TEMPORARY 

ASSISTANCE FOR 

NEEDY FAMILIES

More Accountability 

Needed to Reflect 

Breadth of Block 

Grant Services

Report to Congressional Requesters

December 2012

GAO-13-33

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-33, a report to 

congressional requesters

December 2012

TEMPORARY ASSISTANCE FOR NEEDY 

FAMILIES

More Accountability Needed to Reflect Breadth of 

Block Grant Services

Why GAO Did This Study

The TANF block grant, created as part 

of the 1996 welfare reforms, gives 

states flexibility to make key decisions 

about how to allocate funds to provide 

services to low-income families. The 

number of families receiving cash 

assistance declined by over half within 

the first 5 years of TANF, and states 

shifted their TANF priorities to other 

forms of aid, or non-cash services. In 

fiscal year 2011, states spent about 64 

percent of nearly $31 billion in federal 

and state funds for such services, with 

federal funds accounting for nearly $9 

billion. GAO examined (1) how states 

have used TANF funds for non-cash 

services and (2) what information is 

available to assess TANF performance

for non-cash services and what 

challenges are involved in doing so. 

GAO reviewed past reports and 

relevant federal laws and regulations; 

analyzed state TANF expenditure

information; and interviewed HHS 

officials, TANF experts, and officials in 

10 selected states through site visits 

and phone conferences. These 10

states accounted for nearly half of all 

TANF spending for non-cash services 

in fiscal year 2010.

What GAO Recommends

Congress may wish to consider ways 

to improve reporting and performance 

information so that it encompasses the 

full breadth of states’ uses of TANF 

funds. GAO recommends that HHS 

develop a detailed plan with timelines 

to revise reporting categories for TANF 

expenditures. In its response, HHS 

provided some timeframes that we 

added to the report, although we 

maintain a more detailed plan will help 

HHS monitor its progress in completing 

this effort. 

What GAO Found

Nationwide, states have used Temporary Assistance for Needy Families (TANF) 

block grant funds not only to provide cash assistance, but also to provide noncash services, such as job preparation and work supports for low-income families 

and aid for at-risk children. Among our 10 selected states, job preparation and 

work activities included help with the job search process, skills training, and 

subsidized employment. California generally provides such services to families 

receiving cash assistance while the other nine states extend some of them to

other low-income families. Florida and Utah provide such services in coordination 

with the Workforce Investment Act one-stop center system. Work supports 

among these states mainly include child care subsidies for low-income working 

families. Services for at-risk children include child welfare activities, such as child 

abuse hotlines, investigative and legal services, child protection, and preventive 

services. TANF has allowed states to make funding decisions based on state 

priorities, particularly as cash assistance caseload declines freed up funds for 

non-cash services. However, according to officials in three states GAO reviewed, 

state decisions to fund a broad array of services can create tensions and tradeoffs between meeting cash assistance and other service needs. 

TANF’s accountability framework provides incomplete information on how states’ 

non-cash services are contributing to TANF purposes. Plans that states submit to 

the Department of Health and Human Services (HHS) outlining how they intend 

to run their TANF programs provide limited information on goals and strategies

for non-cash services. In addition, past HHS reports and selected states 

identified some weaknesses in TANF expenditure reporting. For example, 

officials in one selected state noted that the use of TANF funds for child welfare 

services is not clearly identifiable in HHS’s reporting categories for TANF 

expenditures. HHS is working to revise reporting categories, with a goal of

implementing them for fiscal year 2014. No reporting requirements currently 

mandate performance information specifically on families receiving non-cash 

services or TANF’s role in filling needs in prominent spending areas for TANF 

funds, like child welfare. These reporting gaps limit the information available for 

oversight of TANF block grant funds by HHS and Congress. Generally, HHS has 

limited authority to impose new TANF reporting requirements on states unless 

directed by Congress. While GAO’s previous work on grant design highlights 

several features of grants, such as broad and varied purposes, that pose 

challenges to the development of performance information and measures, it also 

lays out accountability principles that can help address these issues for TANF. 

Percentage of Federal and State Funds Spent on Cash Assistance and Non-Cash Services 

from Fiscal Years 1997 to 2011 

View GAO-13-33. For more information, 

contact Kay E. Brown at (202) 512-7215 or 

brownke@gao.gov.
Page i GAO-13-33 Non-Cash TANF

Letter 1 

Background 4

States Use Flexible Federal TANF Funds to Emphasize Job 

Preparation and Work Supports for Low-Income Families and 

Services for At-Risk Children 14

TANF’S Accountability Framework Provides Incomplete 

Information on States’ Use of TANF Funds 26

Conclusions 33

Matter for Congressional Consideration 33

Recommendation for Executive Action 33

Agency Comments and Our Evaluation 34

Appendix I HHS Categories of Expenditures for Cash Assistance and 

Non-Cash Services on the Form ACF-196 36

Appendix II TANF Spending Areas for Non-Cash Services 39

Appendix III Selected State Profiles 40

Appendix IV Comments from the Department of Health and Human 

Services 51

Appendix V GAO Contacts and Staff Acknowledgments 53

Related GAO Products 54

Tables

Table 1: HHS Categories of Expenditures on the Form ACF-196 36

Table 2: Nationwide Federal TANF and State MOE Expenditures as 

Reported on HHS’s Form ACF-196 for Fiscal Year 2011 37

Table 3: TANF Spending Areas for Non-Cash Services 39

Contents 
Page ii GAO-13-33 Non-Cash TANF

Figures

Figure 1: Percentage of Federal TANF and State MOE Funds Spent 

on Cash Assistance and Non-Cash Services Nationwide 

from Fiscal Years 1997 to 2011 8

Figure 2: Percent of Federal TANF and State MOE Funds Spent 

Nationwide on Non-Cash Services from Fiscal Years 1997 

to 2011 9

Figure 3: Percentage of Federal TANF Funds Used for Non-Cash 

Services by States in Fiscal Year 2011 10

Figure 4: Number of Families with Children under Age 18 in 

Poverty and AFDC/TANF Cases from 1988 through 2010 

(in thousands) 12

Figure 5: Federal TANF Funds Used by States for Non-Cash 

Services Nationwide by Spending Area in Fiscal Year 2011 15

Figure 6: Top Spending Areas for States’ Federal TANF Funds for 

Non-Cash Services in Fiscal Year 2011 16

Figure 7: State Spending of Federal Funds on Child Welfare in 

Fiscal Year 2010 19

Figure 8: Examples of How State Policies May Affect the Allocation 

of Resources for Child Care Subsidies 22

Figure 9: Florida State Agencies Receiving Federal TANF Funds in 

Fiscal Year 2010 24

Abbreviations

AFDC Aid to Families with Dependent Children

CCDF Child Care and Development Fund

HHS U.S. Department of Health and Human Services

MOE maintenance of effort

PRWORA Personal Responsibility and Work Opportunity 

 Reconciliation Act of 1996

SSBG Social Services Block Grant

TANF Temporary Assistance for Needy Families

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-13-33 Non-Cash TANF

United States Government Accountability Office

Washington, DC 20548

December 6, 2012

The Honorable Max Baucus

Chairman

The Honorable Orrin Hatch

Ranking Member

Committee on Finance

United States Senate

The Honorable Tom Coburn

Ranking Member

Permanent Subcommittee on Investigations

Committee on Homeland Security and Governmental Affairs

United States Senate

In 1996, the federal government made sweeping changes to federal 

welfare policy by replacing the previous cash assistance program with the 

Temporary Assistance for Needy Families (TANF) block grant. The 

Personal Responsibility and Work Opportunity Reconciliation Act of 1996 

(PRWORA),1 which created TANF, ended the Aid to Families with 

Dependent Children (AFDC) program that had entitled eligible families to 

monthly cash assistance. Instead, Congress has provided $16.5 billion in 

TANF funds to states each year to operate their own welfare programs 

within federal guidelines. At the federal level, the U.S. Department of 

Health and Human Services (HHS) is responsible for overseeing TANF 

programs. The number of families receiving cash assistance declined by 

over half within the first 5 years of TANF, and states shifted their TANF 

spending priorities to other forms of aid, which we refer to as non-cash 

services.2

 

1 Pub. L. No. 104-193, 110 Stat. 2105.

TANF funds may be used for a broad array of non-cash 

2 Federal law governing TANF generally refers to the term “assistance” and does not 

make distinctions between different forms of aid funded by TANF. However, HHS draws 

distinctions between “assistance” and “nonassistance.” HHS regulations define assistance 

to include cash, payments, vouchers, or other forms of benefits designed to meet families’ 

ongoing, basic needs. 45 C.F.R. § 260.31. HHS also generally includes in assistance 

services, such as child care and transportation assistance for parents who are 

unemployed. HHS uses the term nonassistance to refer to TANF expenditures that fulfill 

one of the four TANF purposes, but do not meet this regulatory definition. In our report, we 

refer to HHS’s definition of assistance as “cash assistance” and its reference to 

nonassistance as “non-cash services.” 

 
 

Page 2 GAO-13-33 Non-Cash TANF

services, ranging from job preparation activities to emergency aid for 

housing, energy, food, and clothing. In fiscal year 2011, states spent 

about two-thirds of total federal TANF and state-related funds (about 

$19.5 billion out of $30.6 billion) on a range of non-cash services for 

families who receive cash assistance and other low-income families.3

Although a large share of federal TANF and state-related funds are spent 

on non-cash services, we reported in 2006 that little information exists on 

the numbers served by TANF funds beyond those receiving cash 

assistance, what services are funded, and how these services fit into a 

strategy or approach for meeting TANF goals.4 More recently, in 2012 we 

noted that this information gap hinders decision makers in determining 

the success of TANF and what trade-offs might be involved in any 

changes to the TANF block grant.5

To answer our research objectives, we reviewed relevant federal laws 

and regulations as well as past reports related to non-cash services and 

performance measurement. We also reviewed and analyzed HHS data 

and documents related to state reports of national and state TANF 

expenditures from fiscal years 1997 through 2011. Expenditures reported 

in any given year may include adjustments made by states to data 

reported in prior years. Through reviews of previous GAO reports and 

interviews with HHS officials, we determined the data to be sufficiently 

You asked us to provide information 

on non-cash services to help inform the potential reauthorization of the 

TANF block grant. This report examines: (1) how states have used TANF 

funds for non-cash services, and (2) what information is available to 

assess TANF performance for non-cash services and what challenges 

may be involved in improving performance information.

 

3 For the purposes of our report, TANF expenditure data includes American Recovery and 

Reinvestment Act of 2009 funds provided in fiscal years 2009 and 2010 to states with 

increased caseloads, or with increased expenditures on non-recurrent short-term benefits 

or subsidized employment. It also includes TANF Contingency funds provided to states 

when certain triggers indicate increased needs. It excludes allowable transfers states 

made to the Social Services Block Grant (SSBG) for states to provide social services to 

meet certain needs of individuals residing within each state and the Child Care and 

Development Fund (CCDF) for states to provide child care subsidies for low-income 

families.

4 GAO, Welfare Reform: Better Information Needed to Understand Trends in States’ Uses 

of the TANF Block Grant, GAO-06-414 (Washington, D.C.: March 3, 2006).

5 GAO, Temporary Assistance for Needy Families: Update on Program Performance, 

GAO-12-812T (Washington, D.C.: June 5, 2012). 
 

Page 3 GAO-13-33 Non-Cash TANF

reliable for providing TANF expenditure information as reported by states. 

We also conducted interviews with HHS officials and TANF experts as 

well as semi-structured interviews with officials in 10 selected states, 

including the District of Columbia, to provide more in-depth information on 

state TANF spending for non-cash services as well as TANF reporting 

and performance measures. State interviews were conducted through 

four site visits to Arkansas, the District of Columbia, Louisiana, and 

Washington as well as six phone conferences with California, Colorado, 

Florida, Illinois, New York, and Utah.6 Furthermore, we collected 

additional information from selected states on these topics using a data 

collection instrument. We focused on TANF-funded programs and 

services for fiscal year 2010 in our selected states, as this was the latest 

year for which information was available when we selected states for our 

study. States were judgmentally selected to capture a variety of state 

characteristics, including the proportion of federal and state funds states 

spent on TANF non-cash services; the proportion spent for specific noncash services including child welfare, emergency aid, and other services, 

job preparation and work activities, and work supports such as child care; 

the total amount of federal and state expenditures for non-cash services; 

and organizational, geographic, and other considerations. While these 10 

states accounted for nearly half of all federal and state spending for TANF 

non-cash services in fiscal year 2010, the results from our interviews are 

not generalizable to all states. In addition, we relied on a survey of states 

funded by the Annie E. Casey Foundation and Casey Family Programs to 

describe how states generally fund their child welfare systems.7

We conducted this performance audit from December 2011 to December 

2012 in accordance with generally accepted government auditing

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

We found 

the survey’s data reliable for these purposes.

