Therefore, in our opinion, any state child care funds expended for families meeting the State s child care eligibility limits would be countable toward TANF MOE because such child care families are eligible for TANF assistance. These families need the assistance of programs that promote work and avoid dependence on cash assistance, and they are needy according to the state s child care program rules. Thus, all state funds expended for families in the state s child care program should qualify toward a state s maintenance of effort spending. The Delaware Department of Health and Social Services opposes the application of Title 45, part 92 of the federal regulations and the consequent application of OMB Circular A-87 and similar regulations to the TANF grant. We would agree that a body of regulations and instructions has evolved over the years that generally provide valuable guidance for the proper financial administration of federal funds.
Every state has similar accounting rules that mirror the essence of federal fiscal rules.
TANF empowers states to experiment with different programs that are vastly different from the welfare programs of the past sixty years. The programs are designed to fit the unique need of each state s circumstances. It is inevitable that conflicts will arise between a state s decision of what spending is reasonably calculated to accomplish the purposes of TANF and historical federal financial rules that were adopted for a much different program and a different time. States agreed to federal block grants in exchange for substantial freedom to operate their own programs and with their own rules. That includes the state s own financial and accounting rules.