Human Services News

From Center for Law and Social Policy:

The changes made by the Deficit Reduction Act of 2005 and the corresponding regulations have increased pressure on states to place TANF recipients in federally countable activities.

"Needy states" may qualify for extended counting of job search and job readiness assistance toward the TANF work participation rate.

HHS has just issued a Program Instruction (TANF-ACF-PI-2006-04) describing this provision and how it will be implemented.

The state qualifies as a "needy state" under the provisions of the Contingency Fund section of the law.

The threshold levels have been calculated by the Department of Agriculture, and are included in a table provided with the Program Instruction.

These provisions were not affected by the TANF changes in the Deficit Reduction Act of 2005 or by the Interim Final Rule published by HHS on June 29, 2006.

However, they take on increased significance because the DRA substantially increased the effective participation rate requirement on states.

Also, the regulations stated that many barrier removal and labor force attachment activities---previously counted under other work activities---could only be counted toward the participation rate as part of "job search and job readiness assistance."

States qualified primarily because of growth in Food Stamp caseloads.

Because of the lags in reporting data, states will not know officially that they qualified under this provision until well after the end of the month.

However, HHS suggests that a state will be able to "predict with reasonably high accuracy whether it will qualify" in a given month by using its own trends and projections of Food Stamp participants and unemployment rates and comparing them to the thresholds.

In the preamble to the Interim Final Rule published on June 29, 2006, HHS stated that, for the purpose of this requirement, a "week" is considered a period of seven consecutive days.

If a state reports even one hour of job search and job readiness assistance as counting toward the participation rate calculation during such a seven-day period, it uses up a full week toward the limit.

In the Program Instruction, HHS clearly endorses such an approach, and it recognizes that a state may need to go back and adjust a month's participation rate data if the state has incorrectly counted additional weeks of job search and job readiness assistance, or if it has failed to count weeks to which it is entitled.

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