 

6 For the purposes of our report, we include the District of Columbia when we refer to 

states. In addition, we include expenditure information from Puerto Rico when discussing 

national expenditure data for fiscal years 2007 through 2009. 

7 Kerry DeVooght et al., Federal, State, and Local Spending to Address Child Abuse and 

Neglect in SFYs 2008 and 2010, Child Trends, (Washington, D.C.: June 2012). 
 

Page 4 GAO-13-33 Non-Cash TANF

PRWORA ended AFDC, which provided states with federal funds to 

share states’ costs for monthly cash assistance to eligible low-income 

families, and created TANF. Congress has provided states with $16.5 

billion per year in fixed federal TANF funding to cover cash benefits, 

administrative expenses, and services primarily targeted to needy 

families; the amount does not vary according to the number of cash 

assistance recipients, referred to as the TANF caseload. Under TANF, 

states are given flexibility in setting various welfare program policies. For 

example, states generally determine cash assistance benefit levels and 

eligibility requirements. States are also generally allowed to spend TANF 

funds on other services as long as these services meet TANF purposes, 

which are: (1) to provide assistance to needy families so that children 

may be cared for in their own homes or homes of relatives; (2) to end 

dependence of needy parents on government benefits by promoting job 

preparation, work, and marriage; (3) to prevent and reduce out-ofwedlock pregnancies; and (4) to encourage two-parent families.

Federal law sets some conditions for states receiving federal funds for 

TANF. For example, states are required to maintain a specified level of 

their own past spending on certain welfare programs to receive all of their 

TANF funds, referred to as state maintenance of effort (MOE). In addition, 

states must ensure that a minimum percentage of families receiving cash 

assistance meet work participation requirements set in law, referred to as 

the work participation rate. Activities creditable towards meeting work 

participation rates are defined in federal law and are generally focused on 

participants gaining employment, work-related skills, and vocational 

education. States that do not meet minimum work participation rates may 

be penalized by a reduction in their block grant. States can use various 

policy options to help them meet their work participation rates, such as by 

reducing cash assistance caseloads and spending state funds for TANF

purposes above the required MOE amount. In addition, states are limited 

in the amount of time they can provide federal cash assistance to 

families. In general, states may not use federal TANF funds to provide 

cash assistance to a family that includes an adult who has received cash 

assistance for 5 years or more.8

 

8 States may extend federal cash assistance benefits beyond 5 years for up to 20 percent 

of their caseloads for families experiencing “hardship,” which is defined by the states. 

States may also use their own state MOE funds to provide cash benefits to families 

beyond 5 years.

Such time limits do not apply to other 

TANF-funded services.

Background 
 

Page 5 GAO-13-33 Non-Cash TANF

The Deficit Reduction Act of 2005 reauthorized the TANF block grant9

and included changes expected to strengthen the work participation rate 

requirement for states, among other changes. TANF is authorized 

through March 27, 2013.

Federal law sets forth the basic TANF reporting requirements for states. 

For example, states are required to provide information and report on 

their use of TANF funds to HHS through quarterly reports on 

demographic and economic circumstances and work activities of families 

receiving cash assistance, state TANF plans outlining how each state 

intends to run its TANF program, and quarterly financial reports providing 

data on federal TANF and state MOE expenditures, among other things. 

HHS reviews state information and reports to ensure that states meet the 

conditions outlined in federal law. For example, HHS uses information on 

demographic and economic circumstances and work activities of families 

receiving cash assistance to determine whether states are meeting work 

participation rates.

For quarterly financial reports, HHS collects information on two types of 

state expenditures.10

1. Assistance, which we refer to throughout the report as cash 

assistance, primarily includes monthly cash payments directed at 

ongoing, basic needs.11

2. Nonassistance, which we refer to throughout the report as non-cash 

services, can include any other services meeting TANF purposes. 

These include services such as job preparation activities, child care 

and transportation assistance for parents who are employed, family 

formation efforts, and child welfare services, as well as some cash 

 

9 Pub. L. No. 109-171 § 7101, 120 Stat. 4, 134.

10 These two types of expenditures are broken into various expenditure categories that 

states report on quarterly through HHS’s Form ACF-196. For more information on the 

categories on the Form ACF-196 and nationwide fiscal year 2011 expenditures, see 

appendix I.

11 While we refer to assistance as “cash assistance” in our report, a small portion of 

spending in this category includes spending for services such as child care and 

transportation assistance for parents who are unemployed. A benefit can fall into this 

category if it is designed to meet on-going basic needs, even if it is not in the form of cash, 

such as a voucher for a specific service or in an electronic form. 

HHS Oversight 

Responsibilities
 

Page 6 GAO-13-33 Non-Cash TANF

benefits such as non-recurring short-term benefits and refundable tax 

credits to low-income working families.12

The distinction between cash assistance and non-cash services is 

important because only families that receive cash assistance are included 

in the work participation rate calculation and are subject to time limits on 

receiving federally-funded cash assistance. Such conditions do not apply 

to families who receive non-cash services.

Amid concerns regarding limited information on TANF expenditures, 

Congress included additional reporting requirements in the Claims 

Resolution Act of 2010,13 which extended TANF authorization through 

September 2011. The act required states to submit additional information 

to HHS on nonassistance (or non-cash services) broadly categorized on 

HHS’s expenditure reporting form as either “other” or “authorized solely 

under prior law” for March 2011 and April through June 2011.14 The act 

only required these reports in 2011, and did not require on-going 

reporting for following years. Expenditures in these categories made up 

nearly 28 percent of all federal TANF and state MOE spending for noncash services nationwide in fiscal year 2011, and the resulting reports 

indicated that over half of them were for child welfare services.15

The major contrasts between the funding structure of the TANF block 

grant and its predecessor became apparent in the early years of TANF. 

When TANF was first implemented in fiscal year 1997, on average over 

 

12 While we refer to nonassistance as “non-cash services” in our report, some portion of 

spending in this category includes some cash benefits, such as those mentioned above as 

well as costs that may not be considered services, such as administration and systems 

costs. 

13 Pub. L. No. 111-291, 124 Stat. 3064.

14 The “authorized solely under prior law” category includes expenditures that are not 

consistent with the purposes of TANF but are allowable for activities provided under prior 

law. States reported various expenditures under this category, such as for juvenile justice 

or state foster care payments.

15 Under the act, states are required to report “other” expenditures for both federal TANF 

and state MOE funds. The act also required states to provide additional detail to HHS on 

the work participation of families receiving cash assistance. See HHS, Engagement in 

Additional Work Activities and Expenditures for Other Benefits and Services: A TANF 

Report to Congress (Washington, D.C.: August 1, 2011) and Engagement in Additional 

Work Activities and Expenditures for Other Benefits and Services: A TANF Report to 

Congress (Washington, D.C.: February 13, 2012). 

National Trends in TANF 

Expenditures 
 

Page 7 GAO-13-33 Non-Cash TANF

3.9 million families were receiving cash assistance every month. This 

number declined by over half within the first 5 years of TANF, and 

averaged about 1.9 million families in fiscal year 2011. The composition 

of the overall TANF caseload also changed, with the percentage of “childonly” cases increasing from about 23 percent from July through 

September 1997 to over 40 percent in fiscal year 2010. These cases 

consist of families receiving cash assistance on behalf of children only, in 

contrast to other cases in which adults in the families also receive 

benefits on their own behalf. Generally, in child-only cases, the parent or 

adult caregiver is not eligible for benefits for one or more of a variety of 

reasons, such as receipt of other federal benefits or immigration status.16

With the financial structure of the block grant, states have generally 

maintained access to their full TANF block grant allocation each year and 

have still been required to meet minimum MOE requirements, even as 

cash assistance caseloads declined. We examined issues related to the 

federal-state fiscal partnership under TANF in 2001 amid concerns that 

states would replace their own spending with federal TANF funds—

thereby freeing up state funds for other purposes, including tax relief.17

Although we have not updated this work, we found at that time that the 

MOE requirement, in many cases, limited the extent to which states used 

their federal funds to replace state funds.18 Declining cash assistance 

caseloads also freed up federal TANF funds that states could save under 

a “rainy day fund” for use in future years, providing states additional 

flexibility in their budget decisions. In fact, we reported in 2010 that many 

states had some TANF reserves that they drew down to meet increasing 

needs in the recent economic downturn.19

 

16 GAO, TANF and Child Welfare Programs: Increased Data Sharing Could Improve 

Access to Benefits and Services, GAO-12-2, (Washington, D.C.: October 7, 2011). 

17 GAO, Welfare Reform: Challenges in Maintaining a Federal-State Fiscal Partnership, 

GAO-01-828 (Washington, D.C.: August 10, 2001). 

18 TANF does not include a provision that prohibits states from using federal TANF funds 

to replace state funds. However, if they did so, they may have had to increase their own 

spending on other low-income programs to satisfy minimum MOE requirements. For 

example, a state could withdraw its own funds from a state refundable earned income tax 

credit for low-income families and use federal TANF dollars instead. However, it would 

need to have enough other state spending to count toward its MOE requirement. 

19 GAO, Temporary Assistance for Needy Families: Implications of Recent Legislative and 

Economic Changes for State Programs and Work Participation Rates, GAO-10-525

(Washington, D.C.: May 28, 2010). 
 

Page 8 GAO-13-33 Non-Cash TANF

Over time, states also used TANF flexibility to shift spending to non-cash 

services. In fiscal year 1997, nationwide, states spent about 23 percent of 

federal TANF and state MOE funds on non-cash services. In contrast, 

states spent almost 64 percent of federal TANF and state MOE funds for 

these purposes in fiscal year 2011 (see fig. 1).

Figure 1: Percentage of Federal TANF and State MOE Funds Spent on Cash Assistance and Non-Cash Services Nationwide 

from Fiscal Years 1997 to 2011

The shift in combined federal TANF and MOE spending over time is also 

reflected in federal and state spending when considered separately. In 

fiscal year 1997, nationwide, states spent about 23 percent of federal 

TANF funds for non-cash services, compared to about 58 percent in fiscal 

year 2011 (see fig. 2). An even greater shift occurred in MOE spending 

patterns over time. While in fiscal year 1997, nationwide, states spent 

about 23 percent of state MOE funds for non-cash services, this rose to 

about 70 percent in fiscal year 2011.
 

Page 9 GAO-13-33 Non-Cash TANF

Figure 2: Percent of Federal TANF and State MOE Funds Spent Nationwide on NonCash Services from Fiscal Years 1997 to 2011

The increased emphasis on non-cash services is widespread among the 

states. Thirty-four states spent half or more of their federal TANF funds 

for non-cash services in fiscal year 2011. Fifteen of these states spent 

three-quarters or more of their federal TANF funds in this way (see fig. 3).
 

Page 10 GAO-13-33 Non-Cash TANF

Figure 3: Percentage of Federal TANF Funds Used for Non-Cash Services by States in Fiscal Year 2011

Note: Expenditures reported may include adjustments made by states in prior years. Also, the data 

reflect federal TANF funds used by states. In addition, states may spend state MOE funds for cash 

assistance and non-cash services.

