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OCR Page 1 of 15with
well
Andrea Kane
11/03/2000 11:51 AM
Record Type:
Record
To:
Brenda Aguilar/OMB/EOP@EOP
CC:
margy waller/opd/eop@eop, kristin e. sneed/omb/eop@eop, debra j. bond/omb/eop@eop
Subject: Re: WtW Revisions
A few follow-up questions/comments:
p. 14, last graph: why drop reference to 4 purposes of TANF ? how did DOL come out on the issue of
individuals who are needy but served under purposes 3 and 4 where state doesn't have to set income
eligibility?
p. 29, new sentence: revise as follows "We also removed the reference to to emphasize that IDAs IDA's
established in accordance with the statutory purposes or uses of TANF or WtW requirements are
allowable WtW activities." This is more consistent with what we agreed to.
p. 52, 1st graph: "Fy" should be "FY"
p. 53, 1st graph: question to OMB: just want to make sure that we agreed to just leave performance
measures discussion as is, and clarify that substantive employment meant 30 or more hours at placement
in the reporting requirements. Is that your recollection?
p. 68 ( two references in 3rd graph), p. 71 (2nd graph), p. 114 [645.212(c)(2)(ii) and (iii): DOL, pls help us
understand why you're leaving "benefits and services" in this context, while you've switched back to
"assistance" elsewhere.
p. 74: Just to make sure we understand how this works, does this mean that grantees must use either: 1)
the defn of income in the 1st graph or 2) proxy income test where either a) the program used as proxy is
limited to individuals below the poverty line or b) the program includes people with higher income but the
individual/family is below povery level? More specifically, we recommend adding to the end of the 2nd
sentence in 1st graph: "and other amounts specifically excluded by any other Federal statute for
consideration as income". This would cover things like food stamps that are not cash. Also, what about
non-cash items such as child care? In the context of this paragraph, we assume this would not be
considered income and most grantees probably would too, but there could be confusion where TANF
funds are used to pay for such things.
p. 75, 1st graph: "suffices" should be "suffice"
On the 70/30 issue, I'm fine with the policy and support the flexibility and common-sense approach DOL is
trying to promote. However, I think the write-up begs the question of how DOL will enforce. For example,
what does it mean to "not quite spend all of its grant funds"? The graph beginning "We see this
change. implies that DOL will make some kind of subjective judgement about the grantees intent and
their efforts. Will this simply be reflected in monitoring reports/TA efforts or will there be any
consequences if a grantee falls far short of expenditure goals and doesn't appear to have made a good
faith effort?
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