Which 2022 federal TANF waivers allowed states to suspend work participation requirements?
Executive summary
Federal guidance and reporting show that in 2022 there was no broad, new federal TANF waiver program that universally suspended work-participation requirements; instead, states used existing flexibility, “good cause” exemptions during COVID-era disruptions, and varied state policies tracked by ACF and research organizations (see ACF databook and FY2022 WPR memo) [1] [2] [3]. Sources document many states adopting waivers or exemptions earlier in the pandemic and note continuing state-level variation by July 2022, but they do not list a named set of 2022 federal waivers that uniformly suspended TANF work requirements nationwide [4] [1] [2].
1. What the record shows: no single 2022 federal waiver suspending work rules
Available federal materials and the ACF work-participation memorandum for FY2022 do not describe a one-time, across-the-board federal waiver issued in 2022 that suspended TANF work-participation requirements for all states; instead HHS/ACF continued to measure state Work Participation Rates and reported many states had zero percent targets or were structurally exempted from some requirements in FY2022 [2] [3]. The ACF graphical databook documents state-level differences as of July 2022, implying policy diversity rather than a single federal suspension [1].
2. Where “waivers” and “exemptions” actually appear in reporting
Advocates and state agencies during the COVID crisis used waivers, “good cause” policies, and other flexibilities to excuse non‑participation; CLASP’s review and ACF materials show states granted good-cause exemptions and temporary suspensions of sanctions during the pandemic, and some states explicitly stopped enforcing work-site attendance early in the crisis (examples cited by CLASP) [4]. Those policies are described as state actions supported by federal relief or leniency rather than a single new 2022 federal waiver [4].
3. Why FY2022 work‑rate reporting matters
ACF’s FY2022 Work Participation Rate memorandum shows how federal measurement, credits, and exemptions operated in practice: 37 states/territories had a zero percent overall target for FY2022 and many were not subject to two-parent requirements because of program structure—facts that explain low measured obligations without invoking a blanket federal waiver [2]. That FY2022 reporting is the best contemporaneous federal documentation of what states actually had to meet in 2022 [2].
4. State-level variation: the concrete reality on the ground
The ACF graphical overview and Urban/OPRE summaries compile hundreds of state policy variables as of mid‑2022, showing a fragmented landscape where some states relaxed sanctions or granted exemptions while others continued strict enforcement—demonstrating that “suspension” of work requirements in 2022 was highly localized and often temporary [1] [5]. Researchers and policy centers note states’ broad discretion under TANF and the resulting uneven experience for families [3] [6].
5. Competing interpretations and political context
Federal press historically has framed waiver policy shifts as a policy choice: ACF’s 2017 materials emphasize restoring work participation expectations and rescinding an earlier invitation to pursue waivers, showing federal reluctance at times to allow broad suspensions [7]. Conversely, advocacy groups argued during COVID that states should continue waiving work requirements and sanctions to protect families and public health; CLASP documented such advocacy and state actions in 2020–2023 [4]. Both perspectives appear in the record: federal enforcement priorities matter, but pandemic-era operational leniency and state discretion produced many local suspensions or exemptions [7] [4].
6. Limits of available sources and what they do not say
Available sources do not mention a discrete list of “2022 federal TANF waivers” that uniformly suspended work participation requirements across states; they instead show FY2022 administrative reporting, state policy trackers, and pandemic-era advocacy documenting state-level waivers, exemptions, and ACF measurement rules [2] [1] [4]. The sources do not provide a compiled, authoritative roster of which specific states suspended every sanction or requirement for every month of 2022—only aggregated snapshots and narrative accounts [1] [2].
7. Practical takeaway for researchers and advocates
To identify which jurisdictions suspended work participation enforcement in 2022, consult the ACF state policy databook and the OPRE/Urban graphical overviews for July 2022 and review state agency announcements and CLASP-style summaries of pandemic exemptions; those sources document state-by-state actions and the federal measurement framework that made many targets effectively zero for FY2022 [1] [5] [4] [2].