Welfare Reform: Comments from the Public on TANF Reauthorization

CRS Report for Congress
Welfare Reform: Comments from the Public
on TANF Reauthorization
Updated December 28, 2004
Vee Burke, Gene Falk, Melinda Gish, Shannon Harper,
Carmen Solomon-Fears, Karen Spar, and Emilie Stoltzfus
Domestic Social Policy Division

Congressional Research Service ˜ The Library of Congress

Welfare Reform: Comments from the Public
on TANF Reauthorization
The 1996 welfare law repealed the previous Aid to Families with Dependent
Children (AFDC) program and replaced it with a block grant to states for Temporary
Assistance for Needy Families (TANF). This landmark legislation required that
federally funded cash assistance be time-limited and conditioned on work, but also
gave states great flexibility in the design of their programs. TANF funding expired
at the end of FY2002 and Congress has continued the program and its funding
through a series of temporary extensions. Efforts toward a long-term reauthorization
of welfare reform began during the second session of the 107th Congress and remain
on the agenda for the 109th Congress.
In preparation for the reauthorization debate that began in 2002, the Department
of Health and Human Services (HHS) solicited public input on TANF during the fall
of 2001. HHS conducted a series of regional “listening and discussion” sessions, and
also invited the public to submit comments, either through the mail or electronically
through a specially created website. This report presents a summary of the comments
received by HHS (more than 4,000 were submitted) and is intended to convey a
general sense of the views and opinions expressed. Readers should note that the
persons and groups who submitted comments represented a self-selected and varied
group and may or may not be representative of the larger population.
HHS prescribed no format for the comments, so they were submitted in many
forms and sizes. Some were long essays, others included lengthy lists of ideas, while
others submitted just a paragraph. Some commenters urged comprehensive
proposals that dealt not only with TANF but with related programs and services.
Some made comments without necessarily making recommendations for change.
The following general observations might be made about the content of these “free-
form” recommendations:
!All categories of commenters wanted Congress either to maintain or increase
the amount of funding available for the TANF block grant.
!There was concern that, although welfare reform has succeeded in promoting
work, jobs have failed to end poverty for some families and have not been
possible for others because of personal barriers.
!Advocates for low-income families tended to urge substantial change in
TANF. Many wanted to impose more mandates on states. They wanted
Congress to require states to provide certain services to certain groups and to
adopt certain procedures. Some proposed repeal of existing ineligibility rules.
!On the other hand, representatives of states and state/county welfare
departments generally wanted to keep maximum flexibility to design and
operate TANF.
!Among commenters on work and time limit rules, there was strong support
for allowing more education and training to be treated as work activities and
for suspending the time limit for some persons and under some circumstances.
!Child care was widely seen as a necessary work support and child support as
a needed source of family income.

In troduction ......................................................1
Methodology .....................................................2
Categorizing the Commenters................................3
Categorizing the Comments..................................3
Why There Are No “Counts” of Comments.....................3
Brief Description of the Commenters..................................4
Overview of Comments.............................................5
Summary of Comments on TANF.....................................6
Goals and Philosophy...........................................6
Funding .....................................................7
Basic Funding Levels.......................................7
Other Grants..............................................8
Flexibility in the Use of Grants...............................9
Program Requirements.........................................10
Time Limits.............................................11
Eligibility Rules..........................................11
Work Rules.............................................11
Assessments .............................................12
Sanctions ...............................................13
Treatment of Special Groups....................................14
Domestic Violence Victims.................................14
Teen Parents.............................................14
Mothers of Young Children.................................14
Nonparental Caregivers....................................14
Rural Issues.............................................14
Indian Tribes............................................14
State Accountability.......................................15
Bonuses ................................................15
Information and Data Reporting.............................16
Administration ...........................................16
Equitable Provision of Services and Benefits...................17
Summary of Comments on Related Programs...........................17
Child Care..................................................17
Funding ................................................18
Program Requirements.....................................18
Data Collection..........................................19
TANF-Funded Child Care..................................19

Child Support Enforcement.....................................19
Medicaid ...................................................21
Food Stamps.................................................22
Child Welfare................................................22
Other Programs..............................................23
Earned Income Tax Credit..................................23
Unemployment Insurance..................................23
Social Services Block Grant................................23
Community Services Block Grant............................24
Minimum Wage..........................................24
Housing ................................................24
Summary of Comments on Cross-Cutting Issues........................24
Noncitizens .................................................24
Program Coordination.........................................25
Transitional Supports for Welfare Leavers.........................26
Charitable Choice.............................................27
List of Tables
Table A1. Comment and Recommendation Categories...................28
Table A2. Commenter Categories....................................36

Welfare Reform: Comments from the Public
on TANF Reauthorization
The 1996 welfare reform law repealed the previous Aid to Families with
Dependent Children (AFDC) program and replaced it with a block grant to states for1
Temporary Assistance for Needy Families (TANF). This landmark legislation
required that federally funded cash assistance be time-limited and conditioned on
work, but also gave states great flexibility in the design of their welfare programs.
TANF funding was authorized and appropriated only for six years and expired at the
end of FY2002; however, Congress has continued the program and its funding (at
FY2002 levels) through a series of temporary extensions. Efforts to enact a long-th
term reauthorization of welfare reform began during the second session of the 107
Congress and remain an agenda item for the 109th Congress. During the 108th
Congress, the House and the Senate Finance Committee each passed different
versions of a long-term reauthorization bill (H.R. 4), but no final action occurred.2
The TANF block grant is administered at the federal level by the Department
of Health and Human Services (HHS). During the fall of 2001, in preparation for the
debate on reauthorization of TANF, HHS solicited public input through two
mechanisms. First, HHS officials conducted a series of regional “listening and
discussion” sessions to which state and local officials and welfare recipients were
invited to share their views about implementing and improving TANF programs.
Wade Horn, Assistant Secretary for Children and Families, led these sessions in
Atlanta, Chicago, Dallas, Philadelphia, New York, San Francisco, and Washington,
D.C. A meeting with tribal representatives also was held in San Francisco.
In addition, in the October 17, 2001, Federal Register, HHS formally invited
members of the public to submit comments, through November 30, 2001, either
through the mail or electronically through a specially created website. As stated in
the Federal Register, the Department’s primary interest was “gathering input about
the TANF provisions of the [1996 welfare reform] legislation. However, many other
federal programs, such as the Food Stamp Program, the Child Care and Development
Fund, Child Welfare, and Child Support Enforcement, serve the same needy families
as TANF and provide related benefits. Some of these programs are facing

1See CRS Report RS20807, Short History of the 1996 Welfare Reform Law, by Joe
Richardson and Vee Burke.
2For a comparison of current law with the House and Senate Finance Committee versions
of H.R. 4 (108th Congress), see CRS Report RL32210, TANF Reauthorization: Side-by-Side
Comparison of Current Law and Two Versions of H.R. 4, by Vee Burke and Gene Falk.

reauthorization ... as well. Thus, the Department will also accept comments on
program coordination issues.”
A precise count of unduplicated comments received by HHS — or of the
individuals and organizations who submitted them — is not obtainable. Several
groups led organized campaigns and generated hundreds of comments, some of
which were easily identifiable as part of an organized campaign while others were
not. The following numbers are offered to give a sense of the scope of the TANF
comments project. Through the specially created HHS website, nearly 700
comments were submitted (some may have been duplicates; others may have been
submitted on different topics by the same individual or organization). Almost
another 4,000 comments were submitted through the mail or by other means (e-mail,
hand delivery). Of these, about 3,000 resulted from organized campaigns. For
example, an organization called Network: A National Catholic Social Justice Lobby
brought in more than 2,000 comments; other groups that organized comment
campaigns included the Children’s Defense Fund, Grassroots Organizing for Welfare
Leadership, Midwest Partners, Influencing State Policy, and the Welfare-to-Work
This report presents a summary of the comments that were received by HHS in
response to the Department’s request, and is intended to convey a general sense of
the views and opinions expressed. The report begins with an explanation of the
methodology used for preparing this summary and a discussion of the categories of
groups and individuals who submitted comments, followed by a general overview of
the comments themselves. The balance of the report presents a summary of the
comments, organized by topic. Only limited background information is included on
the current law provisions which may be the subject of comments. Readers should
consult other CRS reports for background information on TANF law and related
programs and for the status of current legislation.3
This report summarizes the TANF reauthorization comments by focusing on
three major questions:
!Who made the comments? To place the comments in some perspective, it is
necessary to describe who made them;
!What were the most common comments and legislative recommendations?
!Who said what? What were various types of organizations or individuals
interested in? Were there differences in the types of concerns and
recommendations made by different groups?

3Readers should go to the Current Legislative Issues section on the CRS home page, click
on “Social Policy” and then on “Welfare” for a selected list of CRS products; or use the
search box on the CRS home page to identify the full range of CRS reports on TANF and
related programs and issues.

