Virginia Regulatory Town Hall
Agency
Department of Social Services
 
Board
State Board of Social Services
 
chapter
Locality Groupings [22 VAC 40 ‑ 293]

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12/30/19  2:59 pm
Commenter: Salaam Bhatti, Virginia Poverty Law Center

Remove the Groupings to Help People out of Poverty
 

The Temporary Assistance for Needy Families (TANF) is a federally funded, public benefit program. Virginia’s TANF program serves the poorest families in the state by providing basic cash assistance for their subsistence and ancillary services.  It currently serves Virginians divided into two different groups (Groups II and III). Group I was dissolved and merged into Group II in 2017. 

The locality groupings were created in the 1970s, have rarely been updated, and thus have grown outdated. Under the guidance of moving one county to a different grouping, there are several counties in Group II that should realistically be in Group III. But, rather than analyze the cost of living for each county and see which group they belong to, it would be more practical to simply eliminate the groupings altogether.  This would result in a single statewide standard. Such a standard would be consistent with nearly all major public benefits and health programs such as SNAP, Medicaid, and WIC.

In 2019, the maximum TANF cash payment for a family of 3 was $363/month in Group II and $442/month in Group III. Despite the $79 difference and the appearance that Group III families were faring better than Group II, both amounts were below 20% of the Federal Poverty Line.  TANF benefits have not increased with inflation and the dollar’s purchasing power has decreased significantly. TANF families remain the poorest of the poor in Virginia with insufficient income to pay for basic family needs. So despite the appearance that group II families will receive more money, both groups still receive far less than they should.

From 1996 to 2019, the cost of living increased 63.3%. However, TANF payments increased a meager 18.4%.  Going back further to 1985, a three person family received an average of $291/month. Had TANF kept pace with inflation, the monthly standards of assistance would be $676. We can see that in both Group II and III, we are far from that amount.  Families in neither group are able to get ahead with these paltry amounts. Eliminating the groupings will be the first step in helping them do just that.

CommentID: 78757
 

12/30/19  5:11 pm
Commenter: Valerie L'Herrou, Center for Family Advocacy, Virginia Poverty Law Center

Kinship families rely on child-only TANF grant
 

The “child only” TANF grant is one of the few sources of cash assistance for kinship families: those relatives who take in children who cannot remain with parents, thus bypassing the Foster Care system, relieving the state of the much greater expense—and, for local departments of social services, the case-loads—of caring for these children in foster care

In Virginia, over 55,000 children live with a relative with no parent present. 133,887 children live with grandparents; of these, 67,534 grandparents are householders financially responsible for grandchildren who live with them. While 41,128 of these grandparents are in the workforce, 9,927 are in poverty; 16,241 have a disability. Federal ACF figures indicate that child-only TANF supported only 13,359 of these children in Virginia in 2018. Grandparents who have retired and live on fixed incomes are in danger of depleting the resources they need as they age. The amount of the child-only TANF grant is not enough to cover the costs of raising a child, no matter what locality one lives in; but every little bit helps.

While the intent behind the groupings, created in the 1970’s, seems logical, it also creates inequities: the per-child amount of TANF is so small-- even with the 2019 increase-- that it barely makes a dent in a family’s budget. Every dollar a kinship family receives -- whether they receive the Group II slightly under $200 a month per child, or the Group III small amount more than that--goes to help these relatives meet the considerable needs of these children. There is not such a significant difference between the amounts per child in Group II vs Group III to justify maintaining them-- especially when the amounts in either grouping are so negligible.

Additionally, the administrative costs to determine what the current cost of living is in the localities, or which localities should be moved to another grouping, only takes funds away from those in need.

Under the existing regulations, one reason a locality may request to move into a lower grouping is if it perceives families are moving to their locality to qualify for a higher monthly payment. It is doubtful many kinship families are doing this -- or that it would even be logical to do so, since their increased costs would be higher than the few additional dollars they'd gain in such a move if they moved to a higher-cost-of-living locality -- but nonetheless, eliminating the groupings would also eliminate any such incentive.

A single statewide standard would also be consistent with nearly all major public benefits and health programs such as SNAP, Medicaid, and WIC, which pay the same even though the cost of food and other necessities vary among localities -- and is one measure of the cost of living.

CommentID: 78758
 

12/30/19  8:25 pm
Commenter: Ali Faruk, Families Forward Virginia

Strengthening family economic security
 

Families Forward Virginia supports changing the way the locality groupings work in the TANF program because it will help more low income children and families get the economic support they need. Policies that improve the socioeconomic conditions of families tend to have the largest impacts on health. Strong empirical evidence consistently links low income to children’s development, academic achievement, and health, including exposure to child abuse and neglect. Improved household financial security has proven to reduce the risk factors for child abuse and neglect. Additional financial resources will help families with children meet basic living needs including shelter, childcare and clothing. 

CommentID: 78759