What federal guidance or waivers affected state TANF work rules in 2022?
Executive summary
Federal guidance and temporary funds tied to COVID-era relief shaped how states applied TANF work rules in 2022: HHS required states to report work participation for October 2021–September 2022 and issued operational guidance on ARP’s Pandemic Emergency Assistance Fund (PEAF) that states could use for non‑recurring short‑term (NRST) benefits through September 30, 2022 [1] [2]. The Welfare Rules Databook and ACF materials show that states retained broad discretion over eligibility and work‑activity design, within federal reporting and penalty frameworks [3] [4].
1. Federal reporting and accountability set the baseline
The Administration for Children and Families (ACF) required all states to report work participation information covering October 2021 through September 2022; ACF’s FY2022 work participation memorandum transmits state results and notes which states or territories failed two‑parent or overall rates, so federal reporting and potential penalties remained the core enforcement lever in 2022 [1].
2. Pandemic emergency funds changed what counts as assistance, not the statutory work rules
ACF guidance on the Pandemic Emergency Assistance Fund (PEAF) created by the American Rescue Plan authorized states, territories and tribes to deliver NRST benefits and administrative supports using ARP funds and reminded recipients that initial PEAF awards had to be used by September 30, 2022; that guidance affected states’ operational capacity to support participants (for example, child care or short‑term financial help) but did not itself rewrite statutory work participation requirements [2].
3. Federal rulemaking and long‑standing regulation remained the framework
The TANF final rule and related ACF materials reaffirm that while states have flexibility to design TANF programs, the federal government regulates where Congress directs and enforces compliance with work participation rates, time limits and other statutory features; ACF’s final rule guidance also explains how prior welfare waivers and good‑cause exceptions (e.g., domestic violence waivers) figure into whether states face penalties [4].
4. States retained large discretionary space — federal guidance mostly directed reporting and funding use
Multiple ACF and OPRE publications stress that TANF is a block grant program in which states decide benefit levels, activity mixes and eligibility criteria subject to federal parameters; the Welfare Rules Databook catalogues wide cross‑state variation in eligibility and work rules as of July 2022, illustrating how federally issued guidance and funds operate within, rather than replace, state policy choices [3] [5].
5. Practical effect in 2022: funding and supports could ease compliance, not change targets
PEAF guidance gave states temporary resources to provide NRST benefits and administrative support through ARP funds (deadline September 30, 2022), a practical tool that could help families meet work requirements (by addressing barriers like short‑term needs) even though federal reporting, WPR targets and waiver rules continued to govern compliance [2] [1].
6. Waivers and “good cause” carve‑outs matter but are limited and reviewed
ACF’s rule materials state that welfare reform waivers and federally recognized “good cause” domestic violence waivers can affect whether states are judged noncompliant or subject to penalties; ACF also indicates it evaluates prior waivers in assessing corrective compliance and penalty relief, so waivers remained a narrow mechanism to modify how federal rules applied to a given state [4].
7. What the sources do not say (limitations)
Available sources do not enumerate any single 2022 federal action that suspended or broadly rewrote TANF work participation statutory targets for that year; they do not provide examples of specific states changing their statutory WPR targets in response to PEAF or other 2022 guidance, and they do not claim that PEAF replaced or waived federal work requirements (not found in current reporting) [2] [1] [4].
8. Competing perspectives implicit in the record
ACF and OPRE materials frame federal actions as balancing state flexibility with accountability (emphasizing reporting, caseload reduction credits and waiver review) while pandemic funding guidance portrays federal intervention as targeted relief to help families; advocacy or policy critiques are not in the provided documents, so alternative claims about whether federal guidance in 2022 relaxed work obligations are not documented in these sources [4] [2] [3].
Bottom line: in 2022 federal action took the form of reporting requirements and time‑limited ARP/PEAF guidance that altered what states could fund to help TANF families — potentially easing the practical path to meeting work rules — but existing ACF rulemaking and waiver processes continued to define statutory work participation obligations and penalty exposure [1] [2] [4] [3].