A team of Congressional Research Service (CRS) analysts categorized
information about the commenters and their comments and entered them into a
database. The comments are qualitative in nature — that is, they are in essay form
and varied widely in both style and content. Though the database afforded analysts
a structure for categorizing the comments, their varied nature often required CRS
analysts to exercise considerable judgment.
Categorizing the Commenters. Those making comments were categorized
into groups; for example, elected officials, national advocacy organizations, local
advocacy organizations, faith-based groups, etc. Additionally, comments and
recommendations were received by a number of organizations that are nonpartisan
research organizations but which expressed a point of view, such as the Heritage
Foundation and the Center for Budget and Policy Priorities. These organizations
were placed in their own category (research/advocacy). A distinction also was made
if an organization was involved in delivering services to families. (See Appendix
Table A2 for a list of the categories used in this report.) Additionally, commenters
were categorized by their geographical affiliation. National organizations were
identified as such, and organizations at the state and local level were identified by
their state.
The categorization of many commenters proved to be difficult. Some of those
making comments identified themselves with an organization, but it was unclear
whether they were speaking for the organization. With mailed comments, it could
reasonably be determined that those written on a letterhead and signed by an official
represented the organization’s point of view. However, it was much more difficult
to discern whether comments submitted through the Internet represented an
organization’s point of view or an individual’s opinion. Additionally, comments
submitted through the Internet often did not contain enough information to identify
a commenter as belonging to a particular category. Therefore, a relatively large
number of commenters were classified either as “general public” or “unknown.”
Categorizing the Comments. The comments themselves were also
categorized. CRS primarily focused on legislative recommendations made by the
commenters; i.e., those statements that signaled a change in policy that could be
made by amending federal law. However, judgment was often required to determine
whether a comment was making a legislative recommendation, or expressing a more
general point of view about welfare policy. Moreover, since HHS solicited comments
from the public, and not just legislative recommendations, an attempt was made to
capture the flavor of the comments in addition to their recommendations.
Many comments included numerous legislative recommendations. Each
recommendation was placed in the appropriate topical category; that is, a comment
from a single individual or organization could have been entered into the database
under several different categories. See Appendix Table A1 for a listing of the
Why There Are No “Counts” of Comments. Though each comment was
tallied in the CRS database, this report does not provide exact numbers of specific
comments or recommendations for a legislative change. It was determined that any
attempt to quantify the comments or recommendations would pose problems. Some

comments represented large organizations potentially reflecting the views of many
people, and some represented individual views. There is no objective way to
“weight” such diverse commenters. Further, a large number of comments were made
through organized letter-writing campaigns, and again, there was no objective way
to give weight to these comments without either skewing the results in the direction
of those comments generated by letter-writing campaigns, or devaluing comments
made through such campaigns. Instead, for each particular issue, the report presents
the scope of the recommendations made as well as the suggestions that were more
or less popular among the commenters.
Brief Description of the Commenters
The many persons and groups who responded to the HHS call for comments
represented a self-selected group. Those who made comments were aware of the
opportunity to comment — from the Federal Register notice, the HHS press release,
and each other. Furthermore, for various reasons, they were sufficiently interested
in the future of TANF to participate in the process. Many of them had close
experience with TANF and had come to some conclusions about how it should be
changed, if at all.
Though the commenters were self-selected, they did come from a wide range
of organizations and backgrounds. Some of the organizations that commented are
familiar from previous debates on welfare reform, and have been asked for and given
testimony before Congress on welfare issues. However, others who commented were
less connected to past federal legislative debates and are active mainly at the state and
local level. Comments on TANF reauthorization were received from:
!Elected Officials. Comments were received from several United States
Senators, state legislators and a few governors. Moreover, there were
comments from organizations that represent elected officials, among them, the
National Governors Association (NGA), National Conference of State
Legislators (NCSL), and the U.S. Conference of Mayors.
!State and Local Human Resource Agencies and Service Delivery
Practitioners. The American Public Human Services Association (APHSA)
and numerous state human resource agencies submitted comments and
legislative recommendations. These public agencies administer or supervise
the administration of TANF at the state level, and APHSA is their national
advocacy organization. In addition, there were comments from local human
services agencies as well as numerous comments from community service
organizations, including child care referral agencies. Comments were also
received from the National Council of Child Support Directors, the National
Association of Social Workers, and the National Association of Black Social
!National Advocacy Organizations. Comments came from national advocacy
organizations representing particular constituencies or views. Comments were
received from groups such as the Children’s Defense Fund (CDF), Planned
Parenthood Federation of America, the National Association for the
Advancement of Colored People (NAACP), National Organization for

Women (NOW) Legal Defense and Education Fund, National Urban League,
Children’s Rights Council, the American Bar Association, and others.
!State and Local Advocacy Organizations. A relatively large share of
comments came from private state and local advocacy organizations. Unlike
many of the national advocacy organizations, which commented on welfare
reauthorization while expressing views on a wide range of issues, state and
local advocacy organizations often were more narrowly focused. For
example, there were several comments from organizations concerned about
protection, treatment, and services for victims of domestic violence. There
were also organizations that appeared to focus on TANF reauthorization as
their single issue (for example, Washington’s TANF Reauthorization
Campaign, the Utah Reauthorization project). A few Indian tribes made
!Faith-Based Organizations. Comments were made by both national and
local faith-based advocacy and service groups. National faith-based groups
that made comments included the U.S. Conference of Catholic Bishops,
Evangelical Lutheran Church in America, United Jewish Communities,
Catholic Charities USA, and the National Catholic Social Justice Lobby. A
number of comments came from local chapters of Catholic Charities, and
local dioceses.
!Research Organizations. Comments were received from a number of
research organizations that tend also to make policy recommendations. Such
organizations included the Center on Budget and Policy Priorities (CBPP),
Center on Law and Social Policy (CLASP), the Heritage Foundation, and the
Progressive Policy Institute. Additionally, comments were received from
professors at universities and students of social work.
!The General Public. Some commenters did not identify themselves as
members of any organization. Some of these comments were likely made by
members of the general public; a few identified themselves as being former
recipients. A fairly large number of comments did not have enough
information to identify the commenter with a particular organization, though
the comment might reflect the view of an organization or may have been a
part of a letter-writing campaign.
Overview of Comments
Comments on TANF reauthorization reached HHS in many forms and sizes.
No format was prescribed. No list of subjects for comment was given. Some
persons submitted long essay responses, summing up their appraisal of TANF
achievements and failings. Some gave long lists of ideas for change; some just a
paragraph. Some urged comprehensive proposals that dealt not only with TANF but
with related programs and services. It can be assumed that most wrote about what
concerned them most.
Reading this outpouring of “free-form” suggestions about the next round of
welfare reform gives this general picture:

!All categories of commenters wanted Congress either to maintain or increase
the amount of funding available for the TANF block grant.
!There was concern that, although welfare reform has succeeded in promoting
work, jobs have failed to end poverty for some families and have not been
possible for others because of personal barriers.
!Advocates for low-income families tended to urge substantial change in
TANF. Many wanted to impose more mandates on states. They wanted
Congress to require states to provide certain services to certain groups and to
adopt certain procedures. Some proposed repeal of some existing ineligibility
!On the other hand, representatives of states and state/county welfare
departments generally wanted to keep maximum flexibility to design and
operate TANF.
!Among commenters on work and time limit rules, there was strong support
for allowing more education and training to be treated as work activities and
for suspending the time limit for some persons and under some circumstances.
!Child care was widely seen as a necessary work support and child support as
a needed source of family income.
Summary of Comments on TANF
Goals and Philosophy
Basic philosophy and program goals attracted a very large block of comments
on TANF (outnumbered only by comments on funding and the time limit). A
majority of the philosophic commenters urged that poverty reduction be added as a
program goal or purpose. A typical remark was that TANF should strive to reduce
poverty, not caseloads. Support for making poverty reduction an explicit program
goal came from advocacy organizations, faith-based groups, research groups, some
elected officials (state legislators, U.S. Senators), human service agencies,
community service organizations, students of social work, and members of the
general public, including two former welfare recipients. A few commenters said
there should be a federal obligation to serve families in need, and several said
TANF’s overall purpose should be expressed as promoting the well-being of children
and families.
The next most common “goal” recommendation, closely allied to the existing
statutory goal of ending dependence on government benefits, proposed “self-
sufficiency” as a key TANF objective. Noting research findings that many ex-TANF
recipients have joined the working poor, these groups often urged income supports
and better jobs for them, along with education and training to enhance their earning
Because of welfare I was able to work part timeSome states expressed
and raise my daughter in a healthy, happy and safeviews about the objectives of
environment: our home. PLEASE, make welfareTANF. One said it found
work to ensure low-income families can work theirreasonable the existing
way out of poverty.
— former welfare motherstatutory statement of purpose:

To increase state flexibility in operating programs designed to achieve (1) support of
needy children in their own homes, (2) an end to dependence on government benefits,
(3) reduction or prevention of out-of-wedlock pregnancies, and (4) promotion of the
formation and maintenance of two-parent families. One said TANF should maintain
“core” elements, including no entitlement and a continued focus on work. Another
state said it would be a serious mistake to take the focus off work and training.
Remarks about the current
Welfare reform has begun to improve the oldfamily formation goals
welfare system by promoting work and(numbers 3 and 4 above)
responsibility. These first few years ofdisclosed disagreement. Most
implementation, however, have demonstrated thatcommenters favored efforts to
there is much more that needs to be done to helpreduce unwed pregnancy,
low-income families achieve self-sufficiency.especially among teenagers.
— state welfare agencyBut many opposed the current
abstinence-only education
programs aimed at that goal, instead favoring more comprehensive education on
reproduction and birth control. Many commenters urged that government be neutral
regarding marriage. Sample comments give their flavor: “Government should not
legislate morals or favor married couples.” “The shift to promoting marriage is
dangerous.” “Marriage is a highly personal matter.” A common view was summed
up by county welfare directors: “Permit but don’t mandate marriage promotion.” On
the other hand, a few respondents urged that a portion of TANF funds be set aside for
marriage promotion.
The most common recommendations concerned TANF funding. In terms of
sheer numbers, more comments advocating either maintaining or increasing funding
were made than were made for any other legislative recommendation. Moreover,
recommendations not to cut funding or to increase TANF funds were made by all
categories of commenters. Additionally, there were a large number of comments that
advocated retaining, or even expanding, state flexibility in the use of grants.
Retaining state flexibility was a major concern of organizations representing state
interests, but it was a theme in other comments as well.
Basic Funding Levels. The 1996 welfare reform law established a basic
$16.5 billion annual block grant to states for FY1997-FY2002; Congress has
continued the program at this funding level through a series of short-term extensions.
This amount was based on federal funding in the mid-1990s for TANF’s predecessor
programs, and is not adjusted for inflation or for a state’s needs. (The basic $16.5
billion block grant lost 15% of its value over the FY1997-FY2004 period.) In
addition to federal funds, TANF programs receive a financial contribution from the
states under a maintenance-of-effort (MOE) requirement. Like the basic block grant,
the required MOE is based on historical expenditures in TANF’s predecessor
programs (national total of $10.4 billion). The number of families receiving cash
welfare declined by almost 60% from March 1994 to September 2001 and has
remained relatively constant through March 2004, but states have used their flexible
TANF dollars to provide new types of services to welfare and other low-income

