In a letter sent to the Administration of Children and Families (ACF), the National Association of Evangelicals commented on several proposed changes to regulations related to the Temporary Assistance for Needy Families (TANF) program.
The first proposed change to TANF regulations would establish a ceiling on the term “needy” to mean a household income below 200 percent of federal poverty guidelines. “The National Association of Evangelicals applauds the move to target assistance to the families in greatest need of assistance,” the letter writes. “Defining as ‘needy’ those families with income at or below 200% of the federal poverty guidelines is a reasonable standard.”
The second change proposed by the ACF would add language to the rule expressing doubt that crisis pregnancy centers offer services that accomplish a TANF purpose. Specifically, the proposed rule states the following:
Similarly, programs that only or primarily provide pregnancy counseling to women only after they become pregnant likely do not meet the reasonable person standard because the connection to preventing and reducing out-of-wedlock pregnancies is tenuous or non-existent, and therefore do not accomplish purpose three.
This language is likely to encourage states to preemptively discriminate against pregnancy centers despite the contributions of their work to preventing and reducing the incidence of out-of-wedlock pregnancies (a stated goal of TANF).
The proposed change assumes that women who come to pregnancy centers are already pregnant. This isn’t always the case as some women who come to centers find out they are not pregnant after testing, and for these women, centers routinely provide counseling to prevent future pregnancies.
The final proposed change would require states that provide funding for certain entities, including pregnancy centers, to show that past and present expenditures accomplish TANF purposes, or that there is academic or other research that indicates the expenditure would accomplish the TANF purpose.
This revision is problematic as TANF providers may not have the resources needed for required evidence. Evidence required of states should be proportional to the magnitude of the partnership.
“In some cases the required evidence might cost more to obtain than the amount of funding sought. Special academic studies or evaluations should not be required beyond the normal requirements for TANF providers. Or if these requirements are maintained for large grant partnerships, they should be waived for partnerships below a specific dollar amount, perhaps $500,000,” the NAE letter states.
The NAE recommends that specific references to pregnancy centers be deleted, or that the ACF more positively acknowledges the work pregnancy centers do in contributing to TANF’s purposes.Read the Letter