First a bit of the basics. TANF has an annual appropriation of $16.5 billion, not including a significant expansion under the American Recovery and Reinvestment Act (ARRA). In the federal budget, TANF is mandatory spending, similar to Medicaid, Medicare, Food Stamps, and other so-called "entitlement" programs. The federal agency administering TANF is the Administration for Children and Families (ACF) within the Dept of Health and Human Services. According to ACF data, states currently are spending $400 million a year in their federal TANF funds on transportation, which they match with $44 million in state “maintenance-of-effort” funds for transportation services. ARRA created a one-time "TANF Emergency Fund" of $5 billion, which expires September 30, 2010.
When the 1996 Personal Responsibility and Work Opportunity Reconciliation Act eliminated the previous Aid to Families with Dependent Children (AFDC) program and replaced it with TANF, responsibility for establishing program rules, services and details were left largely in the hands of states. States receive TANF as a block grant, with allocations based primarily on their 1994 levels of AFDC spending. These amounts don't change, even when states' economies plummet and unemployment (and thus the degree of TANF demand) rises.
States often call their TANF programs by unique, state-specific, names, and set most of their own procedures for how TANF-related services are provided. States are not required to spend any of their TANF funds on transportation. But almost every state does, in some way or another, because the lack of transportation continues to be documented as one of the leading barriers to employment participation, especially among otherwise-unemployed single mothers (not surprisingly, the lack of child care continues to be the other leading barrier to employment participation among this segment of the "at-risk" population). States can provide transportation as part of the direct "assistance" they provide to TANF recipients (typically using vouchers, transit passes or related strategies), in which case TANF funds tend to follow the individual, are tracked closely for eligibility, and have to comply with the time limits and other person-specific requirements of TANF. This practice is especially prevalent at times like our current economy, when TANF-eligible populations are more numerous and demands on TANF resources are peaking. States also have the opportunity to provide TANF-related transportation as "non-assistance," meaning that they are helping to finance transportation networks that serve the needs of the TANF-eligible population, but not in ways that are directly delivered as benefits to individuals. For example, in the late 1990s, many states were using their TANF funds to match Federal Transit Administration "Job Access and Reverse Commute" grants to provide systems of transportation services addressing all low-income populations, not just the populations receiving direct TANF assistance.
The FTA/DOL Joblinks Employment Transportation Initiative, operated by the Community Transportation Association of America, has focused a lot of energy on TANF and created a host of TANF-related documents over its 12 years (and counting) of operation. This post is not meant to recap or replace that wealth of literature, but simply aims to point out a few reminders about TANF and transit programs.
The first reminder, as stated above, is that states have an abundance of flexibility and autonomy to create TANF-funded services in ways that suit their circumstances.
Second, TANF is one of the very few non-DOT grant programs for which federal agencies created guidance directing the relationship between TANF and FTA grants. Although it predates the current SAFETEA-LU authorization, there is a joint guidance document, officially issued by the Federal Transit Administration, the Employment and Training Administration (ETA), and the Administration for Children and Families, that explains, from each of these agencies' perspectives, how their funds - JARC, TANF, and the old Welfare-to-Work grants - can be used together. At the headquarters level, the staff of FTA, ETA and ACF all have said this guidance remains in force. It can be found on the FTA website at http://www.fta.dot.gov/
Third, SAFETEA-LU makes statutory references to TANF in its authorization for ALL of the Federal Transit Administration's formula grant programs:
Urban transit....
49 USC 5307(e)(4):
"Use of certain funds. - The prohibitions on the use of funds
for matching requirements under section 403(a)(5)(C)(vii) of
the Social Security Act (42 U.S.C. 603(a)(5)(C)(vii)) shall
not apply to the remainder [ie, the non-FTA share of project costs]"
Elderly/Disabilities transit....
49 USC 5310(c)(3):
"Use of certain funds. - For purposes of paragraph (2)(B)Rural transit....
[defining the non-FTA share of project costs], the prohibitions
on the use of funds for matching requirements under section
403(a)(5)(C)(vii) of the Social Security Act (42 U.S.C.
603(a)(5)(C)(vii)) shall not apply to Federal or State
funds to be used for transportation purposes."
49 USC 5311(g)(4):
"Use of certain funds. - For purposes of paragraph (3)(B)
[defining the non-FTA share of project costs], the prohibitions
on the use of funds for matching requirements under section
403(a)(5)(C)(vii) of the Social Security Act (42 U.S.C.
603(a)(5)(C)(vii)) shall not apply to Federal or State
funds to be used for transportation purposes."
Job Access and Reverse Commute.....
49 USC 5316(h)(4):
"Use of certain funds. - For purposes of paragraph (3)(B)
[defining the non-FTA share of project costs], the prohibitions
on the use of funds for matching requirements under section
403(a)(5)(C)(vii) of the Social Security Act (42 U.S.C.
603(a)(5)(C)(vii)) shall not apply to Federal or State
funds to be used for transportation purposes."
New Freedom....
49 USC 5317(g)(4):
"Use of certain funds. - For purposes of paragraph (3)(B)
[defining the non-FTA share of project costs], the prohibitions
on the use of funds for matching requirements under section
403(a)(5)(C)(vii) of the Social Security Act (42 U.S.C.
603(a)(5)(C)(vii)) shall not apply to Federal or State
funds to be used for transportation purposes."
The above language was inserted in each of those portions of authorizing legislation specifically because Congress did not want there to be an impediment in the use of TANF funds (which is the reference to Section 403 of the Social Security Act) with regard to coordination with FTA funds. This is notable, in that it is the only statutory requirement of "coordination" that imposes a requirement on non-DOT programs; the language specifically addresses TANF as a partner in all FTA grants.
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