Even though TANF caseloads have fallen by 50A large number of thosewho commented called for
percent, it is clear that the need for TANF-increasing the TANF block
supported services has not declined. Federal data
reporting of the TANF caseload reflects only thegrant for inflation. This was a
number of families receiving TANF cash assistancerecommendation of the
in a given state; it does not include families thatAmerican Public Human
receive TANF-funded child care, employment andServices Association (APHSA)
training, counseling, and other supportive “non-that was also reflected in many
assistance” servicescomments from state human
— national association of state welfare agenciesservices agencies as well as
other organizations. Other
national organizations that
recommended adjusting the grant for inflation included the Children’s Defense Fund,
the National Association of Social Workers, and the Child Welfare League of
America. Several Senators, Governor Lincoln Almond of Rhode Island, the
California Legislature and the Washington State Legislature Democratic caucus all
called for adjusting the basic block grant for inflation.
Others who commented suggested an unspecified “increase” in funding. Some
simply argued that funding needed to be maintained. They countered arguments that
the grant should be cut because of the decline in the cash welfare caseload by noting
the expansion of services beyond cash welfare that has occurred under TANF and the
more disadvantaged caseload that remained.
Many organizations and commenters who suggested maintaining or increasing
federal TANF funding also recommended maintaining the MOE requirement at least
at current levels. Some organizations, including APHSA, said that if the TANF
block grant were adjusted for inflation, the MOE requirement also should be
increased. A few state human services agencies (e.g., Maryland) followed the lead
of APHSA on this point, but many were silent. Virginia, under the previous
Governor’s administration, recommended that an MOE based on prior law caseloads
be discontinued.
Other Grants. In addition to the basic block grant, TANF includes a
contingency fund to provide additional funding during recessions, supplemental
grants for certain states with high population growth and/or low historic federal
funding per poor person, and a welfare-to-work grant program to help localities
provide employment services to certain TANF recipients and other groups, including
noncustodial parents. These grants also were the subject of several comments,
although not to the degree that basic funding was discussed.
There was widespread sentiment that there should be a TANF contingency fund
to help states through a recession. Further, there was sentiment that access to the
contingency fund created by the 1996 law was too restrictive. The most common
proposal was to reduce the amount states needed to spend before they could access
the fund. Additional comments requested that the fund be less restrictive, but did not
specify changes that should be made.
Both supplemental grants and welfare-to-work grants were the subject of some
comments, but their constituency was relatively narrow. Supplemental grants are

generally made to states in the South and interior West (the West Coast states of
California, Oregon, and Washington did not receive supplemental grants). Most calls
for renewing supplemental grants came from those states that received them or from
national organizations. Similarly, there were relatively few calls to reinstate welfare-
to-work grants. These grants were generally administered locally, rather than by the
states. The major national organization advocating a welfare-to-work grant program
was the U.S. Conference of Mayors. Also supporting these grants was the National
Child Support Enforcement Association. Generally, state organizations (except the
Iowa Department of Human Services, which recommended that they be continued
and expanded) were silent on whether welfare-to-work grants should be renewed.
Regarding additional TANF grants, some commenters would establish a new
bonus for poverty reduction; some would revise the existing high performance bonus
that rewards states for certain outcomes; and some would eliminate or alter the
existing bonus for reducing out-of-wedlock births. (See additional discussion of
bonus funds under State Accountability section, below.)
Flexibility in the Use of Grants. Under current law, states may expend
TANF funds in any way “reasonably calculated” to achieve the goals of the program.
States also may transfer up to 30% of the federal TANF grant to the Child Care and
Development Fund and the Social Services Block Grant (SSBG). SSBG transfers are
limited to 10% of the TANF grant; this ceiling was set to decline to 4.25% starting
in FY2001 but Congress has maintained the 10% limit through annual appropriations
laws. States also may carry over funds without fiscal year limit, but carried-over
funds can only be used to provide “assistance” (essentially ongoing cash welfare) to
A common theme running through the reauthorization comments was
maintaining state flexibility in the use of grants. However, some advocacy and
public commenters did suggest particular uses of TANF funds, and some even
advocated legislative restrictions on the use of funds by states. Organizations
representing the states often called for continuing the authority to transfer funds (with
the SSBG transfer limit set at 10%, rather than 4.25%), and no “earmarking” of funds
for specified purposes. The suggestion that a portion of TANF funds be set-aside for
promotion of marriage received more negative than positive comments, including
from advocacy organizations and others. It was common to suggest that if Congress
wished to emphasize a particular goal or set of activities, additional funds (rather than
set-asides from current funds) should be provided.
The four purposes [of TANF] along with theThe states and otherssometimes sought more
flexibility granted to states resulted in a
remarkable transformation of welfare programs.flexibility in the use of funds,
With an economic downturn evident and caseloadsparticularly asking for the
on the rise, the last thing states need is a moreability to use carry-over funds
prescriptive program. Keep the purposes and thefor any TANF activity (instead
flexibility.of just cash welfare).
— member of the publicGenerally, this was not
(no further identification)opposed. However, the Center
on Budget and Policy Priorities
commented that states should

have the ability to reserve only a “limited” amount of TANF funds (50% of the block
grant), and be required to spend additional grants within three years.
The states and advocacy groups split on the issue of “supplantation;” i.e., use
by states of federal TANF dollars for activities that are allowable under TANF law
to achieve its broad goals, but which were previously paid for with state funds. A
large number of advocacy organizations and commenters — both national and at the
state and local levels — recommended legislation to prohibit supplantation. The
states, by and large, opposed this effort as a restriction of their flexibility in using
TANF dollars.
There also were some general comments about the use of funds, particularly
advocating an increased emphasis on the use of TANF for certain activities. These
comments were not always phrased as legislative recommendations, and sometimes
suggested that TANF be used for activities that are already allowable by law, or
commended states for using funds for these activities. For example, there were
comments on the expanded use of TANF funds for Individual Development
Accounts, supplements to the Earned Income Tax Credit (EITC), economic
development or job creation, development of model programs, and services to
address the needs of families with barriers to self-sufficiency. A few urged that
TANF grants be allowed to fund foster care and adoption. Some suggested that
TANF funds, which now cannot be used for medical services, be permitted for some
medical services payable under Medicaid, such as behavioral or mental health
assessment. Several commenters requested that treatment for alcohol and drug abuse
be exempted from the definition of “medical services” to facilitate use of TANF
funds for them. One state said that TANF should provide a specific amount for
intensive family development services.
Program Requirements
Federal law gives states flexibility in the design of their welfare programs,
within certain federal parameters. For example, the welfare law prohibits the use of
federal funds to provide ongoing cash welfare to a household with an adult who has
received benefits for 60 months. States may exempt up to 20% of their caseload
from this time limit, and they also may establish shorter time limits. States also can
use their own funds to serve recipients beyond the federal time limit. States also
establish their own eligibility rules; however, federal funds cannot be used to serve
certain categories of individuals (e.g., specified groups of noncitizens, certain felons,
unwed parents under 20 unless they comply with certain requirements). Furthermore,
while states design their own programs, federal law requires states to engage a certain
percentage of their caseload in work activities (referred to as the work participation
rules). The law specifies which activities “count” toward this requirement, and
clearly emphasizes “work first” before education and training or other types of
activities. These and other program requirements were the subject of many
comments, some of which advocated additional federal requirements (more extensive
applicant screening, for example). In general, these comments did not come from
states or organizations representing states, which tended to favor flexibility at the
state level.

Time Limits. Comments showed overwhelming support for liberalization of
the current law five-year limit on federally funded ongoing cash aid. Proposals
included suspending the time limit for persons who comply with program
requirements; increasing the hardship exemption (from the current 20% of caseload
limit); requiring or allowing states to suspend the time limit for working recipients;
and allowing or requiring extensions in times of high unemployment. Some
recommended that certain caregivers be categorically exempted from the time limit.
Some proposed to prohibit state time limits shorter than 60 months, and a few
proposed to lengthen the federal limit.
Eligibility Rules. Three categorical eligibility rules received comment: the
ban on federally funded TANF payments for immigrants during their first five years
of residence (discussed in more detail in the section on Noncitizens below); the
prohibition on TANF for persons convicted of a drug-related felony (unless the state
opts out by state law); and the ban on TANF aid to an unwed mother under age 20
who does not live with an adult (with allowance for good cause exceptions). Those
who commented recommended repeal of all these restrictions. Some also
recommended that states be barred from imposing a “family cap” on benefits (paying
no benefit or a reduced amount on behalf of a new baby born into a TANF family).
Existing law is silent on this issue. Many urged that eligibility and benefit policies
not be allowed to discriminate against applicants or two-parent families. Many
proposed that the federal government require that states pay a specified minimum
benefit, and some proposed that states be required to base benefits on “real need” and
to index them for inflation.
Work Rules. The National Governors Association was among many
commenters who urged that states should have greater authority to determine work
activities that are countable toward federal requirements. Among the numerous
persons who commented on TANF work activities, there was overwhelming support
for allowing more “human capital” activities (education and training) to be credited
toward the work participation requirements and for lifting restrictions on creditable
vocational educational training. (Under current law, participation in education —
completion of high school and vocational educational training — can account for no
more than 30% of persons credited with work, and vocational educational training
is countable only for 12 months.) Numerous persons urged that “rehabilitative
activities,” such as participation in treatment for substance abuse, mental illness, and
domestic violence, be counted as a work activity. Many recommended that domestic
duties (caring for a disabled or ill family member, for example) be treated as a
countable work activity. Further, some urged that job search be a countable activity
for longer than six weeks.
Rhode Island and Arizona said federal work participation rates should be
dropped. Utah called them administratively burdensome and not instrumental to
success. Virginia and New Hampshire, and the American Public Human Services
Association, said participation rates should be replaced by outcome measures of
success. Another state suggested that partial credit should be allowed for persons
working fewer hours than the weekly minimum (now 30 for most families). Some
persons urged elimination of the higher participation rate for two-parent families
(90% vs. 50% for “all” families). Many commenters urged that participation rates
be suspended or reduced for times and areas of high unemployment. Some urged that

