Personal Responsibility, Work, and Family Promotion Act of 2002

May 14, 2002

The Honorable Dennis Hastert
Speaker of the House
U.S. House of Representatives
Washington, D.C. 20515

Dear Speaker Hastert: 

On behalf of the U.S. Conference of Catholic Bishops and Catholic Charities USA, we are writing to you concerning H.R. 4700, the Personal Responsibility, Work, and Family Promotion Act of 2002 to reauthorize the Temporary Assistance to Needy Families (TANF) block grant program. 

As we consider proposals for reauthorization, we are guided by Catholic moral principles and traditional values: respect for human life and dignity; the importance of family and the value of work; an option for the poor and the call to participation; and the principles of subsidiarity and solidarity.  We also draw upon the Church's experience living with, serving, and being the poor among us.  The Catholic community, perhaps the largest non-governmental provider of human services to poor families, meets the poor in our soup kitchens, shelters and Catholic Charities agencies.  Our community has lived with the realities of welfare reform, encouraging and helping people to make the transition from welfare to work.  But we also live with those who are left behind, who turn to our parishes, eat in our soup kitchens, sleep in our shelters and ask for our help.

In 1996, the Catholic Bishops' Conference stated that welfare reform policies should: Protect human life and dignity; strengthen family life; encourage and reward work; preserve a safety net for the vulnerable; build public/private partnerships to overcome poverty; and invest in human dignity.  Based on these principles, we believe a central goal for TANF reauthorization should be to address the moral scandal of so much poverty in the richest nation on earth.  We believe we can achieve the goal of poverty reduction through a three pronged strategy of policies that support meaningful work; strengthen marriage and family life; and sustain the needy and vulnerable among us, especially our children, and by committing to funding TANF, at a minimum, at current levels adjusted for inflation.

While we believe that certain provisions of H.R. 4700 contain promising ideas for TANF reauthorization, we cannot support the bill because of our deep concerns about aspects of H.R. 4700, including the following:

Work is the means by which individuals support themselves and their families, participate in God's creation, express their dignity, and contribute to the common good of society.  The challenge is to ensure that our nation's policies support productive work with wages and benefits that permit families to leave welfare behind and to live in dignity and self-sufficiency.  While we support continuing TANF's emphasis on work, we have deep concerns that the combined effects of several work-related provisions in H.R. 4700 would limit the flexibility of the states to continue their implementation of welfare reform in a way that meets the needs of TANF families in their state.  The bill would increase the work participation rates states must meet, from 50% to 70%, and increase the hours of activities individuals must engage in to be counted towards the work participation rates from 30 hours to 40 hours per week, with the first 24 hours restricted to employment, work experience, or community service.  Under current law, recipients are also allowed to engage in job search or vocational education activities during the first 20 hours per week, and states may place up to 30% of the caseload in full-time vocational educational training for 12 months.   Current law also provides a less stringent work requirement of 20 hours per week for single parents with children under 6 years of age, which would not be continued under H.R. 4700. The current caseload reduction credit would be replaced by a similar formula that continues to reward states for merely reducing TANF caseloads, rather than for increasing employment among TANF recipients. 

Unfortunately, the combined effect of these provisions would be to impose a "one size fits all" approach on states, instead of giving them more flexibility to design programs, including expanded ability to count appropriate education and training activities towards core work requirements, that will be effective at helping TANF families move from welfare, to work that will allow them to achieve self-sufficiency. 

Under H.R. 4700, five states would be able to turn the Food Stamp program into a block grant.  Funding would be frozen at an amount tied to 2000-2002 levels.  During economic hard times, more people turn to food stamps and spending for food stamps typically rises to meet the need.  With funding levels capped under a block grant, states would no longer be able to provide food stamps benefits to families in need, without cutting benefits or completely barring categories of people. Limiting food stamps spending to 2000-2002 levels makes it unlikely that a block grant state would allow legal immigrants to receive food stamps, even though the Farm Bill just signed by President Bush restored eligibility to many legal immigrants, because they would not be able to afford to do so.  Capping food stamps spending would also undermine efforts to make sure all eligible families receive the benefit – states would not be able to afford the increased participation rate.   