The move away from traditional cash assistance toward non-cash 

services by states is not necessarily driven by reduced need for cash 

assistance among low-income families. Several factors have affected the 

early decline and continued low levels of cash assistance since states 

implemented TANF. The initial decline occurred during a strong economy 

where federal support for work supports like child care increased and 

TANF provided new program emphasis on work. Many former welfare 

recipients increased their income through employment, and employment 

rates among single parents increased. At the same time that some 

families worked more and had higher incomes, others had incomes that 

left them still eligible for cash assistance. However, many of these eligible 

families were not participating in the program. According to our estimates 

in a 2010 report, the vast majority—87 percent—of the caseload decline 

through 2005 can be explained by the decline in eligible families 

The Decline in TANF’s 

Cash Assistance Role
 

Page 11 GAO-13-33 Non-Cash TANF

participating in the program, in part because of changes to state welfare 

programs.20 These changes included mandatory work requirements; 

changes to application procedures; lower benefits; policies such as 

lifetime limits on assistance; diversion strategies such as providing onetime, non-recurring benefits instead of monthly cash assistance to 

families facing temporary hardships; and sanctions for non-compliance, 

according to a review of the research. Among eligible families who did not 

receive cash assistance, 11 percent did not work, did not receive meanstested disability benefits, and had very low incomes. While we have not 

updated this analysis, some recent research shows that this potentially 

vulnerable group may be growing.21 Overall, the relationship between the 

number of families in poverty and those receiving cash assistance 

through TANF is not as strong as it has been in the past (see fig. 4).

 

20 GAO, Temporary Assistance for Needy Families: Fewer Eligible Families Have 

Received Cash Assistance Since the 1990s, and the Recession’s Impact on Caseloads 

Varies by State, GAO-10-164 (Washington, D.C.: Feb. 23, 2010). 

21 Pamela Loprest and Austin Nichols, The Dynamics of Disconnection for Low-Income 

Mothers, Focus, Vol. 28, No. 2, (Fall/Winter 2011-2012). 
 

Page 12 GAO-13-33 Non-Cash TANF

Figure 4: Number of Families with Children under Age 18 in Poverty and AFDC/TANF Cases from 1988 through 2010 (in 

thousands)

Note: Poverty data were measured from March through March of each year. Caseload data were 

measured for each calendar year.

Some low-income families not receiving cash assistance may be 

receiving other forms of aid or services (non-cash services) funded by 

federal TANF or state MOE funds, as allowed under TANF. However, the 

number receiving this aid is not known because it is not reported by 

states and is not included in TANF program data.

This report generally focuses on how states have spent federal TANF 

funds, but state MOE spending also plays an important role in TANF. Our 

previous work has shown that the overall amount of state MOE spending 

has increased in recent years. More specifically, we reported in 2012 that 

according to HHS data, state MOE expenditure levels remained stable 

around the required minimum spending level of $11 billion through fiscal 

year 2005, and then increased to about $4 billion higher than this 

minimum in fiscal years 2009 and 2010.22

 

22 GAO, Temporary Assistance for Needy Families: State Maintenance of Effort 

Requirements and Trends, 

As we noted in that report, 

GAO-12-713T (Washington, D.C.: May, 17, 2012).

The Role of State MOE 

Expenditures in TANF
 

Page 13 GAO-13-33 Non-Cash TANF

several reasons likely accounted for these increases, including states’ 

reliance on higher levels of MOE spending to help them get credit toward 

meeting their TANF work participation rate, as allowed under federal 

regulations, as well as to gain access to the full amount of contingency 

funds available to states that meet certain criteria related to increased 

need.23 We noted that states generally began relying on MOE spending to 

get credit toward meeting TANF work participation rates in fiscal year 

2007 because of statutory changes in allowable activities made to the 

rate requirements enacted in 2006. 

Our previous and current work highlights some ways in which states may 

have increased their MOE spending in recent years. We reported in 2012 

that the number of states that reported counting third party 

nongovernmental expenditures toward their state MOE spending 

increased over the past 5 years.24 In addition to its own spending, a state 

may count toward its MOE certain in-kind or cash expenditures by third 

parties, such as a nongovernmental organization like a food bank, as long 

as the expenditures meet other MOE requirements, including those 

related to eligible families and allowable activities.25 In addition, while we 

did not fully explore states’ MOE spending in this current work, officials in 

a number of states selected for our study discussed new ways in which 

they have claimed MOE funds to meet TANF requirements. For example, 

officials in one state said they began claiming MOE expenditures for an 

existing state early-childhood education program for needy families in 

fiscal year 2008. Officials in two other states said they hired consultants 

during the economic downturn to identify opportunities to claim MOE 

expenditures from existing state programs that were not originally used 

for TANF purposes. For example, one state found that many of its 

programs could be counted under TANF as “prevention of out-of-wedlock 

pregnancies” so claimed funds spent on these programs as MOE. 

As noted in our previous work, we have not reviewed HHS’s existing 

efforts to monitor MOE and cannot comment on its effectiveness in doing 

so. However, the extent to which states have relied on third party and 

 

23 A capped amount of funds, referred to as the Contingency Fund, was created at the 

same time as TANF that helps states meet increased need under certain conditions.

24 GAO, Temporary Assistance for Needy Families: More States Counting Third Party 

Maintenance of Effort Spending, GAO-12-929R (Washington, D.C.: July 23, 2012).

25 45 C.F.R. 263.2(e).
 

Page 14 GAO-13-33 Non-Cash TANF

existing state expenditures to help them meet work participation rate

requirements as well as MOE requirements generally highlights the 

importance of having reasonable assurances that current oversight is 

working. If MOE claims do not actually reflect maintaining or increasing 

service levels, low-income families may not be getting the services they 

need, particularly in the current fiscal environment. 

In fiscal year 2011, nationwide, the top areas of state spending of federal

TANF funds for non-cash services were child welfare, emergency aid, 

and other services; job preparation and work activities; and work supports 

including child care.26 Among the 10 states we reviewed, target 

populations for services and delivery methods differed within and across 

these three spending areas. State decisions on how to allocate funding 

for non-cash services were influenced by state priorities and TANF’s 

funding structure, according to officials we interviewed.

In fiscal year 2011, nationwide, states spent federal TANF funds for noncash services in common areas including child welfare, emergency aid, 

and other services; job preparation and work activities; and work supports 

including child care. These spending areas accounted for 70 percent of 

over $8.7 billion in federal TANF funds spent on non-cash services 

nationwide that year (see fig. 5).

 

26 We combined HHS TANF expenditure reporting categories under “spending areas” for 

the purposes of our report. For example, the “child welfare, emergency aid, and other 

services” spending area includes expenditures categorized as “authorized solely under 

prior law” and “other” for non-cash services by HHS, the “job preparation and work 

activities” spending area includes the “work related activities” category, and the “work 

supports” spending area includes “child care” and “transportation” categories for parents 

who are employed. For a crosswalk of HHS TANF expenditure reporting categories and 

our spending areas, see appendix II.

States Use Flexible 

Federal TANF Funds 

to Emphasize Job 

Preparation and Work 

Supports for LowIncome Families and 

Services for At-Risk

Children 

States Focus Federal 

Funds for Non-Cash 

Services in Common Areas 

but Can Differ in Target 

Populations and Service 

Delivery
 

Page 15 GAO-13-33 Non-Cash TANF

Figure 5: Federal TANF Funds Used by States for Non-Cash Services Nationwide by 

Spending Area in Fiscal Year 2011

a

Data for this analysis exclude allowable transfers states made to the Social Services Block Grant 

(SSBG) and the Child Care and Development Fund (CCDF), two other HHS programs that provide 

funds to states to provide social services and subsidize child care for low-income families, 

respectively. States transferred nearly an additional $1.6 billion in federal TANF funds to CCDF for 

states to provide child care subsidies for low-income families in fiscal year 2011. b

Federal TANF funds for administrative costs are capped at 15 percent of the grant amount, excluding 

systems costs related to monitoring and tracking the program.

c

In this spending area, “cash-related benefits” include non-recurring, short-term benefits to families 

that could be in the form of cash to help with a family’s specific need; it does not include expenditures 

for cash assistance.

As shown in figure 6, based on each state’s spending for non-cash 

services, these areas—child welfare, emergency aid, and other services; 

job preparation and work activities; and work supports—also represented 

the three areas most frequently emphasized by states. For example, 18 

states spent the largest percentage of their federal TANF funds for noncash services for child welfare, emergency aid, and other services and 17 

states spent the largest percentage for job preparation and work 

activities.
 

Page 16 GAO-13-33 Non-Cash TANF

Figure 6: Top Spending Areas for States’ Federal TANF Funds for Non-Cash Services in Fiscal Year 2011

a

Data for this analysis exclude allowable transfers states made to SSBG and CCDF. States 

transferred nearly an additional $1.6 billion in federal TANF funds to CCDF for states to provide child 

care subsidies for low-income families in fiscal year 2011.

The spending area referred to as child welfare, emergency aid, and other 

services includes a range of services categorized as “authorized solely 

under prior law” and “other,” which were primarily child welfare services. 

According to expenditures reported by states in HHS’s report to Congress 

required by the Claims Resolution Act of 2010 for April through June 

2011,27 states spent over 54 percent of federal funds categorized as 

“authorized solely under prior law” and “other” combined on child welfare 

services.28

 

27 This report was based on one quarter (3 months’ worth) of a fiscal year of state 

spending, and may not reflect percentages based on a full year of data. However, it gives 

an indication of the types of services provided and reported under the “authorized solely 

under prior law” and “other” categories.

States spent an average of 29 percent of their federal TANF 

28 In addition, states spent 19 percent of federal funds categorized as “authorized solely 

under prior law” and “other” on TANF program expenses, such as salaries and benefits for 

TANF workers, case management, and other operating costs; 17 percent on services 

such as domestic violence, mental health, and youth education programs; 5 percent on 

emergency aid; and the remaining 5 percent on additional expenditures. States reported 

on spending categorized as “authorized solely under prior law” combined for both cash 

assistance and non-cash services, and HHS did not break out state spending between 

these two types of assistance. 
 

Page 17 GAO-13-33 Non-Cash TANF

funds for non-cash services in this area, ranging from under 5 percent in 

12 states to over 85 percent in 2 states.29

TANF requires each state to engage a specified percentage of families 

receiving cash assistance in work or work-related activities, and 

combined, states had spending on job preparation and work activities 

totaling over $1.9 billion in fiscal year 2011. Nationwide, 17 states had 

these services as a top spending area for federal TANF funds for noncash services that same year. Overall, states spent an average of about 

25 percent of their federal TANF funds for non-cash services in this area, 

ranging from under 5 percent in eight states to 79 percent in one state.30

Eight states had work supports as a top spending area for federal TANF 

funds for non-cash services in fiscal year 2011. We reported in 2006 that 

growth in TANF spending for work supports, particularly for child care, 

reflected state efforts to support employment as these supports helped 

many families formerly receiving cash assistance maintain jobs.

Expenditures are not reported in a way to determine what portion of 

spending in this area is spent on those receiving cash assistance versus 

other eligible low-income individuals.

31 States 

spent an average of about 13 percent of their federal TANF funds for noncash services in this area, ranging from under 5 percent in 25 states to 67 

percent in 1 state.32

While states spent a large portion of their federal TANF funds in these 

areas, we found in our interviews with selected states that target 

populations for services and delivery methods can differ. The following 

provides examples of these differences in our selected states for child 

welfare, emergency aid, and other services; job preparation and work 

activities; and work supports.

 

29 One state had spending in this area that exceeded 100 percent of its spending for noncash services. As noted above, expenditures reported in any given year may include 

adjustments made by states to data reported in prior years. A positive change to data from 

a prior year could show amounts that exceed total expenditures for a category.

30 As mentioned, expenditures reported may include adjustments made by states to prior 

years. Also, our data reflects federal TANF funds used by states. In addition, states may 

spend state MOE funds in these areas. 

31 GAO-06-414. 

32 This excludes TANF funds states transferred to CCDF.
 

Page 18 GAO-13-33 Non-Cash TANF

Among our selected states, federal TANF funds were used to support 

child welfare services, such as child abuse hotlines, investigative and 

legal services, child protection, and preventive services as well as 

emergency aid, such as clothing and shelter. Child welfare services are 

generally provided to children and their families to prevent the occurrence 

of child abuse or neglect, to help stabilize the family and prevent the need 

to remove the child from the home if abuse has occurred, and to improve 

the home and enable the child to reunite with his or her family if the child 

has been removed from the home. Officials in several of our ten selected 

states said that TANF funds helped expand existing child welfare 

programs that were also funded with other federal sources, such as Title 

IV-E of the Social Security Act for foster care payments and adoption 

assistance, Medicaid for health care coverage for low-income individuals 

including children, Title IV-B of the Social Security Act for child and family 

services to promote the welfare of children, and Social Services Block 

Grant (SSBG) funds for states to provide social services to meet certain 

needs of individuals residing within each state. The officials noted that 

TANF’s flexibility allowed them to meet budgetary needs in this area. One 

study shows that states rely on federal TANF funds to help support 

children and families served by state child welfare agencies (see fig. 7).33

 

33 Ibid. DeVooght et al., Federal, State, and Local Spending to Address Child Abuse and 

Neglect.