the caseload reduction credit be ended or modified (this credit reduces state work
participation rates by one percentage point for each percent reduction from 1995
levels in the state’s average monthly caseload; its effect in 2002 was to lower to zero
the effective participation rates in 21 states). A few commenters sought to have
Congress exempt certain persons (parents with a child under four, with a child under
one, with multiple barriers to work) from both work requirements and the calculation
of participation rates. One state recommended that any persons exempted by the state
from work should be disregarded in calculating official participation rates.
Assessments. Concerns about TANF participants with multiple barriers to
employment were raised frequently by commenters, including those who addressed
the law’s provisions regarding assessments. Under current law, the state agency
responsible for administering the TANF program is required to make an initial
assessment (within 90 days of determining that an individual is eligible for TANF
benefits) of the skills, prior work experience, and employability of each TANF
recipient who is at least age 18 or who has not completed high school or obtained a
certificate of high school equivalency, and is not attending secondary school. On the
basis of the assessment, the state TANF agency has the option, in consultation with
the recipient, to develop an individual responsibility plan for the recipient. The
manner in which assessments are performed varies across states; for example, some
states simply have a form for recipients to fill out, others have an in-depth
questionnaire, some have caseworkers conduct cursory interviews with recipients,
while others use specialized staff (such as a substance abuse specialist) to perform
All states must be required to implementMany respondentsproposed that states be required
mandatory screening and assessment for barriers
to TANF participants, especially those related toto screen all applicants, assess
mental health, substance abuse, and domestic andtheir employability, and
sexual violence.determine whether they have
— social work student (recommendation ofbarriers to employment. The
national advocacy organization campaign)commenters usually mentioned
the following as barriers to
employment: being a victim of
domestic or sexual violence, mental health problems, physical disabilities, substance
abuse problems, and limited English proficiency. Many of the commenters also
wanted to mandate that states provide the appropriate types of services to help
recipients deal with their employment barriers. Many commenters maintained that
caseworkers needed more specialized training to properly screen recipients; some
suggested that qualified professionals be used to screen recipients and perform
assessments. In general, the commenters supported requiring states to do more to
protect vulnerable families with multiple barriers to employment. They urged that
states serve and “protect” the most vulnerable and provide more help for those with
severe work handicaps. Consistent with this concern, many commenters wanted
states to perform additional assessments before sanctioning a family.
Additional comments on this topic were mentioned by only one or two groups
or individuals. Recommendations included establishing panels to identify
appropriate strategies for dealing with persons with multiple barriers to employment,
providing referral information to vulnerable families if the TANF agency could not

provide the needed service, performing assessments on recipients annually, extending
the “family violence option” (which requires screening and referral to services for
victims of domestic violence) to other employment barriers, offering mentoring
programs to vulnerable families, providing extra funding to reduce language barriers
(including hiring staff that speak Spanish, etc.), providing family needs assessments
as well as vocational assessments, and extending assessment services to noncustodial
parents of TANF children.
Sanctions. Sanctions are financial penalties for failure to comply with work
or other requirements of the state TANF programs. Under current law, states must
impose sanctions on families that refuse, without good cause, to participate in
required work activities. States also must impose sanctions on individuals who fail
to cooperate without good cause with Child Support Enforcement (CSE)
requirements, and on teen parents who fail to comply with school attendance and
living arrangement requirements. In addition, states may sanction families that are
not complying with their individual responsibility plans (which can include
requirements that custodial parents attend school, maintain certain grades and
attendance, ensure school attendance of their school-aged children, obtain proper
immunizations for their children, attend parenting and money management classes).
In general, states have considerable flexibility in the design of their sanction policies
(e.g., size of the sanction, exemptions from sanctions, etc.).
Full family sanctions should be prohibited,Most persons commentingon sanctions urged that
realizing children receive the worst impact of suchCongress prescribe sanctioning
— state advocacy organizationprocedures. Some
recommended that full family
sanctions, in which the entire
cash grant is eliminated, be prohibited, at least for a first violation. Most of the
commenters maintained that recipients should be assessed or screened before
sanctioning occurred. These commenters generally said that states should be required
to review cases, and to acknowledge and address severe or multiple employment
barriers before families are allowed to lose TANF benefits. Moreover, some of these
commenters argued that vulnerable families with severe work barriers should not be
sanctioned as long as they are participating in a program or receiving a service to
ameliorate their barriers. Many respondents wanted to ensure that due process
concerns (e.g., timely notice, a reassessment, fair and nondiscriminatory practices,
and opportunity for a fair hearing) were adequately addressed before sanctions were
imposed. Numerous respondents supported expansion of the existing federal child
care exemption (for caretakers of children under age six) to include older children
(school-age children, adolescents, disabled children). Some also proposed that “good
cause” for work refusal should include lack of transportation, lack of quality child
care, and suffering from a serious impairment (substance abuse, mental illness,
domestic violence) or being in treatment for the impairment. In contrast, several
commenters stated that strict sanctions, such as full family sanctions, are needed to
ensure that families comply with program requirements. One state welfare agency
maintained that states should continue to have the right “to design penalties as they
see fit.”

Additional comments on sanctions, mentioned by only one or two groups or
persons, included support for funding of programs to increase compliance and reduce
the need for sanctions, such as home visiting programs; giving families more
opportunities for compliance before a sanction is actually imposed; using a protective
payee approach rather than a full family sanction; ending sanctions immediately after
a family complies with program requirements; and eliminating sanctions altogether.
Treatment of Special Groups
Domestic Violence Victims. Some commenters urged that the protections
for domestic violence victims under the “family violence option” (now adopted by
44 TANF jurisdictions) become mandatory, and several proposed that states be
required to adopt specific procedures for serving victims of domestic violence,
including counseling for noncustodial fathers, education on domestic and sexual
violence, and mandatory caseworker training.
Teen Parents. Few persons commented on teen parent rules, but of those who
did, most favored ending the requirement that they live under adult supervision, and
some favored dropping the requirement that they attend school. Some proposed that
the federal time clock not commence until these parents reach age 20, and one law
center said states should have full authority to develop programs for teen parents.
Mothers of Young Children. Various individuals suggested exempting
mothers from work requirements for a time after their youngest child reached age one
(the current outer limit in federal law). The several proposals were to lift the
threshold to age one, age three, age four, or age eight and in each case to exclude the
exempted mothers from the calculation of work participation rates. One person said
all states should be required to adopt a uniform age of youngest child at which the
parent would be required to work.
Nonparental Caregivers. Among the persons commenting on rules and
benefits for nonparental caregivers of TANF children, all but one favored a federal
rule exempting the caregiver from the time limit; most also favored exempting the
caregiver from the work requirement, and three said states should have the option to
decide these issues. Under current law, a caregiver who receives TANF-funded
assistance on his or her own behalf is subject to TANF’s work and time limit rules.
(Also see comments on Child Welfare, below.)
Rural Issues. A small subset of commenters focused mainly on rural issues;
a few other commenters included recommendations about rural recipients within their
more general comments about TANF. Among comments focused on rural issues,
there was general agreement about the difficulties faced by rural welfare recipients.
Transportation and child care were two areas that, while seen as problems for TANF
recipients in general, are viewed as much worse for rural TANF recipients.
Recommendations included providing transportation assistance (such as car-buying
programs), allowing child care to count as a work activity for mothers with children
up to age two, and counting travel time toward work participation hours.

