Filed Under: Assistance vs. Non-Assistance, Temporary Assistance for Needy Families

Assistance vs. Non-Assistance

Updated August 2023

“Assistance” has a very specific meaning in TANF. It is important because families that receive “assistance” are subject to four specific requirements; (1) work requirements, (2) time limits, (3) child support cooperation requirements and (4) assignment of any rights they have to child support to the state and federal government. All monthly cash benefits provided to TANF recipients are “assistance” but they are not the only benefits that meet the definition of assistance.  A very short-hand way of thinking of “assistance” is a cash payment, voucher or other form of providing help that is intended to help a family meet their ongoing basic needs, such as for food, clothing, shelter, utilities, personal care items or household needs. Some supportive services (e.g., transportation and child care) provided to non-working families also are considered assistance. Key exclusions include tax credits and “non-recurrent short-term benefits” that are provided to meet a specific episode of need and will not last for more than four months. States can avoid imposing time limits and child support requirements on families receiving “assistance” if they provide cash benefits through a separate state program (SSP), funded only with MOE funds that are not comingled with federal TANF dollars. Families receiving assistance through an SSP are, however, subject to work requirements. Considerations of whether a benefit meets the definition of assistance is important when considering providing food, diapers, period products, clothing or housing assistance to families who are NOT already receiving cash assistance. Benefits need not be provided in cash; in-kind benefits may be considered assistance if they do not meet the requirements of a non-recurrent short-term benefit.

The definition of assistance is laid out in regulations: 45 CFR § 260.31 – What does the term “assistance” mean? | Electronic Code of Federal Regulations (e-CFR) | US Law | LII / Legal Information Institute (cornell.edu). The detailed text is included below.

HHS has also provided a Q and A document which can be found at this link: Q & A: Definition of Assistance | The Administration for Children and Families (hhs.gov).

This document, written by CBPP and CLASP staff after the passage of the DRA provides a discussion of when TANF-Related requirements apply (pages 21 -23):  Implementing TANF Changes in the Deficit Reduction Act: Win-Win Solutions for Families and States

Regulations defining what “assistance” means in TANF.

§ 260.31 What does the term “assistance” mean?

(a)

(1) The term “assistance” includes cash, payments, vouchers, and other forms of benefits designed to meet a family’s ongoing basic needs (i.e., for food, clothing, shelter, utilities, household goods, personal care items, and general incidental expenses).

(2) It includes such benefits even when they are:

(i) Provided in the form of payments by a TANF agency, or other agency on its behalf, to individual recipients; and

(ii) Conditioned on participation in work experience or community service (or any other work activity under § 261.30 of this chapter).

(3) Except where excluded under paragraph (b) of this section, it also includes supportive services such as transportation and child care provided to families who are not employed.

(b) It excludes:

(1) Nonrecurrent, short-term benefits that:

(i) Are designed to deal with a specific crisis situation or episode of need;

(ii) Are not intended to meet recurrent or ongoing needs; and

(iii) Will not extend beyond four months.

(2) Work subsidies (i.e., payments to employers or third parties to help cover the costs of employee wages, benefits, supervision, and training);

(3) Supportive services such as child care and transportation provided to families who are employed;

(4) Refundable earned income tax credits;

(5) Contributions to, and distributions from, Individual Development Accounts;

(6) Services such as counseling, case management, peer support, child care information and referral, transitional services, job retention, job advancement, and other employment-related services that do not provide basic income support; and

(7) Transportation benefits provided under a Job Access or Reverse Commute project, pursuant to section 404(k) of the Act, to an individual who is not otherwise receiving assistance.

(c) The definition of the term assistance specified in paragraphs (a) and (b) of this section:

(1) Does not apply to the use of the term assistance at part 263, subpart A, or at part 264, subpart B, of this chapter; and

(2) Does not preclude a State from providing other types of benefits and services in support of the TANF goal at § 260.20(a).