Outcomes include the ability of parents to continue work and educational programs; as well as development of protective factors and skill building for youth that help them develop healthy relationships and prevent early and unwanted pregnancies.

The Afterschool Alliance submitted comments to this proposed rule on December 1, 2023.