Indian Tribes. Several states with Indian populations (including at least one
that contributed state funds to tribal programs and received TANF maintenance-of-
effort credit for the spending) said tribal block grants should be fully federally
funded. Two tribes advocated tribal access to bonus and contingency funds, and also
recommended that TANF funds and programs be better coordinated with other
federal tribal workforce development programs. Two groups proposed that a tribal
employment services program be established to replace the current Native
Employment Works program. One tribe said a poverty level should be developed
specific to tribes, and one group said all participants in a tribal work program should
be exempt from work participation calculations. Five commenters advocated giving
Indian tribes technical assistance to support their infrastructures.
State Accountability
Federal TANF law establishes program goals, provides states with funding for
activities to achieve these goals, and has penalties and bonuses to enforce
requirements and reward high performance. States are required to submit to HHS a
plan of the program they intend to operate, and report data to HHS on the
characteristics, work, and job preparation activities of cash welfare recipients. These
documents and data reports provide HHS and Congress with information to help
monitor states’ progress toward achieving the goals set forth in TANF. The
following section discusses comments on TANF bonuses and data reporting
Bonuses. Current TANF law provides for two bonuses: one for reducing out-
of-wedlock births (with reduced abortion rates); and a “high performance bonus.”
There was little comment on the efficacy of providing bonuses as a means of
encouraging states to design programs to meet federal goals. Rather, comments
generally focused on support or opposition to particular bonuses or criteria for
awarding bonuses.
As discussed in the section on program goals and philosophy, one of the most
common comments was to establish reduction in poverty as a TANF goal. Many of
those who made that recommendation also suggested that a poverty reduction bonus
be added to TANF. Few state groups made this recommendation, with the exception
of New York, which commented that any use of child poverty as a measure of
meeting program goals should be in a positive framework, such as a performance
bonus. However, recommendations for a poverty reduction bonus came from the
broad spectrum of those who sought to incorporate poverty reduction as a goal of
TANF (national and state and local advocacy organizations, faith-based groups,
community service organizations, and members of the general public).
There were a number of suggestions to abolish the current bonus for reducing
out-of-wedlock births. Some suggested that these bonus funds be put to other uses.
For example, the Center on Budget and Policy Priorities recommended replacing this
bonus with a fund to conduct research on policies that could enhance the well-being
of families with children. The NOW Legal Defense and Education Fund suggested
replacing the out-of-wedlock birth bonus with a poverty reduction bonus, and the

Minnesota Department of Human Services recommended moving its funding to the
high performance bonus.
The comments on the high performance bonus generally related to specific
criteria used to measure performance and award bonuses. Minnesota’s Department
of Human Services suggested eliminating the measures that award part of the bonus
based on coverage of the Food Stamp and medical assistance programs. A number
of commenters suggested adding additional measures to be rewarded, such as
employment in jobs that pay a certain wage, job advancement, effectiveness of
services for different groups (e.g., racial ethnic groups/people with disabilities/low-
income communities), and reductions in homelessness.
Information and Data Reporting. Sharp divisions appeared in the
comments between state groups and others who addressed the subject of information
available about state programs and data reporting. Advocacy groups typically
requested more information and more data. States generally opposed adding to
existing data reporting requirements and some suggested reducing existing
Among the state human services agencies that commented, additional reporting
requirements were unanimously and adamantly opposed. There were calls to
streamline and simplify existing reporting requirements. Concerns about the impact
of any additional reporting requirements on state computer systems (e.g., changes to
large computer systems necessary to comply with requirements) and a desire that
reporting also be separately financed was voiced in the comments.
Other commenters — particularly advocacy organizations — requested more
information about state programs. For example, some commenters proposed that
state TANF plans be required to include new provisions. Suggested as mandated
plan provisions were: procedures for civil rights complaints; a description of how
the state (and the county, in county plans) will function as a partner in the Workforce
Investment Act (WIA) one-stop center and how funds will flow; a report on what
strategy will be used to help families with limited English proficiency; a description
of how states will enter into cooperative agreements with state vocational
rehabilitation agencies to be sure that TANF parents are assessed for “hidden
disabilities” before being required to work; and a description of how states will
assess the needs of kinship families.
The Center on Budget and Policy Priorities suggested that the HHS annual
report to Congress include more detail on state program rules. Better reporting of
how federal and state funds are spent was also requested by a number of groups. A
large number of commenters urged that states make data publicly available, with
information provided by race and ethnicity to ensure that services are provided on an
equitable basis.
Administration. A number of additional comments related to state
administration were received. For example, some persons said that states should be
required to accept TANF applications immediately and unconditionally. Some urged
that states use a planning process that includes input from the public, and that HHS
monitor compliance with this rule. (Current law requires that a summary of any plan

or plan amendment submitted to HHS be made available to the public.) Several
commenters urged that states be required to make sure that caseworkers are
adequately trained. With regard to federal administration, one state urged that
regulations be kept to a minimum.
Equitable Provision of Services and Benefits. A sizeable number of
national, state and local advocacy groups addressed the need to ensure fair and
equitable treatment of TANF recipients and applicants. These comments concerned
fair access to TANF benefits and services, as well as equitable treatment for TANF
recipients. In general, commenters sought to ensure that civil rights and labor law
protections applied to TANF recipients. And, together, they listed a wide variety of
conditions, characteristics or statuses that they asserted should not be a factor in
access to or receipt of TANF benefits or services. These include applicant or
recipient status, mental or physical disability, marital status, race, gender, ethnicity,
sexual orientation, criminal record, immigration status, and primary language.
Within the context of ensuring equitable access to all, some commenters
specifically mentioned the need for language-appropriate services, education, and
welfare-to-work services that meet the needs of all TANF recipients. Many of these
commenters also asked for greater attention to compliance with labor and civil rights
laws, as well as with the Americans with Disabilities Act, including specific data
reporting on benefits and services provided by race, gender, and other categories.
Summary of Comments on Related Programs
Child Care
Many commenters focused on child care issues affecting low-income families,
and provided recommendations with respect to the reauthorization of the Child Care4
and Development Fund (CCDF), as well as TANF. Both of these federal block
grants support child care for low-income families, but only the CCDF is dedicated5
solely for that purpose. As a result, recommendations for changes in funding and
program requirements usually applied to the CCDF, but not always. In some cases,
commenters called specific attention to TANF’s role in supporting child care services
and suggested changes to the federal TANF law (i.e., requiring that TANF-funded
child care meet the same health and safety standards of CCDF-funded child care).
At the broadest level, the comments reflected a desire to improve the availability,
affordability, and quality of child care. The suggested means for achieving those

4For a comparison of child care legislation approved by the House and Senate Finance and
HELP Committees in the 108th Congress, see CRS Report RL32241, Child Care
Reauthorization: A Side-by-Side Comparison of Child Care Provisions in H.R. 4, S. 880,
and Current Law, by Melinda Gish.
5 The term “CCDF” refers to the combination of mandatory and discretionary funding that
is used to administer programs under the rules of the Child Care and Development Block
Grant (CCDBG) Act. In this report, “CCDF” is used not only as a funding term, but also
to encompass all rules and regulations under which those funds are administered.

improvements generally involved making changes with respect to CCDF funding,
program requirements, and data collection.
Funding. The most frequently submitted comment with respect to child care
called for increasing CCDF funding. Many commenters specifically recommended
increasing the mandatory portion (CCDF is funded through a combination of
mandatory and discretionary grants. Total CCDF funding appropriated for FY2005
amounts to $4.817 billion, with the mandatory portion comprising $2.717 billion —
these amounts have been roughly unchanged since FY2002.) Commenters of all
types expressed the sentiment that funding for child care has fallen short of the need,
and that increasing CCDF funding would help move toward serving all eligible
children and help improve overall child care quality.
Funding for child care has fallen short of the trueIn addition to increasingthe overall funding available for
need. Waiting lists for child care programs are
common and place our most vulnerable children inchild care, many commenters
substandard care.... [Fund] more slots and [set]favored raising the percentage
higher income guidelines.of CCDF funds that states are
— community service organizationrequired to set aside specifically
for promoting quality activities.
Under current law, 4% of
CCDF funds must be dedicated for this purpose, and many commenters expressed
support for raising that percentage to 12%. Likewise, several commenters advocated
increasing the funding reserved for infants and toddlers. Comments that deviated
from promoting these set-asides came from at least two organizations which, while
supporting an increase in overall funding, oppose additional set-asides in favor of
greater state flexibility in their use of CCDF funds. One research/advocacy
organization emphasized that while they do support providing additional resources
for the quality set-aside, it should not reduce the current level of funding available
for actual child care slots.
Aside from funding levels and set-asides, a number of commenters expressed
support for simplifying CCDF rules for states’ obligation and expenditure of funds,
by making the time periods for doing so identical regardless of CCDF funding
Program Requirements. Most of the comments that called for changes in
CCDF program requirements reflected those commenters’ lack of satisfaction with
the availability of quality child care, both during standard work hours, and weekend
and evening care. Numerous comments expressed the sentiment that one way to
improve child care quality is “to improve compensation for providers and to help
them get additional education.” However, only a few of those commenters
mentioned dedicating specific funds for this purpose (i.e., a set-aside). Several
individuals and organizations called for requiring that all providers receiving CCDF
funds have training in childhood development before caring for children. Moreover,
some commenters recommended using provider payment rates as a means of
improving quality of care. Each of these commenters suggested the federal
government “require states to pay the full market rate [as opposed to the 75th
percentile suggested in CCDF regulations] for child care, and higher rates for care
that is of higher quality, limited supply, for children with special needs, and children

in low-income communities.” With respect to the providers who receive public
funds, many commenters said that they should be subject to at least two mandatory,
unannounced visits a year.
Several commenters recommended a requirement that every community have
access to child care resource and referral agencies. Many comments also expressed
support for simplifying the application and recertification process for parents. The
most common recommendation in this area was to require certification for CCDF
subsidies no more than once a year, so that the recertification process would be less
likely to present a barrier to receiving subsidies.
Data Collection. Those submitting child care comments overwhelmingly
recommended additional funding, citing a need to improve child care availability,
affordability, and quality. However, many acknowledged a lack of comprehensive
national data to illustrate the needs they describe. Several comments included
identical language calling for a national data collection initiative to gather
information on child care supply and demand, as well as quality available to low-
income families.
TANF-Funded Child Care. Several commenters who addressed child care
issues suggested two TANF-related modifications. The first, alluded to earlier,
would require that the health and safety standards applicable to CCDF child care
providers also apply to providers receiving funds directly from TANF. Under current
law, TANF funds transferred to the CCDF are required to be spent according to the
CCDF rules, but TANF funds spent for child care directly within the TANF program
are not. The second modification relating to TANF child care concerns the definition
of “assistance” under TANF. Under current law, TANF program requirements (i.e.,
work requirements, time limits) are triggered when TANF money is spent on
“assistance” as defined by HHS in regulation. Whether child care is classified as
“assistance” depends on the individual situation. For example, child care for a
working person is not assistance and would not trigger TANF requirements, whereas
child care for a nonworking person, such as a cash welfare recipient in a training
program, would be categorized as “assistance” and thus trigger TANF requirements.
Several commenters suggested that child care should not be counted as “assistance”
under any circumstances.
Child Support Enforcement6
Most of the individuals or groups that made comments on the Child Support
Enforcement (CSE) program were interested in getting more child support to
children. They wanted child support collections to be paid to former TANF families
first, before the state or federal government could claim for their own expenses any
child support arrearage payments (as required under current law, up to the amount of
TANF benefits that had been paid to the family).

