How did 2022 changes to TANF work requirements or sanctions vary by state?
Executive summary
States diverged sharply in 2022 on TANF work requirements and sanctions: 37 states/territories faced a zero percent overall federal work participation target for FY2022 while 26 were structured so they were not subject to the two‑parent federal work requirement [1]. Federal reporting and the Urban Institute/ACF Welfare Rules Databook show wide state variation in whether unemployed applicants must job‑search, the presence or elimination of full‑family sanctions, and pandemic‑era waivers or relaxations of sanctions [2] [3] [4].
1. Federal framework sets floors, not uniform rules
Federal law requires states to meet an overall and a two‑parent work participation rate or face potential penalties, but the administration’s guidance and caseload credits mean many states had minimal or zero targets in 2022 — 37 states/territories had a zero percent overall target for FY2022 and 26 structured programs to avoid the two‑parent requirement [5] [1]. The practical result is a patchwork: federal metrics exist, but how states count activities, apply exemptions, and use caseload reduction credits produces widely different obligations [5] [1].
2. State-by-state policies varied on upfront job search and activity rules
The Welfare Rules Databook and companion graphical brief document specific, state‑level choices: in July 2022 the maximum monthly earnings to qualify and whether unemployed applicants had to search for a job differed by state — for example, only 16 states/territories required unemployed applicants to conduct a job search at application [2] [3]. Those administrative choices translate into meaningful differences in who is deemed eligible and what activity is required to begin receiving aid [2] [3].
3. Sanctions: some states reduced or eliminated full‑family penalties
Advocates and state legislatures moved in different directions in 2022. National reporting and advocacy tracking show some states eliminated or curtailed full‑family sanctions that once cut benefits for children when a parent failed to meet work rules; New York is cited as having eliminated full‑family sanctions and repealed lifetime bans tied to certain convictions [6] [7]. Other states retained or modestly reduced sanctions; state legislative actions such as Colorado’s HB22‑1259 explicitly reduced punitive sanctions and raised cash assistance levels [8].
4. Pandemic-era changes created temporary loosening that some states kept
During COVID, many states temporarily waived work requirements, eased sanctions, or adopted automatic recertification; Urban Institute’s review found most states made some pandemic policy changes but the specifics varied by state and program and many changes were time‑limited [4]. Those temporary relaxations affected 2020–2022 implementation and produced different post‑pandemic policy decisions across states [4].
5. Implementation choices affect state compliance and measured outcomes
ACF memos and Urban/ASPE research show states used multiple strategies to meet federal participation targets — creating unpaid work slots, prolonging caseload inclusion, or moving families to state‑funded programs — and those administrative choices altered who was counted as meeting work requirements and who faced sanctions [9] [5]. The consequence: two states with similar labor markets can report divergent work participation rates and sanctioning patterns because of counting rules and program design [9] [5].
6. Policy debate: punishment versus support
Research and advocacy cited by federal reports and nonprofits frame the 2022 variation as a values contest. Proponents of stricter requirements argue work participation promotes self‑sufficiency; critics and health researchers show easing sanctions and waiving requirements improves health and stability — for example, studies linking pandemic relaxations to better physical and mental health and calls from CBPP to eliminate full‑family sanctions [8] [7] [10]. Both perspectives appear in the sources: federal guidance emphasizes meeting participation targets [5], while advocacy and research document harms from punitive sanctions and benefits from loosening rules [7] [8] [10].
7. Limits of available reporting and what’s not in the sources
Available sources provide detailed tables and state snapshots for July 2022 and fiscal year reporting, but they do not offer a single, centralized list of every 2022 legislative change to work or sanction rules by state in narrative form; detailed legislative timelines and some state implementation specifics are not found in the current reporting [3] [4]. For granular, up‑to‑the‑minute lists of 2022 statutory changes by state, the Welfare Rules Databook tables and state agency manuals cited by ACF are the primary resources [3].
8. What to watch next
Federal reporting continued to show zero targets and variable two‑parent applicability into FY2023 and FY2024 reports; ACF memos note states must still report participation data and may face corrective plans or discretionary exceptions if they fail targets [1] [11]. State legislative sessions and advocacy campaigns reported in 2022–2024 (for example, Louisiana doubling benefits and Oregon changing resource limits) indicate that states will keep diverging in how strictly they enforce work rules versus investing TANF funds in cash assistance and supports [12] [3].
Sources: ACF/OPRE Welfare Rules Databook and graphical brief (July 2022) [2] [3], ACF TANF IMs on work participation rates FY2021–FY2023 [5] [1] [11], Urban Institute pandemic policy review [4], ASPE/academic and advocacy pieces on sanctions and state reforms [9] [7] [8] [10] [12].