Reflections on ACF’s New Guidance: Utilizing TANF Funds to Prevent Child Welfare Involvement

Because of ACF's mission to promote the economic and social well-being of children and communities, I have had a front-row seat to the strength and vitality of the American family. I've witnessed how across the country, in communities of every size and background, parents strive to pursue opportunity for themselves and their children. But this front-row seat has also shown me what can be behind the curtain: families who have to choose whether to put food on the table or pay the bills, or parents straining to find affordable child care so that they can go to work or school. Some of these struggling families are one unexpected medical bill, car repair, or crisis away from eviction, bankruptcy, or a total destabilization. For some parents, these economic troubles can result in their children being removed from their care due to policy and practice that equate poverty with neglect. The Administration for Children and Families (ACF) issued new guidance (PDF)to states on how to utilize the Temporary Assistance for Needy Families (TANF) program to prevent unnecessary child welfare involvement by addressing poverty-related challenges with economic-related solutions.

Neglect can affect millions of children. Each state bases its own definition of neglect on broad standards set by federal law. To be clear, states can and should protect children from neglect. Because neglect is defined state-by-state, however, it can be unclear and difficult to determine whether all cases of neglect that come to the attention of the child welfare system represent an equivalent risk of harm. What is clear is that most children in the child welfare system are there due to neglect and not abuse, with the most recent data (PDF)from 2023 showing that 64% of children who entered foster care did so because of associated reports of neglect. What is also clear is that poverty can often be conflated with neglect and that helping families move out of poverty decreases the risk to children.

Most families who live in poverty do not neglect their children. However, research tells us that families who are experiencing poverty are far more likely to be reported to the child welfare system than families with more resources. It makes sense that a job loss or other economic shock can impact the ability to provide, or that the possibility of being evicted can result in strained family dynamics and caregiving decisions. It is important to keep in mind that these may be parents who are otherwise providing a safe and loving home. The effects of poverty-related factors play out in research studies, with one study (PDF)showing that difficulty finding child care was found to be a strong predictor of maternal neglect, more so than mental health, severity of drug use, or history of abuse as a child. Another study (PDF)demonstrated that states in which TANF recipients lost benefits saw increases in both reports of neglect and foster care entries. It is important that we take a multi-system approach to alleviating family poverty, including using TANF dollars to provide economic support to families in need to prevent child welfare involvement.

TANF exists to accomplish specific goals related to family well-being, including providing assistance to families experiencing financial hardship so that children can be cared for in their own homes or in the homes of relatives (also known as "TANF purpose one"). Knowing that no two communities are alike, these structures give states the flexibility to provide services and programs that work best for families in their state to reduce poverty and improve family well-being, including preventing child welfare involvement. For example, TANF dollars can be steered to those families facing a financial crisis so that an unexpected medical bill or car repair doesn't bankrupt them or lead to child welfare involvement. Nationally, 1 out of 5 federal TANF dollars are in fact directed by states to child welfare activities, but on a state-by-state basis the expenditures can be anywhere from 0 to 52 percent of federal dollars spent. We hope that states follow ACF's guidance (PDF)that they can and should use more of their TANF dollars to directly support families and help prevent child welfare involvement.

When it comes to keeping families together, an ounce of prevention is worth a pound of cure. Foster care is an extremely costly intervention, both financially and in the potential erosion of emotional health and well-being of the family. We can decrease these costs by states investing federal dollars on the front end to provide direct support to families and lower instances of neglect related to impacts of poverty, even as we must also work to address other issues that may impact a child's safety and well-being. This common-sense approach to providing direct financial support to address poverty-related concerns is evidence-based, with research showing that cash supports to help families with concrete emergency insufficiencies results in reduced likelihood of experiencing a subsequent child maltreatment report. Through ACF's most recent guidance (PDF), we are making it clear that states can use TANF to prevent child welfare involvement through supports that include: direct cash assistance to short-term rentals and other expenses related to finding and maintaining housing (e.g., security deposits, application fees, and utility costs); subsidies for transportation, which enable parents to keep their jobs as well as access a range of services including health care, behavioral health care, and child care; and immediate concrete supports for families with young children, including clothing, child safety supplies, and other basic necessities. All of these activities are allowable under TANF purpose one. TANF has the potential to be a powerful tool of prevention and truly provide support to American families in need so that they can stay together.

We recognize that at the state level, TANF and child welfare may be housed within different state agencies, and using TANF to prevent child welfare involvement may require structural changes, political will, logistical challenges, and upending outdated mentalities on the causes and consequences of poverty. None of this is easy; but all of it is worth it. Ultimately, the goal must be to create a new context in which multiple systems work together with communities to fairly provide the support all families need to nurture their children and thrive. Our communities are full of neighbors, volunteers, churches, and community groups and organizations that stand in the gap when our fellow citizen needs help. However, effectively using dollars from programs like TANF can often be the missing support needed to help get a family back on their feet and keep them together.

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