6 For a comparison of child support provisions passed by the House and Senate Finance
Committee during the 108th Congress, see CRS Report RL32258, Child Support
Enforcement: Side-by-Side Comparison of Current Law and Two Versions of H.R. 4, by
Carmen Solomon-Fears.

Child support payments should benefit the child,In addition, they wantedsome of the child support
not the state or federal government. One of the
reasons that low-income fathers do not pay childcollected on behalf of current
support, or do not pay it on the record, is becauseTANF families to be passed
when their child receives TANF assistance, theirthrough to the families and
child support will be used to reimburse the statedisregarded in determining the
rather than to support the child.family’s TANF benefit amount.
— national advocacy organizationSome of these commenters
stated that the current law
requirements regarding the
federal share should be eliminated. In other words, they maintained that states should
be able to pass through and disregard a portion of child support collected on behalf
of a TANF family without having to reimburse the federal government. Most
commenters did not put a dollar amount or percentage on how much child support
should be passed through and disregarded, and only a minority said all of the child
support collected for a TANF family should be passed through and disregarded. A
few commenters said that states should be rewarded with monetary incentives for
providing more child support to TANF families. Several commenters suggested that
the child support passed through and disregarded should be counted as state MOE
funds or that TANF funds be used to help support the child support pass-through.
Another frequent recommendation was to repeal the existing federal requirement
that TANF applicants and recipients cooperate in establishing paternity or obtaining
support payments. These commenters generally argued that if the custodial parent
did not want to pursue child support, it usually was because of a legitimate reason.
Moreover, several commenters wanted to eliminate the current law provision that
requires TANF recipients to assign their rights to child support to the state.
Several commenters mentioned financing of the CSE system. Some wanted to
maintain the current general federal matching rate of 66% of state expenditures on
CSE activities, and the 90% federal matching rate for the laboratory costs of paternity
establishment. A couple of commenters wanted the enhanced automated systems
matching rate, which was 80% of a capped amount, reinstated until October 2005.
Other commenters wanted a 90% federal matching rate for costs associated with
medical support. A few commenters wanted to eliminate or adjust the current law
cap on incentive payments to the states, which requires states to compete among each
other for a fixed amount of funds.
Convene a panel of noncustodial parentOther comments, whichwere raised by only a few
organizations to seek their advice on how TANF,
CSE, child care, and related programs can bestpeople, called for additional
serve them and their children.funding for visitation programs
— men’s advocacy organizationin which noncustodial parents
would have more access to their
children, the development of
fatherhood programs, a requirement that unemployed noncustodial parents participate
in welfare-related work programs, the transfer of the administration of the CSE
program from the states to the Internal Revenue Service, and the initiation of a
forgiveness program which would allow noncustodial parents who consistently paid
their child support obligations on time to not have to pay a specified percentage of

their child support arrearages. In addition, there was concern about the need to do
more to enforce the child support obligations of higher-income noncustodial parents,
the need for more collaboration between the CSE agencies and the TANF agencies,
increased communication among the states, the need for states to properly distribute
undistributed child support collections, and the need for states to better use the tools
available to them for the enforcement of child support.
The subject of Medicaid drew comments from a relatively small number of
persons. The predominant Medicaid recommendation was that eligibility should be
extended to cover working parents without other health insurance coverage. The next
most common recommendation was for some form of general health care coverage,
at least for families with children. One proposed that Medicaid be converted into
“universal coverage” for those with income below 200% of the federal poverty
guideline. Some sample comments: “Provide a national health care plan (or at least
permit low-wage employees to ‘buy into’ Medicaid).” “Provide new funding,
incentives, and authority to states to expand health insurance coverage.”
Some persons mentioned transitional Medicaid assistance (TMA).7 The TMA
provision, which requires l2 months of coverage for families whose earnings end
their TANF eligibility, expired on September 30, 2002, and has been extended
through a series of temporary measures, along with TANF. Most of the commenters
said TMA should continue to provide at least one year of coverage; two said it should
be automatic and another that its reporting and income rules should be abolished.
Some recommended that the length of TMA be doubled to 24 months (one at state
option), and two urged that Medicaid be extended indefinitely to ex-TANF recipients,
without time limit. One urged that application for TMA be consolidated with
application for food stamps and child care.
A few groups urged revision of basic Medicaid eligibility rules. A poverty law
center recommended that Medicaid eligibility be relinked to TANF (conferring
automatic Medicaid coverage on TANF recipients). The Minnesota Department of
Human Services said states should have authority to “align Medicaid with TANF
eligibility,” and be allowed to adopt a two-tiered system, with separate eligibility
standards for TANF and non-TANF families. The County Welfare Directors
Association urged that states be given the option to extend Medicaid (and the state
Children’s Health Insurance Program [SCHIP]) to noncustodial parents who are
paying child support. One commenter urged a new “federal eligibility floor” for
Medicaid. Three commenters recommended that Congress end the ban on Medicaid
reimbursement for residential alcohol and drug treatment programs.
A law center said states should be required to “act affirmatively” to ensure that
persons eligible for Medicaid and SCHIP receive those benefits, and a legal aid group
urged that procedures be established to ensure that eligible prisoners are enrolled in
Medicaid when they leave prison or jail.

7For information on this program, see CRS Report RL31968, Transitional Medical
Assistance (TMA) Under Medicaid, by April Grady.

Food Stamps8
Among those who commented, there were a number of calls for unspecified
“strengthening” of food stamps, and making the program a more effective “safety
net” for low-income families. Such comments, and those proposing an increase in
either food stamp funding or benefit amounts, were typically made by advocacy and
faith-based organizations or the general public. Some persons associated with state
human resource agencies expressed opposition to creating a block grant to replace
the existing Food Stamp Program. The Progressive Policy Institute recommended
that Congress “radically rethink” the Food Stamp Program’s place in a network of
supports for working families.
Additionally, there were comments from the American Public Human Services
Association (APHSA), states human resource organizations, or state organizations
suggesting simplification and a streamlining of food stamp rules. There were a few
calls to de-emphasize the program’s administrative emphasis on reducing error rates.
Child Welfare
A limited number of commenters made recommendations that dealt with child
welfare services and/or the interaction between TANF and child welfare services.
Clarify [the] law to permit the use of TANF fundsGenerally, children whoreceive a TANF benefit and are
to provide support services, including child care,
to kinship caregivers of TANF-eligible children,cared for by a non-parent
without regard to income...”relative (e.g., grandparent or
— state association of county welfare agenciesaunt) would, in the absence of
this kin care, be in state
protective custody (foster care).
Commenters, who ranged from national research/advocacy groups and county
welfare directors to community service organizations and social work students, called
for fewer requirements and greater access to support services for kinship care givers.
(See Treatment of Special Groups — Nonparental Caregivers, earlier in this
report, regarding exemptions from TANF requirements.) A number of commenters
also advocated for kin caregiver’s access to other kinds of support, such as child care
assistance, respite care, and food stamps, and a national advocacy organization
suggested that states be required to provide information in the TANF state plans
about how they will assess and serve the needs of kinship families.
Under the 1996 welfare reform law (as amended in 1997), a state may claim
federal reimbursement of certain foster care and adoption support expenses only if
the child on whose behalf the funds were spent was removed from a family that
would have been eligible for AFDC (as it existed on July 16, 1996). A few
commenters, primarily state and county human services agencies — or groups who
advocate for them, proposed severing this relationship between the now-repealed

8Food stamp amendments were enacted in 2002, after these comments were submitted. For
a summary of food stamp provisions in the 2002 Farm Act, see CRS Report RL31195, The

2002 Farm Bill: Overview and Status, pp. 18-21.

AFDC program and federal foster care and adoption assistance. They recommended
basing eligibility on a child’s need alone, or letting states set their own income
eligibility levels (e.g., up to 200% of the federal poverty level). Some commenters
also took the opportunity to call for greater funding or increased flexibility in the use
of other child welfare funds. Recommendations included increased funding for the
Promoting Safe and Stable Families Program, directing some federal spending from
foster care and adoption assistance to more preventive child welfare services, and
modifying restrictions on certain funds to improve coordination between child
welfare services and TANF.
Other Programs
Numerous commenters understood TANF as one component of a broader social
safety net, and as a result, promoted increased support for a variety of other programs
and laws designed primarily to assist low-income individuals and families. These
include the Earned Income Tax Credit (EITC), Unemployment Insurance, the Social
Services Block Grant (SSBG), the Community Services Block Grant (CSBG), the
minimum wage, and housing assistance. Public state and local human service
agencies were among the commenters on SSBG but most additional
recommendations concerning “other programs” came from advocacy groups,
community service organizations, labor unions, and the general public.
Earned Income Tax Credit. Among the community service providers, local
and national advocates, legislators, researchers, and others who commented on the
EITC, there was near unanimous support for an expanded or increased federal EITC
benefit. (A few commenters only referenced encouragement of state EITC
programs.) Specifically, commenters suggested making the benefit more valuable
for married couples and families with more than three children, and one suggested
making it available to primary wage earners who are attending school/training. The
Heritage Foundation suggested increasing the value of the credit for married couples
with children, as well as the income range in which the credit is available for such
working couples.
Unemployment Insurance. Advocacy organizations at the community,
state, and national level (including faith-based organizations), and others commented
on the need to reform the federal-state unemployment insurance system. Overall,
they asked that the system provide greater security for part-time and low-wage
workers in general, and for former TANF recipients in particular. A state advocacy
organization recommended that unemployment insurance cover former TANF
recipients who are no longer eligible for TANF but who have worked at least half-
Social Services Block Grant. Nearly all of the commenters who wrote
about the SSBG called for full or historic level funding (which they variously defined
as $2.38 billion or $2.8 billion) and many asked that the current option, which allows
states to transfer up to 10% of their TANF money into the SSBG, be maintained.
Support for a “fully funded” SSBG came from a variety of groups, including state
and local human service agencies, national and state advocacy groups, faith-based
organizations, a labor union, Indian tribe, professional associations, and others.