Child Welfare, Emergency Aid, 

and Other Services 
 

Page 19 GAO-13-33 Non-Cash TANF

Figure 7: State Spending of Federal Funds on Child Welfare in Fiscal Year 2010

Note: This figure excludes data from Rhode Island and West Virginia as well as Puerto Rico. “SSBG” 

includes funds transferred from TANF to SSBG. “Other” includes funds both dedicated to child 

welfare and other federal dollars.

In addition to child welfare services, selected states used funds in this 

spending area to provide a variety of other services. For example, the 

District of Columbia used federal TANF funds to support homeless 

shelters, provide case management, and conduct home visits to families 

formerly receiving cash assistance.

Among our selected states, job preparation and work activities included 

job readiness training related to resume-writing and interview preparation, 

help with the job search process, skills training, and subsidized 

employment. These activities provided work-related assistance that 

typically counts toward the state’s work participation requirement, and 

that the state must track for reporting and compliance purposes. Officials 

in one selected state noted that they also provided activities such as 

English as a Second Language courses that do not count toward meeting 

work participation requirements. Officials in 5 of our 10 selected states 

said they provide services like resume and interview assistance through 

contractors or directly through the state.

Job Preparation and Work 

Activities 
 

Page 20 GAO-13-33 Non-Cash TANF

While selected states provided similar services, the populations served 

and delivery methods often differed. For example, California targets its 

non-cash services to families receiving cash assistance, with the 

exception of those receiving short-term aid in an effort to divert them from 

the caseload. Its TANF-funded services promote job preparation and 

work activities directed at this population. Other states we reviewed said 

they provide certain non-cash services to low-income families regardless 

of whether they receive cash assistance. For example, Arkansas and 

Washington use federal funds from TANF to partner with local colleges 

and businesses to provide tailored education and training opportunities 

designed to meet the needs of local industries. Arkansas officials said 

that the state’s Career Pathways program provides eligible individuals 

who have children, such as cash assistance recipients and those with 

incomes up to 250 percent of the federal poverty line,34 with education 

and career training at participating community colleges for high demand 

jobs. Arkansas officials noted that the program was originally going to be 

supported using federal funds under the Workforce Investment Act, but 

these funds were not available, so TANF funds were used instead. 

Meanwhile, Florida and Utah coordinate work-related services with those 

provided through the Workforce Investment Act one-stop center system, 

through which job seekers can access most federally-funded employment 

and training programs and services.

Among our selected states, work supports primarily included child care 

subsidies or vouchers for low-income families that are working, which 

may include those receiving cash assistance. Selected states provided 

child care services similarly through statewide child care systems, 

counties, or contract vendors. Officials in several selected states said 

they use TANF funds to provide child care services in combination with 

federal funds from the Child Care and Development Fund (CCDF), which 

helps states provide child care subsidies for low-income families. This 

practice of using both TANF and CCDF funds for child care services was 

also noted in our previous work, which indicated that states use a 

combination of TANF, CCDF, TANF funds transferred to CCDF, SSBG, 

 

34 This is equivalent to $47,725 for a family of three in fiscal year 2012.

Work Supports

Opportunities for Improving Efficiency 

in Employment and Training Programs

We reported in 2011 on options to colocate

services and consolidate administrative 

structures in federal employment and 

training programs to promote efficiencies, 

including services provided through the 

Workforce Investment Act and TANF. 

Florida and Utah blended Workforce 

Investment Act and TANF funding, and 

Utah officials noted that this had allowed 

them to expand the population served as 

well as provide more intensive services for 

low-income families. Officials in two other 

selected states told us that coordination 

was difficult to do since different program 

rules and requirements apply to the 

Workforce Investment Act programs and 

TANF, and they target different 

populations. We recommended that the 

Department of Labor and HHS disseminate 

information about state efforts to 

consolidate administrative structures and 

co-locate services and, as warranted, 

identify options for increasing incentives to 

undertake these initiatives. Both agencies 

agreed with our recommendations, and 

have taken some steps to implement them.

For more information on our 2011 study, 

see GAO, Multiple Employment and 

Training Programs: Providing Information 

on Colocating Services and Consolidating 

Administrative Structures Could Promote 

Efficiencies, GAO-11-92 (Washington, 

D.C.: January 13, 2011).
 

Page 21 GAO-13-33 Non-Cash TANF

and state funds to provide child care subsidies to low-income families. 

Officials in several of our selected states said that TANF funds helped 

them address unmet needs and expand services provided through CCDF 

to larger populations. However, they also noted that even with these 

combined funding sources, they have had waitlists for child care 

subsidies in their state. Our prior work shows that waitlists are not always 

an accurate indicator of need. For example, in our 2005 and 2010 reports 

on the decline of the number of children served by CCDF, we noted that 

states have made changes since 2001 that could decrease the number of 

families that can access child care but could also provide larger subsidies 

to those who receive services.35

 

35 GAO, Child Care: Additional Information Is Needed on Working Families Receiving 

Subsidies, 

These included eligibility and enrollment 

changes, increased provider payment amounts, and increased copayment amounts for families (see fig. 8). An official we spoke with in one 

state said that they do not use waitlists, and instead adjust key features of 

their child care subsidy program, such as eligibility criteria, to match the 

resources they have available. These adjustments allow them to avoid 

waitlists but also make some families that could potentially benefit from 

the program unable to participate.

GAO-05-667 (Washington, D.C.: June 29, 2005) and Child Care: Multiple 

Factors Could Have Contributed to the Recent Decline in the Number of Children Whose 

Families Receive Subsidies, GAO-10-344 (Washington, D.C.: May 5, 2010).
 

Page 22 GAO-13-33 Non-Cash TANF

Figure 8: Examples of How State Policies May Affect the Allocation of Resources for Child Care Subsidies

a

The term “transitioning families” refers to families transitioning off of receiving cash assistance 

through the TANF program or that have recently received TANF cash assistance.

For additional information on selected states’ TANF programs and 

spending for non-cash services, see appendix III.36

TANF’s funding structure has given states flexibility in making decisions 

regarding non-cash services. As mentioned earlier, the dramatic caseload 

declines during the first few years of TANF’s implementation allowed 

states to spend federal funds not used on cash assistance for new or 

existing non-cash services. For example, Louisiana officials said their 

state’s caseload declines freed up federal TANF funds for new programs 

to encourage marriage, provide pre-kindergarten services, and help 

prevent out-of-wedlock pregnancies. In fiscal year 2010, Louisiana spent 

71 percent of its federal TANF funds for non-cash services on these 

efforts. Further, they noted that caseloads continued to decline or stayed 

the same, since many families that would have been eligible for cash 

assistance left the state following Hurricane Katrina.

 

36 As mentioned for our selected states, we focused on TANF-funded programs and 

services for fiscal year 2010 as this was the latest information available when we selected 

states for our study.

State Decisions for NonCash Services are 

Influenced by TANF’s 

Funding Structure and 

State Priorities
 

Page 23 GAO-13-33 Non-Cash TANF

Officials in several other selected states also said that federal TANF 

funds were spent on existing or new programs according to state 

legislative priorities, and, as a result, funds are often allocated to and 

administered through multiple state and local agencies. This is in contrast 

to TANF’s predecessor program, AFDC, which was typically administered 

through state welfare agencies. More specifically, in 2 of our 10 selected 

states, officials said that federal TANF funds were allocated directly to a 

lead agency, usually the state TANF office, which may have allowed it to 

focus funds in specific areas. For example in Utah, federal TANF funds 

were generally provided first to its Department of Workforce Services. 

While the department had agreements with other state agencies to 

provide services, 63 percent of its federal TANF funds for non-cash 

services in fiscal year 2010 were used for job preparation and work 

activities. Similarly, in Louisiana, federal TANF funds were generally 

provided to the state Department of Child and Family Services, which 

used interagency agreements to support its emphasis on the family 

formation and out-of-wedlock pregnancy prevention efforts mentioned 

above. In contrast, federal TANF funds can be allocated to multiple

agencies through a state’s annual legislative budget process. For 

example in Florida, federal TANF funds went to several agencies that 

provided a variety of services to low-income families as well as those 

receiving cash assistance (see fig. 9). Florida officials said legislative 

priorities can shift from year to year, and recent emphasis has been on 

out-of-wedlock pregnancy prevention programs and child welfare 

initiatives, such as protective investigations and adoption subsidies.
 

Page 24 GAO-13-33 Non-Cash TANF

Figure 9: Florida State Agencies Receiving Federal TANF Funds in Fiscal Year 2010

a

In fiscal year 2010, Florida spent 16 percent of its federal TANF funds for cash assistance and 84 

percent for non-cash services. Of federal TANF funds spent on non-cash services, 45 percent were

spent on child welfare, emergency aid, and other services; 24 percent on job preparation and work 

activities; 24 percent on work supports; 6 percent on administration and systems; 0.6 percent on 

family formation efforts; and 0.3 percent on tax credits and cash-related benefits.

States’ use of federal TANF funds for a broad array of non-cash services 

beyond traditional cash assistance can create tensions and trade-offs in 

state funding decisions, particularly in times of severe fiscal constraints. 

Officials in three of our selected states cited tensions between the need to 

provide cash assistance and the need to provide other state services. 

They noted that this has become more apparent as the number of 

families needing cash assistance increased during the recent economic 

downturn. Officials in five selected states cited recent spending 

reductions in non-cash areas including job preparation and work 

activities, and officials in one state noted the need to reduce family 

formation efforts, particularly after American Recovery and Reinvestment 

Act of 2009 funds were no longer available.
 

Page 25 GAO-13-33 Non-Cash TANF

To help manage costs, states may make changes to key elements of their 

cash assistance programs, such as adjusting eligibility criteria, benefit 

levels, and other features. For example, officials in one selected state 

said that instead of reducing spending for non-cash services to meet 

increased need for cash assistance during the recession, the state 

recently enacted more stringent eligibility criteria and reduced benefit 

amounts for cash assistance. They explained that their state legislature 

allocates TANF funds to the cash assistance program just like any other 

program for non-cash services and thus, funding is not shifted between 

programs to accommodate increased need. Almost no federal 

requirements or benchmarks exist as to eligibility criteria or benefit 

amounts or on the percentage of low-income families who are to be 

covered by a state’s cash assistance program.37 Officials in 9 of our 10 

selected states said that the state allocates funds for cash assistance 

based on caseload projections using data from previous years. 

Remaining funds are then available for non-cash services.

 

37 Eligibility criteria and benefit amounts for cash assistance can vary greatly by state. For 

example, in Arkansas, as of July 2011, for a family of three, earnings had to be equal to or 

below $279 per month in order to be eligible for cash assistance, and their maximum 

benefit amount was $204. In contrast, in California, as of July 2011, a family of three’s 

income had to be equal to or below $1,224 per month to be eligible for cash assistance, 

and their maximum benefit amount was $714. See Urban Institute, Welfare Rules 

Databook: State TANF Policies as of July 2011 (Washington, D.C.: August 2012).
 

Page 26 GAO-13-33 Non-Cash TANF

Although the TANF block grant has evolved into a flexible funding stream 

that states use to support a broad range of allowable services while also 

serving as the nation’s major cash assistance program for low-income 

families with children, the accountability framework currently in place in 

federal law and regulations has not kept pace with this evolution. As a 

result, there is incomplete information available for assessing TANF 

performance.

