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restrictions on one-time, short-term assistance. We do not believe that our proposed definition otherwise deviated from the definition in the guidance. It is our view that benefits such as child care and transportation subsidies, while not directly mentioned, were part of the definition of assistance, in the January 1997 policy announcement (TANF-ACF-PA-97-1), as they involved subsidies or other forms of income support. Our intent in inserting the references to child care and transportation in the NPRM was to provide a clearer and more complete definition, not to make a substantive change. (Nevertheless, as we discuss in the next section, on "Work Supports," the final rule excludes such supports for working families from the definition of assistance.) Comment: Several commenters suggested that we should exclude assistance that was not cash assistance or financial assistance from our definition. Response: As we discuss in the following comments, the legislative history does not support this approach. Rather, for both TANF and WtW, it suggests that Congress envisioned inclusion of at least some non-cash benefits as assistance. Otherwise, it would have been superfluous to specifically 211