If the state combines TANF and MOE funds, then MOE funds will trigger the TANF requirements. If the state creates a separate state program, which is distinct from programs funded by TANF yet serves TANF-eligible populations, then participation does not trigger TANF requirements. If a state segregates MOE funds from TANF funds, within a TANF-supported program, participation supported by MOE funds is not subject to the TANF time limits, but is subject to all the other TANF requirements. Since one key TANF purpose is support of needy families, income guidelines must apply to participation in programs designed to meet that purpose. States have flexibility in determining what constitutes needy and can include families whose incomes are up to 200 percent of the poverty line.
States also can set different standards for different programs.
In the same state, transportation subsidies could be for those below 150 percent of the poverty line and child care subsidies could be for those below 200 percent. Overarching Need to Spend TANF Dollars Failure of states to spend TANF dollars puts future funding for the program in jeopardy. Many states have huge TANF surpluses, making it difficult to justify the ongoing need for TANF funds. TANF comes up for reauthorization in 2002. Failure by the states to spend TANF funds could send Congress the message that TANF is over-funded, which could lead to a substantial decrease in TANF funding.