Under federal law and regulations, states are required to submit several 

reports to HHS related to TANF. These generally include:

• quarterly reports on demographic and economic circumstances and 

work activities of families receiving cash assistance;

• state TANF plans outlining how each state intends to run its TANF 

program, generally filed every two years;

• quarterly financial reports providing data on federal TANF and state 

MOE expenditures;

• quarterly state MOE reports providing data on families receiving cash 

benefits under separate state programs, which are funded entirely 

with state MOE funds and are not subject to certain federal 

requirements; and

• annual single audit reports resulting from required audits of nonfederal 

entities that expend federal funds.

Taken together, this set of reports and the information provided serves as 

the accountability framework in place to help HHS and Congress ensure 

that states use TANF funds in keeping with the block grant’s purposes 

and identify any program improvements that may be warranted. Yet, 

these numerous requirements provide limited information on state 

strategies for using their TANF funds for non-cash services. Our past 

work has shown that a sound accountability framework includes (1)

defining desired outcomes, (2) measuring performance to gauge 

TANF’S 

Accountability 

Framework Provides 

Incomplete 

Information on States’ 

Use of TANF Funds

Current Reporting 

Provides Limited 

Information on State’s Use 

of Funds for Non-Cash 

Services
 

Page 27 GAO-13-33 Non-Cash TANF

progress, and (3) using performance information as a basis for decisionmaking.38 This requires complete, accurate, and reliable data. However, 

this type of performance information is not available for a majority of 

TANF funds nationwide. There are no reporting requirements mandating 

performance information specifically on families receiving non-cash 

services or their outcomes, or information related to TANF’s role in filling 

needs in other areas like child welfare, even though this has become a 

more prominent spending area for TANF funds in many states.39

State TANF plans serve as a potential source of useful program 

information. However, they currently provide limited descriptions of a 

state’s goals and strategies for its TANF block grant, including how noncash services fit into these goals and strategies, and the amount of 

information in each plan can vary by state. Federal law includes general 

language on what should be included in the state TANF plan. For 

example, the law states that plans are to outline how a state will “conduct 

a program...that provides assistance to needy families with (or expecting) 

children and provides parents with job preparation, work, and support 

services to enable them to leave the program and become self-sufficient.” 

Federal law does not require states to include descriptions in their state 

plans of how they intend to use TANF funds beyond the cash assistance 

population for non-cash services, and states have used their discretion in 

determining how much detail to put in their plans.

These 

reporting gaps limit the information available for oversight of TANF block 

grant funds by HHS and Congress.

40

 

38 GAO, Executive Guide: Effectively Implementing the Government Performance and 

Results Act, 

For example, a state 

plan prepared by one of the selected states outlined its cash assistance 

program and provided descriptions of a variety of non-cash services it 

intends to provide. In contrast, the state plan of another selected state 

described its intentions to provide supportive services, particularly to 

families who have exhausted cash assistance benefits, but did not 

describe what those services would be.

GAO/GGD-96-118 (Washington, D.C.: June 1, 1996).

39 We primarily focused on examining the information available to assess TANF 

performance for non-cash services and did not fully assess the adequacy of TANF 

reporting requirements in providing information on cash assistance. 

40 HHS officials also noted that they do not have the authority to require states to include 

basic information about their cash assistance programs, including state TANF eligibility 

criteria, benefits levels, and other program features. 
 

Page 28 GAO-13-33 Non-Cash TANF

The financial reports on federal TANF and state MOE expenditures also 

provide some information on the types of non-cash services provided by 

states, but recent HHS studies and officials in most selected states we 

spoke to have noted some weaknesses in the information collected from 

states. Specifically, an HHS study from 2009 reviewed most states’ 

expenditures and noted incomplete and inconsistent information related 

to HHS’s current TANF expenditure reporting form for states. HHS 

identified similar issues in its reports to Congress required under the 

Claims Resolution Act of 2010, which examined more detailed information 

from states on TANF expenditures reported on the form. For example, the 

reports show that spending for child welfare services is often reported in 

the “other” category for non-cash services as well as the “authorized 

solely under prior law” categories for cash assistance and non-cash 

services. In addition, the reports noted inconsistencies between states 

with the activities counted under the form’s reporting categories. Officials 

in 7 of the 10 selected states said that the form does not fully capture the 

purposes of their TANF spending. For example, one state official 

described how their state’s use of TANF funds for child welfare services is 

not identifiable in the form’s reporting categories. Also, current 

expenditure reporting does not provide data in a way that allows 

distinctions between expenditures made on behalf of cash assistance 

recipients to help them find employment and leave welfare, and 

expenditures provided to other individuals and families not directly related 

to welfare-to-work purposes.

While state plans and expenditure reports individually provide some 

information on non-cash services, even when considered together, they 

do not provide a complete picture on state goals and strategies for uses 

of TANF funds. This is because the state plan is not required to be written 

in a way that connects to HHS’s financial reporting categories. This 

makes it difficult to determine how and whether spending areas fit into 

each state’s stated goals and strategies. One state official we interviewed 

said that with the current reporting requirements, it was hard for them to 

know how much TANF funding each of their state programs were using 

and what benefit the state was getting from each program. As a result, 

the state developed an additional internal report that presents the costs of 

performing activities by program, which provides it with better information 

for assessing the return on investment for each program. Officials from 

another state also said that it might be helpful to have the state plan more 

closely tied to the TANF expenditure reporting form, but they would want 

very specific instructions for how this should be done.
 

Page 29 GAO-13-33 Non-Cash TANF

HHS officials noted the department’s recent efforts to improve TANF 

expenditure reporting and acknowledged that reporting could be improved 

in certain other areas as well. HHS officials said they are revising the 

TANF expenditure reporting form to the extent permitted by law to include 

additional reporting categories, such as those related to child welfare 

services. They said they are also revising reporting instructions for states 

to improve consistency across states. Officials noted the importance of 

considering the implications for states of any changes or additions to 

current reporting requirements. For example, some state officials we 

interviewed described how new or revised reporting requirements can 

require costly and time-consuming changes to automated and other 

systems and practices in states and localities, and need to be carefully 

considered in terms of burden and appropriate timing for states. HHS 

officials were unable to provide a detailed plan with specific timeframes 

for the reporting revisions, but said that they are working on them, that 

they will seek input from relevant parties, and that when the revisions are 

finalized, they will be shared with Congress to assist in potential TANF 

reauthorization. In commenting on a draft of this report, HHS stated that it 

intends to publish draft revisions and instructions for comment in early 

2013, with a goal of implementing the revisions for fiscal year 2014.

The work participation rate for states, established in law and focused on 

families receiving cash assistance, serves as a key performance measure 

for state TANF programs.41 This focus remains, even though the cash 

assistance component of TANF no longer reflects how most TANF funds 

are spent. Our 2010 report shows that the emphasis on the work 

participation rate as a measure of program performance has helped 

change the culture of state welfare programs so that they focus on 

moving families off cash assistance and into employment.42

 

41 An HHS official noted that the work participation rate is prominent because it can result 

in financial penalties for states that fail to meet it. PRWORA also created the TANF High 

Performance Bonus program that provided additional federal awards to states that chose 

to participate and who achieved relatively high performance on certain measures related 

to TANF purposes. Funding for these performance incentive awards was eliminated under 

the Deficit Reduction Act of 2005, although HHS still tracks information on these 

measures and reports them in its annual TANF reports to Congress.

States are 

held accountable for ensuring that a specified percentage of all families 

receiving TANF cash assistance, and considered work-eligible, participate 

42 GAO-10-525. 

A Key Performance 

Measure Focuses on Cash 

Assistance Recipients
 

Page 30 GAO-13-33 Non-Cash TANF

in one or more of the federally-defined allowable activities for the required 

number of hours each week. We noted in our 2010 report that while the 

rate specified in law is 50 percent, states have used various policy 

options, such as credits for caseload reductions and spending above 

required MOE amounts, to reduce their required rates below 50 percent, 

as permitted by law. TANF also provides states some flexibility regarding 

which families to include or exclude in calculating their rates. Our 2010 

report noted that over the years, states have typically engaged about onethird of work-eligible families in allowable work activities nationwide and 

generally met their reduced rates. State participation rates have remained 

essentially the same since TANF’s implementation, despite legislative 

changes in 2005 that were generally expected to strengthen the work 

requirements, as we also reported in 2010 and again in 2011.43 We also 

noted in 2012 that the TANF work participation rate requirements, as 

enacted, in combination with the allowable credits and flexibility provided 

to states, may not serve as an incentive for states to engage more 

families in work.44

Our previous work and our work in selected states also shows that the 

work participation rate measure may not capture aid and services that 

states believe are important and that it may also serve as a disincentive 

to work with families with complex needs. All 10 selected states were 

using federal TANF funds to offer a range of non-cash services that 

could, for example, help remove barriers to work and/or keep families off 

the cash assistance caseload. A few of these states provided emergency 

aid to help meet low-income families’ immediate needs, including 

housing, child care, and transportation.45

 

43 GAO, Temporary Assistance for Needy Families: Update on Families Served and Work 

Participation, 

These efforts are not captured in 

the key performance measure, the work participation rate. Also, some 

officials in several selected states also said that the pressure to meet 

TANF work participation rate requirements causes them to focus on the 

“ready to work” cash assistance population, which can leave the “harderto-serve” population without services.

GAO-11-880T (Washington, D.C.: September 8, 2011). 

44 GAO-12-812T. 

45 Because our report focuses on non-cash services, in our interviews with state officials 

we only referred to child and transportation assistance for parents who are employed. See 

appendix I.
 

Page 31 GAO-13-33 Non-Cash TANF

In our interviews with state officials in the 10 selected states, we found

that eight said their states had developed or are developing performance 

measures of their own that include at least some TANF non-cash 

services. Officials from seven of these eight states said that their states 

had tracked information that included the number of people served by 

some state programs that used federal TANF funds for non-cash 

services. In addition, of these eight states, officials in Washington and the 

District of Columbia said they are going through a “re-design process” for 

their cash assistance program. For example, they are more closely 

aligning services across multiple state agencies to provide 

comprehensive services to meet the individual needs of families receiving 

cash assistance and to help them attain self-sufficiency. Washington 

officials said they are developing alternative measures of family wellbeing to measure the effectiveness of TANF as a whole for these families 

under the re-designed TANF program. Examples of measures 

Washington officials are considering for families receiving cash 

assistance include examining whether parents are attaining higher levels 

of education, training, and financial literacy; whether children have 

increased access to early childhood and preschool programs; and 

whether families have increased access to health care, stable housing, 

and supports for family conflict and domestic violence.

Several features of TANF pose challenges to designing performance 

measures, as indicated by our previous work. In our 2006 report on 

improving performance accountability in grant programs, we noted that 

some grant features in particular affect the difficulties of designing 

accountability mechanisms.46

• operates as a funding stream rather than a distinct program, and

These features include the extent to which 

a grant:

• supports a limited or diverse array of objectives.

We also said in our 2012 guidance on designing evaluations that a block 

grant, with loosely defined objectives that simply adds to a stream of 

funds supporting on-going state programs, presents a significant 

 

46 GAO, Grants Management: Enhancing Performance Accountability Provisions Could 

Lead to Better Results, GAO-06-1046 (Washington, D.C.: September 29, 2006).

Selected States Are 

Developing Some 

Performance Measures for 

Non-Cash Services

Improving Performance 

Information to Include 

TANF Non-Cash Services 

Is Challenging
 

Page 32 GAO-13-33 Non-Cash TANF

challenge to efforts to portray the results of the federal program.47

Moreover, we noted in 1995 that accountability for block grants can be 

difficult since accountability provisions need to strike a balance between 

the potentially conflicting objectives of increasing state flexibility while 

attaining certain national objectives—a balance that inevitably involves 

philosophical questions about the proper roles and relationships among 

the levels of government in our federal system.48

While accountability for the TANF block grant can be challenging, general 

principles of performance measurement can help guide the development 

of improved performance information. As we cited earlier, our previous 

work noted that an essential first step in any system of performance 

information and measurement is to establish goals to be achieved 

through the relevant program or funding stream. This work also identified 

characteristics of successful performance measurement systems.

The four stated TANF 

purposes in the law that generally define allowable use of funds for states 

are broad, so the ways in which states use TANF funds can often be 

complex and varied across states. Also, as discussed previously, as 

allowed under TANF, states have used TANF funds to expand existing 

state programs that may be funded with other federal sources, such as 

Workforce Investment Act funds for employment and training services; 

CCDF funds for child care; and SSBG and Title IV-B and E funds of the 

Social Security Act for child welfare services.