Community Services Block Grant. A very small number of commenters
addressed the Community Services Block Grant. They asked that funding for this
block grant be increased, that states be allowed to transfer TANF funds to this block
grant, and/or that services funded under TANF and CSBG be better coordinated.
Minimum Wage. A number of commenters included recommendations about
increasing the minimum wage as part of their general TANF comments. Of those
who mentioned the minimum wage, the majority wanted an unspecified increase to
a “living wage.” However, there were several commenters who wanted a specific
increase of at least $1.50 per hour.
Housing. Advocacy groups and faith-based or other community service
organizations were the primary commenters who addressed housing concerns; they
sought greater attention to housing needs as part of TANF program planning. Citing
adequate and stable housing as essential to the achievement of self-sufficiency, many
called for an increase in spending for, or creation of, affordable housing (including
use of TANF or other funds). A few suggested developing “service-enriched”
housing for TANF clients who have multiple or severe barriers to employment. The
Wisconsin Governor and State Legislature separately were among the several
housing commenters who asked that TANF dollars be allowed for use as ongoing
supplemental rental assistance (and that this support be treated as “non-assistance”).
TANF participants must have stable residentialIn addition, to give statesan incentive to address housing
situations before they can secure and handle
employment.issues as part of their TANF
— state advocacy organizationprograms, some commenters
suggested tying a part of the
high performance bonus to a
reduction in homelessness or, separately, to specific criteria that would measure
housing stability among families who are TANF income-eligible. Finally, some of
those who commented on housing issues urged more effective coordination of
services designed to promote self-sufficiency and job mobility among housing
assistance and TANF recipients; they also called on HHS and the Department of
Housing and Urban Development (HUD) to develop uniform data collection methods
for TANF recipients who receive housing assistance.
Summary of Comments on Cross-Cutting Issues
Title IV of the 1996 welfare reform law restricted legal immigrant eligibility for
several social service programs, including TANF, Supplemental Security Income
(SSI), Medicaid, and food stamps. Under the 1996 law, legal immigrants entering
the country after August 22, 1996, are ineligible for TANF for a five-year period.
States may use federal funds to provide assistance to some groups of legal
immigrants, including certain refugees and asylees (for five years after their entry into
the country), residents with 10 years of work history, and veterans of the U.S. armed
forces and some members of their families. Federal funds also can be used to assist

legal immigrants who entered the country before the cut-off date or after they have
been in the country for five years. In addition, states may choose to assist other
categories of noncitizens with their own funds. Some of the prohibitions on
noncitizen eligibility, especially for SSI and food stamps, have been loosened since
1996, but generally, legal immigrants’ eligibility for federal public assistance
programs remains very restricted.9
Among those commenting
Immigrant children should have equal access toon immigrant eligibility for
basic assistance, food stamps, health care, fosterTANF and related social
care and social services, public education andprograms, there was almost
housing, regardless of the immigrant status of theuniversal support for loosening
child or the child’s parents.the restrictions that were
— national legal advocacy organization
established in 1996. A large
number of commenters made
recommendations to repeal all restrictions on legal immigrant eligibility for social
programs (TANF, food stamps, SSI, and Medicaid). Additional commenters
recommended ending the ban on immigrant eligibility for individual programs,
primarily food stamps and TANF. Only a few commenters wanted to retain the
current restrictions, or place additional restrictions on immigrants’ access to public
benefits, or make legal immigrants completely ineligible. “Immigrants need our help
and assistance,” said a social work professor. “This country will be stronger and
better functioning with the support of our immigrants.”
Program Coordination
Although the main purpose of HHS’s request for comments was to gather input
on TANF, the Federal Register notice also requested comments on program
coordination between TANF and other benefit programs for low-income families.
Food stamps, child care, child welfare, and child support enforcement all were
mentioned specifically in the notice. Recommendations regarding each of these
specific programs have been discussed above. However, the range of comments went
well beyond these individual programs, and covered issues related to the overall
social safety net for low-income families and families leaving welfare.
There was general support from commenters for improving coordination
between TANF, the Food Stamp Program, and Medicaid. The recommendations
provided by commenters addressed improvements in both the systems and the rules
for these programs. Most commonly, commenters supported modifying eligibility
rules and aligning income and resource rules across programs. To improve the
systems, commenters suggested cross-training for case workers, simplifying
applications, providing more hours for interviews and recertifications, automatic
eligibility for multiple programs, automatic transitional benefits for those leaving
welfare, and improved outreach to inform people of their potential eligibility.

9For further information and current legislative proposals, see CRS Report RL31114,
Noncitizen Eligibility for Major Federal Public Assistance Programs: Policies and
Legislation, by Ruth Wasem.

Giving states the flexibility to align program goals,Several commenters alsoadvocated more integration of
eligibility requirements, and outcomes across
programs would allow states to more effectivelyTANF and Workforce
serve low-income families.Investment Act programs.
— state welfare agencyOther programs mentioned
included public housing,
vocational rehabilitation, and
child welfare programs. These comments came from a wide range of individuals and
groups, including advocates and state human service agencies. A university child
development center said: “Support collaboration at the service delivery level. Allow
families to have one service delivery plan, rather than multiple plans.”
Many commenters wanted coordination between TANF agencies and different
types of service providers (i.e., community action agencies or domestic and sexual
violence agencies). Others recommended more public input. Generally, among those
who made comments about coordination, there was support for broadening the range
of actors in TANF service provision and allowing specialists in specific fields to deal
with their areas of expertise.
Transitional Supports for Welfare Leavers
Families leaving welfare are often eligible for a wide range of benefits and
services under various federal or state programs. Recipients who leave TANF for
work are not only eligible for, but are often given priority to receive child care
subsidies under the state’s CCDF plan. Transitional Medicaid Assistance also is
currently available to these former recipients for one year, and up to two years at state
option. There was general support among commenters for providing a wide range
of supports to recipients who leave the rolls, and a recognition of the importance of
these supports in the transition to self-sufficiency. In addition to food stamps and
Medicaid, transportation subsidies, child care, and education and training were
frequently mentioned as valuable supports for working families. Other services
mentioned include job retention services, and housing assistance.
The law should do more to ensure that familiesOther suggestionsincluded providing an
leaving welfare continue to receive food stamps,
Medicaid, child care and other necessary supports.entitlement to transitional
— local community service organizationservices for a period of time
after leaving TANF (e.g., six
months, one year), and
improving access to supports and making sure leavers are aware of their continued
eligibility. As noted above, similar suggestions were made about coordinating
program eligibility.
As a response to TANF work mandates and time limits, a number of
commenters proposed creating some type of public service jobs program to provide
work for families on or leaving TANF cash assistance. The groups mentioned most
often as the target population for these programs were families reaching time limits
and those with limited work experience. Other populations cited as potential
beneficiaries of these programs include the hard-to-employ, those with prison
records, and recipients in rural or urban areas with limited employment opportunities

or high unemployment. Among the commenters advocating a public service jobs
program, many emphasized that such jobs must pay a “living wage.” Some
commenters also wanted these jobs to provide education and training, mentoring, and
support services.
Charitable Choice
Section 104 of Title I of the 1996 welfare law addresses services provided under
TANF by charitable, religious, or private organizations. Commonly known as the
“charitable choice” provision, the stated purpose of this section is to allow states to
use religious organizations as service providers “on the same basis as any other
nongovernmental provider without impairing the religious character of such
organizations, and without diminishing the religious freedom of beneficiaries of
assistance funded under such program.”10
Although there were a number of commenters affiliated with churches or faith-
based service providers, these groups did not often comment on the charitable choice
provisions under TANF. Comments on charitable choice came from a wide variety
of individuals and groups, most of whom had similar concerns about the provision.
In general, commenters supported the protections currently afforded recipients under
the charitable choice provision (such as the prohibition against requiring religious
observance to obtain services) but wanted a system of oversight and increased
protections to make sure that these protections were being enforced.
In addition, many of these commenters were concerned that under charitable
choice, federal TANF funds could be paid to employers who discriminate in hiring.
The current charitable choice provision allows religious organizations who are
exempt from Section 702 of the Civil Rights Act of 1964 (which prohibits
employment discrimination on the basis of religion) to maintain their exempt status
as service providers under TANF. Among those who commented on these
provisions, there was strong support for applying anti-discrimination laws to all
providers of TANF services.

10For more information, see CRS Report RS20717, Charitable Choice, Faith-Based
Initiatives, and TANF, by Vee Burke.

Table A1. Comment and Recommendation Categories11
Program/Category/Recommendation or Comment
Goals/general philosophy
Make poverty reduction a TANF goal
Strengthen TANF goal related to marriage
Promote marriage-neutral TANF policies
Other proposals related to TANF goals
Goals toward achieving self-sufficiency
Strengthen goal for reducing out-wedlock pregnancies
Other goal/philosophy issues regarding out-of-wedlock pregnancies
State plans/programs
Modify state plan requirements
Require adoption of family violence option
Require states to spell out domestic violence procedures
Other state plan requirements
Maintain funding level
Reduce funding level
Increase funding level
Adjust funding for inflation
Maintain state MOE rules
Reduce the MOE
Increase state MOE requirements
Change the distribution of funds
Provide supplemental grants (under old rules)
Modify supplemental grants
End supplemental grants
Maintain bonus for reducing nonmarital births
Change bonus for reducing nonmarital births
Eliminate bonus for reducing nonmarital births
Maintain high performance bonus
Revise high performance bonus
Eliminate high performance bonus
Establish a poverty reduction bonus
Establish new bonus (other than poverty reduction)
Other bonus recommendation

11These are the categories that were created in the CRS database to capture all potential
comments. However, there were not necessarily comments made in every category listed.

