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Using TANF to Free Up MOE Funds Is Not Supplantation
This paper does not define supplantation to include cases when a state uses TANF funds to
replace state funds that were being counted toward MOE. A state could, for example, choose to
fund its basic cash assistance entirely with TANF funds, and then use the freed-up state funds for
other MOE purposes, including creation of a separate state program. If a state uses TANF funds
to replace MOE funds, presumably it must increase state spending countable toward MOE
elsewhere, which means it has not freed up state funds that can be used for a
ny purpose.
Such a use of TANF funds should not be considered supplantation.
intent of the new spending test - to require the state to maintain the $10 million state funding
commitment - can be subverted.
Moreover, the flexibility TANF regulations provide for states to set the income definition
for needy families, while generally a positive step that allows states to direct TANF services to
working families that remain low-income, also allows for greater supplantation. For programs
that serve families with a broad range of incomes, setting a relatively high income threshold for
"needy" families allows a greater share of existing state spending to be replaced with TANF
funds.
Activities that meet the third and fourth purposes of TANF - reducing out-of-wedlock
births and promoting two-parent families - represent another opportunity for supplantation.
The TANF regulations indicate that such activities need not be limited to needy families. A state
thus could use TANF funds to support after-school programs for children at all income levels,
under the notion that such programs reduce out-of-wedlock births. By contrast, states cannot use
MOE to fund such activities without an income test; MOE funds must be spent on needy families
regardless of the TANF purpose they are intended to meet.
States consequently can use TANF to replace existing state funding for programs serving
non-needy families if they assert that the activities are reasonably calculated to reduce out-of-
wedlock births or promote two-parent families. A state might claim, for example, that
extracurricular school activities such as tutoring or recreation reduce out-of-wedlock births.
Moreover, almost any service that supports families might be claimed to promote the
maintenance of two-parent families. Because there are a wide variety of programs that could be
claimed to meet the third and fourth purposes of TANF and because TANF-funded activities that
meet these purposes can serve children at all income levels, the potential for states to identify
existing programs whose funding could be supplanted with TANF funds is large.
The opportunity to supplant state funding in this manner existed before the final TANF
regulations were released. It appears, however, that states began considering much more
extensive use of TANF funds to "reduce out-of-wedlock births" or "promote two-parent
5
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"ocrText": "Using TANF to Free Up MOE Funds Is Not Supplantation\nThis paper does not define supplantation to include cases when a state uses TANF funds to\nreplace state funds that were being counted toward MOE. A state could, for example, choose to\nfund its basic cash assistance entirely with TANF funds, and then use the freed-up state funds for\nother MOE purposes, including creation of a separate state program. If a state uses TANF funds\nto replace MOE funds, presumably it must increase state spending countable toward MOE\nelsewhere, which means it has not freed up state funds that can be used for a\nny purpose.\nSuch a use of TANF funds should not be considered supplantation.\nintent of the new spending test - to require the state to maintain the $10 million state funding\ncommitment - can be subverted.\nMoreover, the flexibility TANF regulations provide for states to set the income definition\nfor needy families, while generally a positive step that allows states to direct TANF services to\nworking families that remain low-income, also allows for greater supplantation. For programs\nthat serve families with a broad range of incomes, setting a relatively high income threshold for\n\"needy\" families allows a greater share of existing state spending to be replaced with TANF\nfunds.\nActivities that meet the third and fourth purposes of TANF - reducing out-of-wedlock\nbirths and promoting two-parent families - represent another opportunity for supplantation.\nThe TANF regulations indicate that such activities need not be limited to needy families. A state\nthus could use TANF funds to support after-school programs for children at all income levels,\nunder the notion that such programs reduce out-of-wedlock births. By contrast, states cannot use\nMOE to fund such activities without an income test; MOE funds must be spent on needy families\nregardless of the TANF purpose they are intended to meet.\nStates consequently can use TANF to replace existing state funding for programs serving\nnon-needy families if they assert that the activities are reasonably calculated to reduce out-of-\nwedlock births or promote two-parent families. A state might claim, for example, that\nextracurricular school activities such as tutoring or recreation reduce out-of-wedlock births.\nMoreover, almost any service that supports families might be claimed to promote the\nmaintenance of two-parent families. Because there are a wide variety of programs that could be\nclaimed to meet the third and fourth purposes of TANF and because TANF-funded activities that\nmeet these purposes can serve children at all income levels, the potential for states to identify\nexisting programs whose funding could be supplanted with TANF funds is large.\nThe opportunity to supplant state funding in this manner existed before the final TANF\nregulations were released. It appears, however, that states began considering much more\nextensive use of TANF funds to \"reduce out-of-wedlock births\" or \"promote two-parent\n5"
}