49

 

47 GAO, Designing Evaluations: 2012 Revision,

These include ensuring that performance measures are tied to program 

goals, demonstrate the degree to which the desired results were 

achieved, and take into account stakeholder concerns. In addition, real 

world considerations, such as the cost and effort involved in gathering 

and analyzing data, must be taken into account while striving to collect 

sufficiently complete, accurate, and consistent data to be useful for 

decision makers. Moreover, other key decisions in establishing 

performance measures relate to whether to link penalties or rewards to 

any such measures. Although in many situations HHS can revise its 

reporting form to make adjustments to the reporting categories, generally 

HHS has limited authority to impose new TANF reporting requirements on 

GAO-12-208G (Washington, D.C.: 

January 2012). 

48 GAO, Block Grants: Issues in Designing Accountability Provisions, GAO/AIMD-95-226

(Washington, D.C.: September 1, 1995).

49 GAO/GGD-96-118. 
 

Page 33 GAO-13-33 Non-Cash TANF

states unless directed by Congress, so many changes to the types of 

performance information that states are required to report would require 

congressional action.

Over the years, TANF has clearly evolved beyond a traditional cash 

assistance program and now also serves as a source of funding for a 

broad range of services states provide to other eligible families. States 

still spend some portion of TANF funds on welfare-to-work programs for 

the cash assistance population, but their new and varied uses of TANF 

funds for non-cash services over time beyond this population raise 

questions about how state efforts are contributing to TANF purposes. Yet, 

without an accountability framework that encompasses the full breadth of 

states’ uses of TANF funds, Congress will not be able to fully assess how 

funds are being used, including who is receiving services or what is being 

achieved. We acknowledge HHS’s steps toward improving TANF 

expenditure reporting and its concerns about reporting revisions for 

states. Any efforts to require more information or make changes to 

existing reporting and performance measures must consider this potential 

reporting burden for states. At the same time, gaps in TANF reporting and 

performance information make it difficult for policymakers to fully assess 

the workings of TANF. If Congress determines that TANF, as currently 

structured, continues to address its vision for the program, improved 

reporting and performance information will be important to enhance 

Congress’ decision making and oversight of TANF in the future.

To provide better information for making decisions regarding the TANF 

block grant and better ensure accountability for TANF funds, Congress 

should consider ways to improve reporting and performance information 

so that it encompasses the full breadth of states’ uses of TANF funds.

As HHS takes steps to revise expenditure reporting for TANF to better 

understand how states use TANF funds, it should develop a detailed plan 

with specific timelines to assist in monitoring its progress for revising its 

financial reporting categories for expenditures of federal TANF and state 

MOE funds.

Conclusions 

Matter for 

Congressional 

Consideration 

Recommendation for 

Executive Action
 

Page 34 GAO-13-33 Non-Cash TANF

We provided a draft of our report to HHS for review and comment. HHS 

indicated in its general comments (see appendix IV) that it agrees that 

current reporting on TANF expenditures provides limited information on 

the range of ways in which states use federal TANF and state MOE 

funds. HHS noted that it intends to publish draft revisions to its reporting 

categories for TANF expenditures and instructions for states for comment 

in early 2013, with a goal of implementing the revisions in fiscal year 

2014. We have added this information to the report. We commend HHS’s 

efforts to improve TANF expenditure reporting, and maintain that a 

detailed plan with timelines for revising the reporting categories will 

facilitate monitoring of its progress and help ensure that the revisions are 

implemented in a timely fashion. We also agree with HHS that as it works 

to improve financial reporting, it will be helpful to develop more refined 

categories of spending than the current categories in existing federal 

reporting, and to look at overall usage of funds, including transfers and 

MOE spending. 

In addition, HHS said that it lacks the authority to require states to provide 

certain types of information in their state plans, such as plans for using 

TANF funds or meeting MOE requirements as well as strategic goals or 

performance targets or measures. HHS noted that absent a statutory 

change, it cannot add additional categories of required information to the 

state plan, and any decision to establish such new requirements is one 

for Congress to consider.

HHS also noted that the report underscores that a large share of TANF 

spending now goes to categories of spending other than cash assistance, 

and that improved information can assist in considering both appropriate 

allowable expenditure categories and the potential for performance 

measurements for these other categories of TANF and MOE spending. In 

addition to these general comments, HHS also provided us with technical 

comments that we incorporated, as appropriate.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the appropriate 

congressional committees, the Secretary of Health and Human Services, 

and other interested parties. In addition, the report will be available at no 

charge on the GAO website at http://www.gao.gov. 

Agency Comments 

and Our Evaluation
 

Page 35 GAO-13-33 Non-Cash TANF

If you or your staff have any questions concerning this report, please 

contact me at (202) 512-7215 or brownke@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. GAO staff who made key contributions to 

this report are listed in appendix V.

Kay E. Brown

Director, Education, Workforce, and Income Security Issues
Appendix I: HHS Categories of Expenditures 

for Cash Assistance and Non-Cash Services 

on the Form ACF-196

Page 36 GAO-13-33 Non-Cash TANF

Table 1: HHS Categories of Expenditures on the Form ACF-196

Assistance (Cash Assistance) Nonassistance (Non-Cash Services)

Basic assistance: cash, payments, vouchers, or other forms of 

assistance designed to meet on-going, basic needs. 

Work-related activities: work subsidies, education and training, 

and other work-related activities, such as job search and job 

readiness, job skills training, employment counseling, job 

development, and work clothes and equipment.

Child care: child care for parents who are not employed but need 

child care to participate in other work activities, such as job 

search, community service, education, or training, or for respite 

purposes.

Child care: child care provided to employed parents and as a nonrecurrent, short-term benefit (e.g., during applicant job search or to 

a recently employed parent during a temporary period of 

unemployment).

Transportation: transportation for parents who are not employed 

but need supportive services to participate in other work activities, 

such as job search, community service, education, or training, or 

for respite purposes.

Transportation: transportation provided to employed parents and 

as a non-recurrent, short-term benefit (e.g., during applicant job 

search or to a recently employed parent during a temporary period 

of unemployment).

Assistance authorized solely under prior law: expenditures that 

are not consistent with the purposes of TANF but authorized 

under prior law, such as for juvenile justice or state foster care 

payments.

Individual development accounts: contributions to individual 

development accounts, or matched savings accounts.

Refundable earned income tax credits: refundable tax credits for 

qualifying families under federal law.

Other refundable tax credits: refundable tax credits for qualifying 

families under state or local law that are consistent with the 

purposes of TANF.

Non-recurrent short-term benefits: one-time, short-term benefits to 

families in the form of cash, vouchers, subsidies, or similar form of 

payment to deal with a specific crisis situation or episode of need.

Prevention of out-of-wedlock pregnancies: prevention of out-ofwedlock pregnancy activities.

Two-parent family formation: two-parent family formation and 

maintenance activities.

Administration: administrative costs, which for federal TANF funds 

cannot exceed 15 percent of the funds available for TANF.

Systems: systems costs related to monitoring and tracking under 

the program.

Non-assistance authorized solely under prior law: expenditures 

that are not consistent with the purposes of TANF but are 

authorized under prior law, such as for juvenile justice or state 

foster care payments.

Other: other expenditures on non-cash services not covered in 

aforementioned categories, such as family preservation activities, 

parenting training, substance abuse treatment, domestic violence 

services, and case management. 

Source: GAO summary of HHS’s Form ACF-196.

Appendix I: HHS Categories of Expenditures 

for Cash Assistance and Non-Cash Services 

on the Form ACF-196
Appendix I: HHS Categories of Expenditures 

for Cash Assistance and Non-Cash Services 

on the Form ACF-196

Page 37 GAO-13-33 Non-Cash TANF

Table 2: Nationwide Federal TANF and State MOE Expenditures as Reported on HHS’s Form ACF-196 for Fiscal Year 2011

ACF-196 line

Federal TANF 

Expenditures

State MOE 

Expenditures

Total Federal TANF and 

State MOE Expenditures

1. Awarded $20,813,254,416 N/A $20,813,254,416

2. Transferred to CCDF Discretionary $1,564,877,339 N/A $1,564,877,339

3. Transferred to SSBG $1,135,445,928 N/A $1,135,445,928

4. Adjusted State Family Assistance Grant $18,112,931,149 N/A $18,112,931,149

5. Expenditures On Assistance $6,448,705,694 $4,682,701,982 $11,131,407,676

5a. Basic Assistance $5,254,652,818 $4,349,517,973 $9,604,170,791

5b. Child Care $268,016,212 $282,642,653 $550,658,865

5c. Transportation and Other Supportive Services $255,879,888 $50,541,356 $306,421,244

5d. Assistance Authorized Solely under Prior Law $670,156,776 $0 $670,156,776

6. Expenditures on Non-Assistance $8,734,643,760 $10,758,066,878 $19,492,710,638

6a. Work Related Activities / Expenses $1,927,990,980 $720,343,007 $2,648,333,987

6a1. Work Subsidies $336,434,610 $154,261,278 $490,695,888

6a2. Education and Training $179,425,211 $148,566,956 $327,992,167

6a3. Other Work Activities / Expenses $1,412,131,159 $417,514,773 $1,829,645,932

6b. Child Care $1,084,113,242 $2,322,993,702 $3,407,106,944

6c. Transportation $156,056,064 $31,401,499 $187,457,563

6c1. Job Access $12,630,313 $2,546,879 $15,177,192

6c2. Other $143,425,751 $28,854,620 $172,280,371

6d. Individual Development Accounts $2,126,290 $851,194 $2,977,484

6e. Refundable Earned Income Tax Credits $157,079,151 $1,847,939,785 $2,005,018,936

6f. Other Refundable Tax Credits $0 $528,810,084 $528,810,084

6g. Non-Recurrent Short Term Benefits $331,410,974 $390,766,769 $722,177,743

6h. Prevention of Out-of-Wedlock Pregnancies $418,507,687 $1,543,562,600 $1,962,070,287

6i. 2-Parent Family Formation and Maintenance $267,079,277 $32,806,130 $299,885,407

6j. Administration $1,313,374,517 $780,512,072 $2,093,886,589

6k. Systems $162,076,546 $48,129,036 $210,205,582

6l. Non-Assistance Authorized Solely Under Prior Law $971,928,140 $0 $971,928,140

6m. Other $1,942,900,892 $2,509,951,000 $4,452,851,892

7. Total Expenditures $15,183,349,454 $15,440,768,860 $30,624,118,314

8. Transitional Services for Employed N/A N/A N/A

9. Federal Unliquidated Obligations $1,074,584,456 N/A $1,074,584,456

10. Unobligated Balance $1,854,997,239 N/A $1,854,997,239

Source: GAO analysis of TANF expenditure data from HHS.

Note: TANF expenditure data includes American Recovery and Reinvestment Act of 2009 funds 

provided in fiscal years 2009 and 2010 to states with increased caseloads, or with increased 
Appendix I: HHS Categories of Expenditures 

for Cash Assistance and Non-Cash Services 

on the Form ACF-196

Page 38 GAO-13-33 Non-Cash TANF

expenditures on non-recurrent short-term benefits or subsidized employment. It also includes TANF 

Contingency funds provided to states when certain triggers indicate increased needs.
Appendix II: TANF Spending Areas for NonCash Services

Page 39 GAO-13-33 Non-Cash TANF

HHS’s TANF expenditure reporting form, the Form ACF-196, includes 13 

categories for states to report spending for non-cash services. We 

combined HHS TANF expenditure reporting categories under the 

following “spending areas” for the purposes of our report.

