The City recommends that another criterion be added to take into account problems resulting from TANF rules that require completion of a process before full implementation of required changes are made. For example, providing complete data reports, as detailed in the appendices to the proposed rule, may be difficult for states as they begin their new programs. Developing systems to comply with the host of new required data elements will take time. We suggest language that includes allowances for problems related to changing state tracking and monitoring capacities that states are in the process of implementing but have not yet completed. We urge DHHS to include flexibility in the final regulatory language so that states may have a longer period without being subject to penalty, so long as the state achieves designated benchmarks intended to ensure compliance at the end of the specified period.
Case management is a service oriented function.
The regulation should delineate those functions that are service oriented to avoid future disputes. To the extent that programs involve the provision of services to clients, they should not be considered administrative. For example, substance abuse screening and assessment and domestic violence services should not be counted as administrative costs. States and localities should not be required to cost allocate a portion to administration. The regulations define as administrative those MIS costs not related to tracking and monitoring of TANF requirements.