H.R. 4700 would require states to deny both federal and state benefits to entire families, including children, when a parent fails to comply with the new work requirements for two months, and would allow states to do so without regard to the reasons why the parent had failed to comply.  This is particularly troubling as experience has shown that sanctioned families tend to have more obstacles to work -- more incidence of substance abuse, family violence, and mental and physical health problems, and child care and transportation difficulties. In a Policy Brief for the Brookings Institution's "Welfare Reform and Beyond" project, Dan Bloom and Don Winstead noted that:

"Studies have found that welfare recipients who are sanctioned are a diverse group but, on average, face more barriers to employment than other recipients; they are also less likely to work after leaving welfare. Studies have also found that enforcing work requirements is important, but it is not clear whether complete termination of benefits is more effective than partial termination. We believe states should continue to have flexibility in setting sanction policies." --Sanctions and Welfare Reform, p.1, January 2002.

While it is no easy matter to develop welfare policy that ensures assistance for the needy without enabling the dependency of those who can and should support themselves, we should not require states to abandon those among us who cannot help themselves, or who, with a little more time, patience and assistance, would be able to help themselves and their families.

Besides these three important provisions which cause us concern, we very much fear that the new waiver authority for certain Cabinet Secretaries could undermine basic programs for the poor.  H.R. 4700 would grant unprecedented authority to these Secretaries to override the program requirements or funding allocations of programs under their jurisdiction at the request of Governors seeking to combine programs.  Among the programs affected could be: food stamps; the Child Care and Development Block Grant; public housing; job training programs under the Workforce Investment Act; the Social Services Block Grant; and TANF.  With this new authority, Cabinet Secretaries could allow states to change eligibility requirements, cut benefits, and redirect funding from one program to another.  The possible impact on the food stamps program, which already gives states a great deal of flexibility, illustrates our deep concern with this provision.  Since the entitlement to welfare benefits ended in 1996, the food stamps program is the last refuge for many families facing hunger and it is vitally important to low-income families that the program's integrity be maintained.  Under H.R. 4700, states could be allowed to put time limits on food stamps, reduce benefits or restrict some populations' eligibility for the program and then transfer the savings from such policies into other programs, such as child care or job training. The proposal could allow states to ignore or undo many of the key program improvements in the Nutrition Title of the Farm Bill just signed into law by President Bush, improvements the Bishops' Conference and Catholic Charities supported.  The food stamps program already lets states alter the program through waivers, but in a careful, limited manner with important protections for food stamps recipients.  The waiver provision of H.R. 4700 would eliminate those protections. 

We note that the bill does take promising steps forward in several areas.  For example, we are pleased that it includes $300 million per year in federal and state matching funds for programs to promote marriage and healthy families (although we believe it would be appropriate to target this spending on marriage and family services for low-income families) and encourages states to treat two-parent families equitably.  We are also gratified that the bill did not cut back on funding for the block grant, despite calls to do so. The bill adds poverty reduction as a goal; increases spending on child care, a pressing need now even under the current TANF work requirements; allows states to pass-through to TANF families more of the child support monies they recover; and includes funding for programs that help fathers develop the parenting skills and economic capacity needed for responsible fatherhood.  The bill also takes a step forward by allowing substance abuse treatment to count towards core work activities; however, states should have flexibility to count substance abuse treatment for a longer period of time than called for in the bill.  We hope a final TANF reauthorization bill will build on features like these, and will include other necessary improvements such as restoring benefit eligibility to legal immigrants and increasing the block grant to reflect inflation.

However, for the reasons described above, we cannot support H.R. 4700 as it is presently written.

Sincerely,

Theodore E. Cardinal McCarrick
Archbishop of Washington
Chairman, Domestic Policy Committee
U.S. Conference of Catholic Bishops

Rev. J. Bryan Hehir
President
Catholic Charities USA