Table 3: TANF Spending Areas for Non-Cash Services

TANF Spending Area 

HHS Non-Cash Services

Categories Included from the Form ACF-196

Job preparation and work 

activities

• Work-related activities

Work supports • Child care

• Transportation

Child welfare, emergency aid, 

and other servicesa

• Non-assistance authorized solely under prior law

• Other

Tax credits and cash-related 

benefits

• Individual Development Accounts

• Refundable earned income tax credits

• Other refundable tax credits

• Non-recurrent short-term benefits

Family formation efforts • Prevention of out-of-wedlock pregnancies

• Two-parent family formation

Administration and systems • Administration

• Systems

Source: GAO definitions based on HHS’s Form ACF-196 for nonassistance (non-cash services).

a

The child welfare, emergency aid, and other services spending area includes expenditures states 

categorize as “authorized solely under prior law” and “other.” We named this spending area “child 

welfare, emergency aid, and other services” because HHS’s report to Congress under the Claims 

Resolution Act of 2010 for April through June 2011 shows that a large number of states reported 

having expenditures for child welfare services as well as emergency aid—such as housing, energy, 

food, and clothing—in these two categories. According to the report, states spent 54 percent of 

federal funds categorized as “authorized solely under prior law” and “other” combined on child welfare 

services; 19 percent on TANF program expenses, such as salaries and benefits for TANF workers, 

case management, and other operating costs; 17 percent on services, such as domestic violence, 

mental health, and youth education programs; 5 percent on emergency aid; and the remaining 5 

percent on additional expenditures. States reported on spending categorized as “authorized solely 

under prior law” for both cash assistance and non-cash services, and HHS did not break out state 

spending between these two types of assistance.

Appendix II: TANF Spending Areas for NonCash Services
Appendix III: Selected State Profiles

Page 40 GAO-13-33 Non-Cash TANF

This appendix provides selected TANF-related information—such as 

TANF caseload and spending data—as well as data on numbers of 

families and children in poverty for each of the 10 states we reviewed in 

this report: Arkansas, California, Colorado, the District of Columbia, 

Florida, Illinois, Louisiana, New York, Utah, and Washington.1

States were judgmentally selected to capture a variety of state 

characteristics including the proportion of federal and state funds states 

spent on TANF non-cash services; the proportion spent for specific noncash services including child welfare, emergency aid, and other services, 

job preparation and work activities, and work supports such as child care; 

the total amount of federal and state expenditures for non-cash services; 

and organizational, geographic, and other considerations. These 10 

states accounted for nearly half of all federal and state spending for TANF 

non-cash services in fiscal year 2010.

 

1 TANF expenditure data includes American Recovery and Reinvestment Act of 2009 

funds provided in fiscal years 2009 and 2010 to states with increased caseloads, or with 

increased expenditures on non-recurrent short-term benefits or subsidized employment. It

also includes TANF Contingency funds provided to states when certain triggers indicate 

increased needs. It excludes allowable transfers states made to the SSBG and CCDF.

Appendix III: Selected State Profiles
Appendix III

Expenditures for Cash Assistance versus Non-Cash Services

Top Three Non-Cash Services Spending Areas

Spending area

Percent of noncash servicesExamples of programs

and services provided

Job preparation

and work activities

45% Education, training, and job search 

services for TANF caseload families as well 

as incentive bonuses for families no longer 

receiving cash assistance to continue finding 

employment.

Career Pathways initiative to increase 

access to education credentials to help TANF 

caseload and other low-income families attain 

higher paying jobs through partnerships with 

local colleges and businesses.

Work supports 24% Subsidized child care services primarily

for TANF caseload families through the 

state’s child care system.

Administration and 

systems

17% Administration costs for the Departments

of Workforce Services and Human Services.

Source: GAO analysis of HHS fiscal year 2010 TANF expenditure data for federal funds and information from state officials.

State Characteristics

Population: 2,839,798

• In poverty: 534,898 (19%)

Children: 699,403

• In poverty: 193,081 (28%)

Source: 2010 American Community Survey 1-year estimates.

Design of State’s Cash 

Assistance Program

For a family of three, as of July 2011 

Income Eligibility: Earnings must 

be no more than $279 per month.

Max monthly benefit: $204

Source: The Urban Institute’s Welfare Rules Databook, 

August 2012. 

Average Number Receiving 

Cash Assistance per Month

All people

• 2010: 19,488

• 2005: 18,759 

• 1997: 53,188

Children

• 2010: 13,993

• 2005: 14,407

• 1997: N/A

Source: HHS fiscal year TANF caseload data.

Agencies Involved in 

Providing Non-Cash 

Services

State TANF Offices: 

Department of Workforce Services

Department of Human Services

Other Agencies: 

Department of Health

Department of Education

Department of Higher Education

Source: GAO analysis of state information and

interviews with state officials. 

Arkansas

Page 41 GAO-13-33 Non-Cash TANF
Appendix III

Expenditures for Cash Assistance versus Non-Cash Services

Top Three Non-Cash Services Spending Areas

Spending area

Percent of noncash servicesExamples of programs

and services provided

Job preparation

and work activities

a

46% Education and training for TANF caseload 

families only. 

Wage subsidies for TANF caseload families 

as well as other eligible low-income families 

not on the TANF caseload.

Administration

and systems

25% Administration costs for both the counties 

and the state, in addition to some related 

costs for contractors.

Child welfare, 

emergency aid,

and other services

14% Domestic violence services for TANF 

caseload families only.

Temporary transitional services such as 

child protection, family preservation, and 

case management to meet a specific crisis 

situation.

Source: GAO analysis of HHS fiscal year 2010 TANF expenditure data for federal funds and information from state officials. 

a

Programs and services are primarily administered by California’s 58 counties.

State Characteristics

Population: 36,593,372

• In poverty: 5,783,043 (16%)

Children: 9,157,681

• In poverty: 2,012,585 (22%)

Source: 2010 American Community Survey 1-year estimates.

Design of State’s Cash 

Assistance Program

For a family of three, as of July 2011 

Income Eligibility: Earnings must 

be no more than $1,224 per month.

Max monthly benefit: $714

Source: The Urban Institute’s Welfare Rules Databook, 

August 2012. 

Average Number Receiving 

Cash Assistance per Month

All people

• 2010: 1,415,960

• 2005: 1,255,635

• 1997: 2,403,510

Children

• 2010: 1,103,629

• 2005: 1,002,222

• 1997: N/A

Source: HHS fiscal year TANF caseload data.

Agencies Involved in 

Providing Non-cash Services

State TANF Office: 

Department of Social Services 

(supervises funds provided

to 58 counties)

Other Agencies: 

Department of Child Support 

Services

Department of Education

Department of Health Care 

Services

Department of Public Health

Employment Development 

Department

Source: GAO analysis of state information and

interviews with state officials. 

California

Page 42 GAO-13-33 Non-Cash TANF
Appendix III

Expenditures for Cash Assistance versus Non-Cash Services

Top Three Non-Cash Services Spending Areas

Spending area

Percent of noncash servicesExamples of programs

and services provided

Job preparation

and work activities

a

82% Child welfare services for TANF caseload 

families as well as other eligible low-income 

families not on the TANF caseload.

Homeless Prevention and Rapid

Re-housing Program, in partnership with

the Colorado Housing and Finance Authority, 

for TANF caseload families as well as other 

eligible low-income families not on the TANF 

caseload.

Administration

and systems

11% Administrative costs for both the counties 

and the state.

Tax credits and 

cash-related 

benefits

4% Child care tax credits for TANF caseload 

families as well as other eligible low-income 

families not on the TANF caseload.

Source: GAO analysis of HHS fiscal year 2010 TANF expenditure data for federal funds and information from state officials.

a

Programs and services are primarily administered by Colorado’s 64 counties.

State Characteristics

Population: 4,934,178

• In poverty: 659,786 (13%)

Children: 1,213,411

• In poverty: 210,532 (17%)

Source: 2010 American Community Survey 1-year estimates.

Design of State’s Cash 

Assistance Program

For a family of three, as of July 2011 

Income Eligibility: Earnings must 

be no more than $421 per month.

Max monthly benefit: $462

Source: The Urban Institute’s Welfare Rules Databook, 

August 2012. 

Average Number Receiving 

Cash Assistance per Month

All people

• 2010: 29,367

• 2005: 38,313 

• 1997: 79,874

Children

• 2010: 21,911

• 2005: 27,509

• 1997: N/A

Source: HHS fiscal year TANF caseload data.

Agencies Involved in 

Providing Non-cash Services

State TANF Office:

Department of Human Services 

(supervises funds provided

to 64 counties)

Other Agencies: 

Department of Health Care Policy 

and Finance

Department of Labor/Employment

Department of Public Health

and Education

Housing and Finance Authority

Source: GAO analysis of state information and

interviews with state officials. 

Colorado

Page 43 GAO-13-33 Non-Cash TANF
Appendix III

Expenditures for Cash Assistance versus Non-Cash Services

Top Three Non-Cash Services Spending Areas

Spending area

Percent of noncash servicesExamples of programs

and services provided

Work supports 40% Child care vouchers for TANF caseload 

families as well as other eligible low-income 

families not on the TANF caseload, delivered 

through the Office of the State 

Superintendent for Education.

Child welfare, 

emergency aid,

and other services

31% Child welfare services for TANF caseload 

families only, with case management 

services provided through the Department of 

Child and Family Services.

Emergency aid such as shelter, food, and 

clothing for TANF caseload families as well 

as other eligible low-income families not on 

the TANF caseload.

Home visits to TANF caseload families to 

identify barriers to employment and link 

these families to needed services.

Family formation 

efforts

13% Teen pregnancy prevention program

through the Department of Health, which 

provides sex education to young women.

Source: GAO analysis of HHS fiscal year 2010 TANF expenditure data for federal funds and information from state officials.

State Characteristics

Population: 570,953

• In poverty: 109,423 (19%)

Children: 100,353

• In poverty: 30,555 (30%)

Source: 2010 American Community Survey 1-year estimates.

Design of State’s Cash 

Assistance Program

For a family of three, as of July 2011 

Income Eligibility: Earnings must 

be no more than $588 per month.

Max monthly benefit: $428

Source: The Urban Institute’s Welfare Rules Databook, 

August 2012. 

Average Number Receiving 

Cash Assistance per Month

All people

• 2010: 19,785

• 2005: 43,077 

• 1997: 66,272

Children

• 2010: 14,149

• 2005: 32,453

• 1997: N/A

Source: HHS fiscal year TANF caseload data.

Agencies Involved in 

Providing Non-cash Services

State TANF Office:

Department of Human Services

Other Agencies: 

Addiction, Prevention and 

Recovery Services Agency

Child and Family Services Agency

Department of Health

Department of Mental Health

Office of the State Superintendent 

for Education

Rehabilitation Services 

Administration

Source: GAO analysis of state information and

interviews with state officials. 

District of Columbia

Page 44 GAO-13-33 Non-Cash TANF
Appendix III

Expenditures for Cash Assistance versus Non-Cash Services

Top Three Non-Cash Services Spending Areas

Spending area

Percent of noncash servicesExamples of programs

and services provided

Child welfare, 

emergency aid,

and other services

45% Child welfare services including protective 

investigations, abuse hotlines, case 

management, and other family safety 

activities for TANF caseload families as well 

as other eligible low-income families not on 

the TANF caseload.

Work supports 24% School readiness child care program for 

TANF caseload families as well as other 

eligible low-income families not on the TANF 

caseload.

Job preparation

and work activities

24% Education, training and work subsidies for 

TANF caseload families as well as other 

eligible low-income families not on the TANF 

caseload.

Source: GAO analysis of HHS fiscal year 2010 TANF expenditure data for federal funds and information from state officials.

State Characteristics

Population: 18,436,788

• In poverty: 3,047,343 (17%)

Children: 3,936,572

• In poverty: 923,963 (24%)

Source: 2010 American Community Survey 1-year estimates.

Design of State’s Cash 

Assistance Program

For a family of three, as of July 2011 

Income Eligibility: Earnings must 

be no more than $393 per month.

Max monthly benefit: $303

Source: The Urban Institute’s Welfare Rules Databook, 

August 2012. 

Average Number Receiving 

Cash Assistance per Month

All people

• 2010: 107,023

• 2005: 112,242 

• 1997: 447,369

Children

• 2010: 85,524

• 2005: 90,785

• 1997: N/A

Source: HHS fiscal year TANF caseload data.

Agencies Involved in 

Providing Non-Cash 

Services

State TANF Office:

Department of Children and 

Families

Other Agencies: 

Department of Education

Department of Economic 

Opportunity

Department of Health

Source: GAO analysis of state information and

interviews with state officials. 