Program/Category/Recommendation or Comment
Provide contingency fund (under old rules or changes not specified)
Change contingency fund economic need criteria
Change contingency fund state spending requirements for access
Increase (or uncap) the size of the fund.
Other contingency fund recommendation
Reinstate welfare-to-work grants
Other welfare-to-work changes
Retain authority to spend TANF on child care
Retain authority to spend TANF on child welfare services
Expand authority to spend TANF on child welfare services
Other Funding Issues
Use of grants
Earmark a portion of grant for marriage promotion activities
Earmark a portion of the grant for reducing out-of-wedlock pregnancies
Add new allowed uses
Maintain the limit on transfers to CCDF or SSBG
Change the limit on transfers to CCDF or SSBG
Permit transfers to additional programs
Other transfer recommendations
End authority to discriminate against interstate immigrants
Prohibit supplantation of state funds
Retain flexibility — no earmarking
Permit payments for ongoing housing
Increase flexibility of use of grants
Increase flexibility in use of prior year grants
Modify the 15% cap on administrative expenditures
Conform use of federal TANF and MOE rules
Other use of grants
End application of Cash Management Improvement Act to TANF
Requirements for state caseworkers and state program administration
Other administrative
Work requirements
Continue current participation rates
Modify participation rate for two-parent families
Eliminate special participation rate for two-parent families
Expand the state option to exempt parents of young children
Permit states to exempt some categories of recipients in participation calculation
Other changes to participation rates

Program/Category/Recommendation or Comment
Continue caseload reduction credit against participation rate
End the caseload reduction credit
Modify the caseload reduction credit
Modify hours requirements for two-parent families
Modify hours requirements for all families
Modify job search restrictions
Modify vocational educational training restrictions
Work activities: retain existing list of activities
Work activities: add more “human capital” activities
Work activities: add “rehabilitative” activities
Work activities: add domestic duties
Work activities: other recommendations
Prohibition full family sanction for failure to work
Modify state requirement to sanction families for failure to work
Retain existing requirements for states to sanction for failure to work
Prescribe sanctioning procedures
Other recommendations regarding work requirements
Requirements: Definition of assistance
Retain current definition of “assistance”
Change the current definition of TANF “assistance”
Maintain requirement that family have minor child
Make childless families eligible for certain TANF services
Child care not counted as “assistance” under any circumstances
Other recommendation regarding scope of requirements
Requirements: Time limit
Time limit: retain 60-month time limit
Time limit: allow states to suspend the time limit for working recipients
Time limit: require states to suspend the time limit for working recipients
Time limit: allow extensions in times of high unemployment
Time limit: require extensions in times of high unemployment
Time limit: exempt some caregivers from time limit
Time limit: increase the hardship exemption
Time limit: prohibit state limits shorter than 60 months
Time limit: lengthen the federal limit
Eliminate the time limit
Time limit: suspend time limit for recipients who comply with program
Other time limit

Program/Category/Recommendation or Comment
Requirements: Child support
Child support cooperation: eliminate penalty for violation
Child support cooperation: protections for domestic violence victims
Child support assignment: modify or eliminate assignment requirement
Child support: other recommendations
Requirements: Teen parents
Teen parents: end requirement to live under adult supervision
Teen parents: end requirement for school attendance
Teen parents: require immediate unconditional acceptance of applications
Teen parents: other recommendations
Requirements: Individual Responsibility Plan
Individual Responsibility Plans: retain option for developing plan
Individual Responsibility Plans: require states to develop IRPs
Individual Responsibility Plans: require certain elements in IRPs
Individual Responsibility Plans: other recommendations
Requirements: Cash welfare eligibility/benefits
Federal requirement for minimum benefit
Establish federal rules for earnings disregards
Establish federal rules for resources
Require states to exempt one vehicle from resources
Other eligibility/benefit rules recommendations
Requirements: Family cap
Prohibition of a family cap
Require in-kind assistance for children in families subject to family cap
Disallow in-kind assistance for new child in capped family
Require services for new child in capped family
Disallow services for new child in capped family
Other family cap
Requirements: Services: relative caregivers
Require additional services for relative caregivers
Require higher benefits for relative caregivers
Reduce TANF requirements for relative caregivers
Apply more TANF requirements for relative caregivers
Modify TANF requirements for relative caregivers
Other relative caregivers
Requirements: Service for immigrants
Require cash assistance for citizen children of ineligible immigrants
Require services for citizen children of ineligible immigrants
Require cash assistance for immigrant children

Program/Category/Recommendation or Comment
Require services for immigrant children
Other immigrant children
Requirements: Sanctioned families
Require in-kind assistance for children in sanctioned families
Disallow in-kind assistance for children in sanctioned families
Require special services for sanctioned families
Disallow special services for children in sanctioned family.
Other sanctioned families
Requirements: Other
Require states to provide TANF funding for legal services
Require states to fund transitional jobs programs
Require states to provide other benefits and services
Requirements for assessments of recipients
Data reporting
Continue quarterly reporting requirements
Reduce state reporting requirements
Require monthly reporting of some data
Increase types of data reported (e.g., by race/age)
Require reporting of “welfare leavers”
Indian TANF programs
Provide technical support to develop infrastructure
Other recommendation re: Indians or TANF Indian programs
Require state research on welfare’s impact
Other research recommendations
Permit states to extend their waivers
Other waivers
Limit on federal authority
Continue limit on federal regulatory authority
Modify imit on federal regulatory authority
Eliminate limit on federal regulatory authority

Program/Category/Recommendation or Comment
Parental Choice
Increase CCDF funding
Maintain quality set-aside for CCDF
Modify CCDF set-asides
Incentive funds for targeted quality initiatives
Other CCDF funding issues
Simplify CCDF funding rules
State plans/requirements
Expand CCDF state plan requirements
Modify requirements for CCDF payment rates (and market surveys)
Mandate higher payment rates for caring for children with disabilities
Expand transitional child in case of job loss/job search
Expand funding for child care research/surveys
Modify recertification process
Data reporting
Expand reporting for child care
Health and safety requirements
Modify health and safety requirements
Child Support Enforcement
State plan/enforcement tools
Require new child support enforcement tools
Modify child support enforcement tools
Maintain CSE matching rates
Increase CSE matching rates
Reduce CSE matching rates
Other recommendation re: CSE matching
Distribution-pass through rules
Pay collections to “family first” before reimbursing government
Simplify the distribution process
Pass-through and disregard child support for welfare family
Require federal government to share cost of CS pass-through
Other child support
Other child support distribution recommendations

Program/Category/Recommendation or Comment
Child Welfare
Child Welfare Eligibility
Delink foster care and adoption eligibility from former AFDC
Restructure IV-E foster care and adoption assistance eligibility
Maintain current foster care and adoptions assistance eligibility
Other recommendations related to foster care and adoption assistance
Food Stamps
Retain current food stamp rules
Increase food stamp benefits
Permit more state flexibility in food stamp rules
Other food stamp changes
Continue transitional Medicaid under current rules
Extend transitional Medicaid beyond one year
Other modifications to transitional Medicaid
Modify Medicaid eligibility
Other modifications to Medicaid
Maintain current SCHIP funding
Increase SCHIP funding
Make caretakers eligible for SCHIP
Other changes to SCHIP
Expand SCHIP eligibility
Expand health insurance coverage (other than specific Medicaid or SCHIP)
Housing assistance recommendations
Immigrant Provisions
Eliminate all restrictions on immigrants enacted in PRWORA
Retain restrictions on immigrants enacted in PRWORA
Eliminate food stamp eligibility restrictions on immigrants
Modify food stamp eligibility restrictions on immigrants
Retain food stamp eligibility restrictions on immigrants
Eliminate SSI restrictions on immigrants enacted in PRWORA
Modify SSI restrictions on immigrants enacted in PRWORA
Retain SSI restrictions on immigrants enacted in PRWORA
Eliminate Medicaid restrictions on immigrants enacted in PRWORA
Modify Medicaid restrictions on immigrants enacted in PRWORA
Retain Medicaid restrictions on immigrants enacted in PRWORA
Eliminate TANF restrictions on immigrants enacted in PRWORA

Program/Category/Recommendation or Comment
Modify TANF restrictions on immigrants enacted in PRWORA
Retain TANF restrictions on immigrants enacted in PRWORA
Other proposals for immigrants
Other Cross-Cutting Recommendations
Improve coordination in program eligibility
Coordinate data reporting across programs
Pubic service jobs program
Rural issues
Provide transitional benefits
Increase the minimum wage
Charitable Choice
Other program coordination issues
Other Programs
Unemployment compensation
Social Services Block Grant
Supplemental Security Income
Earned Income Tax Credit
Community Services Block Grant
Social Security
Juvenile Justice
Civil Rights Enforcement

Table A2. Commenter Categories12
U.S. Senator
U.S. House Member
U.S. Judicial
State Governor
State Human Services Agency
State Legislator
City Mayor
Local Human Services Agency
City Council
National Advocacy Organization
Advocacy Organization (state or local)
National Faith-based Organization
Faith-based Organization (state or local)
Community Service Organization
Student of Social Work
Indian Tribes
Labor Unions
Welfare Recipients
Former Welfare Recipients
General Public

12These were the categories created in the CRS database to capture all potential commenters.
However, comments were not necessarily received from individuals or groups representing
each of the categories listed.