Florida

Page 45 GAO-13-33 Non-Cash TANF
Appendix III

Expenditures for Cash Assistance versus Non-Cash Services

Top Three Non-Cash Services Spending Areas

Spending area

Percent of noncash servicesExamples of programs

and services provided

Child welfare, 

emergency aid,

and other services

39% Child welfare screening, assessments,

and investigations for TANF caseload 

families. 

Home visits and parent training for child 

welfare cases.

Job preparation

and work activities

35% Employment and training programs

provided to TANF caseload families through 

contractors administered by the state.

Work supports 19% Child care certificate and voucher program

for TANF caseload families as well as other 

eligible low-income families not on the TANF 

caseload.

Source: GAO analysis of HHS fiscal year 2010 TANF expenditure data for federal funds and information from state officials.

State Characteristics

Population: 12,543,457

• In poverty: 1,731,711 (14%)

Children: 3,086,916

• In poverty: 600,045 (19%)

Source: 2010 American Community Survey 1-year estimates.

Design of State’s Cash 

Assistance Program

For a family of three, as of July 2011 

Income Eligibility: Earnings must 

be no more than $772 per month.

Max monthly benefit: $432

Source: The Urban Institute’s Welfare Rules Databook, 

August 2012. 

Average Number Receiving 

Cash Assistance per Month

All people

• 2010: 62,009

• 2005: 98,270 

• 1997: 580,324

Children

• 2010: 54,551

• 2005: 78,163

• 1997: N/A

Source: HHS fiscal year TANF caseload data.

Agencies Involved in 

Providing Non-Cash 

Services

State TANF Office:

Department of Human Services

Other Agencies: 

Department of Children and Family 

Services

Department of Healthcare and 

Family Services

Department of Revenue

State Board of Education

Source: GAO analysis of state information and

interviews with state officials. 

Illinois

Page 46 GAO-13-33 Non-Cash TANF
Appendix III

Expenditures for Cash Assistance versus Non-Cash Services

Top Three Non-Cash Services Spending Areas

Spending area

Percent of noncash servicesExamples of programs

and services provided

Family formation 

efforts

71% Pre-kindergarten program to reduce

out-of-wedlock pregnancies and encourage 

two-parent families by increasing literacy

and responsible behavior for TANF caseload 

families as well as other eligible low-income 

families not on the TANF caseload.

Administration

and systems

12% Administration costs associated with 

multiple programs.

Job preparation

and work activities

8% Work-related activities, education, and 

skills training for TANF caseload families.

Source: GAO analysis of HHS fiscal year 2010 TANF expenditure data for federal funds and information from state officials.

State Characteristics

Population: 4,413,890

• In poverty: 825,144 (19%)

Children: 1,098,598

• In poverty: 299,779 (27%)

Source: 2010 American Community Survey 1-year estimates.

Design of State’s Cash 

Assistance Program

For a family of three, as of July 2011 

Income Eligibility: Earnings must 

be no more than $359 per month.

Max monthly benefit: $240

Source: The Urban Institute’s Welfare Rules Databook, 

August 2012. 

Average Number Receiving 

Cash Assistance per Month

All people

• 2010: 23,707

• 2005: 37,458 

• 1997: 186,565

Children

• 2010: 20,305

• 2005: 31,472

• 1997: N/A

Source: HHS fiscal year TANF caseload data.

Agencies Involved in 

Providing Non-Cash 

Services

State TANF Office:

Department of Children and Family 

Services

Other Agencies: 

Department of Education

Department of Safety/Corrections

Department of Economic 

Development

Department of Health/Hospitals

Louisiana Workforce Commission 

Source: GAO analysis of state information and

interviews with state officials. 

Louisiana

Page 47 GAO-13-33 Non-Cash TANF
Appendix III

Expenditures for Cash Assistance versus Non-Cash Services

Top Three Non-Cash Services Spending Areas

Spending area

Percent of noncash servicesExamples of programs

and services provided

Child welfare, 

emergency aid,

and other services

a

44% Child protective and preventive services 

and maintenance of a child welfare hotline

for TANF caseload families as well as other 

eligible low-income families not on the TANF 

caseload.

Administration

and systems

24% Administration costs including TANF 

eligibility determination.

Job preparation

and work activities

18% Work programs for TANF caseload families 

as well as other eligible low-income families 

not on the TANF caseload.

Source: GAO analysis of HHS fiscal year 2010 TANF expenditure data for federal funds and information from state officials.

a

Programs and services are primarily administered by New York’s 58 local social service districts. 

State Characteristics

Population: 18,879,810

• In poverty: 2,821,470 (15%)

Children: 4,242,462

• In poverty: 900,626 (21%)

Source: 2010 American Community Survey 1-year estimates.

Design of State’s Cash 

Assistance Program

For a family of three, as of July 2011 

Income Eligibility: Earnings must 

be no more than $878 per month.

Max monthly benefit: $788

Source: The Urban Institute’s Welfare Rules Databook, 

August 2012. 

Average Number Receiving 

Cash Assistance per Month

All people

• 2010: 388,226

• 2005: 490,194 

• 1997: 1,048,257

Children

• 2010: 281,814

• 2005: 342,618

• 1997: N/A

Source: HHS fiscal year TANF caseload data.

Agencies Involved in 

Providing Non-Cash 

Services

State TANF Office:

Office of Temporary and Disability 

Assistance (supervises funds 

provided to 58 local social service 

districts) 

Other Agencies: 

Office of Children and Family 

Services

Department of Health

Source: GAO analysis of state information and

interviews with state officials. 

New York

Page 48 GAO-13-33 Non-Cash TANF
Appendix III

Expenditures for Cash Assistance versus Non-Cash Services

Top Three Non-Cash Services Spending Areas

Spending area

Percent of noncash servicesExamples of programs

and services provided

Job preparation

and work activities

63% Employment, education, and job training 

services for TANF caseload families as well 

as other eligible low-income families not on 

the TANF caseload.

Subsidized employment for TANF caseload 

families.

Administration

and systems

24% Administration and systems costs for the 

state.

Family formation 

efforts

8% Healthy marriage promotion programs

through education and training.

After-school youth development programs 

to help prevent out-of-wedlock pregnancy.

Source: GAO analysis of HHS fiscal year 2010 TANF expenditure data for federal funds and information from state officials.

State Characteristics

Population: 2,730,176

• In poverty: 359,242 (13%)

Children: 862,300

• In poverty: 135,565 (16%)

Source: 2010 American Community Survey 1-year estimates.

Design of State’s Cash 

Assistance Program

For a family of three, as of July 2011 

Income Eligibility: Earnings must 

be no more than $668 per month.

Max monthly benefit: $498

Source: The Urban Institute’s Welfare Rules Databook, 

August 2012. 

Average Number Receiving 

Cash Assistance per Month

All people

• 2010: 19,106

• 2005: 22,960

• 1997: 33,805

Children

• 2010: 12,143

• 2005: 16,557

• 1997: N/A

Source: HHS fiscal year TANF caseload data.

Agencies Involved in 

Providing Non-Cash 

Services

State TANF Office:

Department of Workforce Services

Other Agencies: 

Department of Health

Source: GAO analysis of state information and

interviews with state officials. 

Utah

Page 49 GAO-13-33 Non-Cash TANF
Appendix III

Expenditures for Cash Assistance versus Non-Cash Services

Top Three Non-Cash Services Spending Areas

Spending area

Percent of noncash servicesExamples of programs

and services provided a

Job preparation

and work activities

39% Vocational education and GED support

generally through community colleges as well 

as job preparation and job search 

assistance for TANF caseload families as 

well as other eligible low-income families not 

on the TANF caseload.

Subsidized employment for TANF caseload 

families only.

Work supports 33% Child care assistance for TANF caseload 

families as well as other eligible low-income 

families not on the TANF caseload.

Administration

and systems

17% Administration and systems costs for the 

state.

Source: GAO analysis of HHS fiscal year 2010 TANF expenditure data for federal funds and information from state officials.

a

Washington officials noted discrepancies between their fiscal year-end 2010 TANF expenditure data 

with the data HHS published for that year. Officials said further that discrepancies are likely due to 

differences in reporting time frames between the state and HHS. 

State Characteristics

Population: 6,615,922

• In poverty: 888,718 (13%)

Children: 1,559,990 

• In poverty: 284,045 (18%)

Source: 2010 American Community Survey 1-year estimates.

Design of State’s Cash 

Assistance Program

For a family of three, as of July 2011 

Income Eligibility: Earnings must 

be no more than $954 per month.

Max monthly benefit: $478

Source: The Urban Institute’s Welfare Rules Databook, 

August 2012. 

Average Number Receiving 

Cash Assistance per Month

All people

• 2010: 169,967

• 2005: 144,425

• 1997: 254,039

Children

• 2010: 117,759

• 2005: 100,838

• 1997: N/A

Source: HHS fiscal year TANF caseload data.

Agencies Involved in 

Providing Non-Cash 

Services

State TANF Office:

Department of Social and Health 

Services

Other Agencies: 

Employment Security Department

State Board for Community and 

Technical Colleges

Department of Commerce

Department of Early Learning

Source: GAO analysis of state information and

interviews with state officials. 

Washington

Page 50 GAO-13-33 Non-Cash TANF
Appendix IV: Comments from the Department 

of Health and Human Services

Page 51 GAO-13-33 Non-Cash TANF

Appendix IV: Comments from the 

Department of Health and Human Services
Appendix IV: Comments from the Department 

of Health and Human Services

Page 52 GAO-13-33 Non-Cash TANF
Appendix V: GAO Contacts and Staff 

Acknowledgments

Page 53 GAO-13-33 Non-Cash TANF

Kay E. Brown, (202) 512-7215 or brownke@gao.gov

In addition to the contact named above, Robert Campbell, Gale Harris, 

Kristy Kennedy, Nhi Nguyen, Michael Pahr, and Michelle Loutoo Wilson 

made significant contributions to all aspects of this report. Also 

contributing to this report were James Bennett, Elizabeth Curda, Rachel 

Frisk, Alexander Galuten, Kathleen van Gelder, Thomas James, Edward 

Leslie, Jennifer McDonald, Ellen Phelps Ranen, Almeta Spencer, and 

Walter Vance.

Appendix V: GAO Contacts and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgements 
Related GAO Products

Page 54 GAO-13-33 Non-Cash TANF

Temporary Assistance for Needy Families: Update on Program 

Performance. GAO-12-812T. Washington, D.C.: June 5, 2012.

Temporary Assistance for Needy Families: State Maintenance of Effort 

Requirements and Trends. GAO-12-713T. Washington, D.C.: May 17, 

2012.

Temporary Assistance for Needy Families: Update on Families Served 

and Work Participation. GAO-11-880T. Washington, D.C.: September 8, 

2011.

Temporary Assistance for Needy Families: Implications of Recent 

Legislative and Economic Changes for State Programs and Work 

Participation Rates. GAO-10-525. Washington, D.C.: May 28, 2010.

Temporary Assistance for Needy Families: Fewer Eligible Families Have 

Received Cash Assistance Since the 1990s, and the Recession’s Impact 

on Caseloads Varies by State. GAO-10-164. Washington, D.C.: February 

23, 2010.

Welfare Reform: Better Information Needed to Understand Trends in 

States’ Uses of the TANF Block. GAO-06-414. Washington, D.C.: March 

3, 2006.

Welfare Reform: States Provide TANF-Funded Work Support Services to 

Many Low-Income Families Who Do Not Receive Cash Assistance. 

GAO-02-564. Washington, D.C.: April 5, 2002.

Welfare Reform: Challenges in Maintaining a Federal-State Fiscal 

Partnership. GAO-01-828. Washington, D.C.: August 10, 2001.

Designing Evaluations: 2012 Revision. GAO-12-208G. Washington, D.C.: 

January 2012.

Grants Management: Enhancing Performance Accountability Provisions 

Could Lead to Better Results. GAO-06-1046. Washington, D.C.: 

September 29, 2006.

Block Grants: Issues in Designing Accountability Provisions. 

GAO/AIMD-95-226. Washington, D.C.: September 1, 1995.

Related GAO Products

Temporary Assistance for 

Needy Families

Accountability 

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