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TANF-ACF-PI-1997-04 (Closeout of Accounts for the AFDC, Emergency Assistance, JOBS, AFDC/JOBS Child Care, Transitional Child Care and At-Risk Child Care Programs)

Published: August 29, 1997
Audience:
Temporary Assistance for Needy Families (TANF)
Types:
Program Instructions (PI)
Tags:
State Plans

To:

State agencies administering the Temporary Assistance for Needy Families (TANF) program, state agencies administering the Child Care and Development Fund, and other interested organizations, agencies, and individuals.

Subject:

Closeout of Accounts for the AFDC, Emergency Assistance, JOBS, AFDC/JOBS Child Care, Transitional Child Care and At-Risk Child Care programs.

Reference:

TANF-ACF-PI-97-1, dated January 8, 1997, "Financial Policies and Procedures for the Transition from AFDC/JOBS to TANF and Title VI Child Care programs.

Section 116 of Public Law 104-193, The Personal Responsibility and Work Opportunity and Reconciliation Act of 1996 (PRWORA).

Effective:

Immediately upon issuance

Purpose:

To provide additional instructions to States for closing out accounts for Aid to Families with Dependent Children (AFDC) Program (including the Emergency Assistance program), the JOB Opportunities and Basic Skills Training (JOBS) Program, and the AFDC/JOBS Child Care, Transitional Child Care, and the At-Risk Child Care programs under Title IV-A of the Social Security Act.

TANF-ACF-PI-97-1 provided initial guidance to States on claiming expenditures for these programs during the fiscal year (FY) 1997 transition year.  This program instruction provides detailed instructions on the use and frequency of reporting forms that States must follow to assure that claims for Federal reimbursement are properly charged to the AFDC, JOBS, TANF and Child Care programs.

For States implementing the TANF program in FY 1997, final State Family Assistance Grant (SFAG) amounts for FY 1997 will be determined once all State actions pertaining to the close out of the AFDC and JOBS programs have occurred.

Inquiries:

Inquiries should be directed to the appropriate Administration for Children and Families Regional Administrator.

/s/

Norman L. Thompson
Director
Office of Program Support


Closeout of the AFDC, Jobs and AFDC/

 

Jobs Child Care, Transitional Child Care and At-risk Child Care programs

This program instruction provides guidance to States for the closeout of the AFDC (including Emergency Assistance), JOBS, and the AFDC/JOBS Child Care, Transitional Child Care, and the At-Risk Child Care Programs.  As noted in TANF-ACF-PI-97-1, the transition from these programs to the TANF and Mandatory and Matching Child Care Funds requires special claiming and reporting procedures to assure that all allowable claims for Federal reimbursement are made against the proper program and appropriations accounts.

For many States, the amount of claims for expenditures in FY 1997 for the AFDC and JOBS programs will impact the State’s FY 1997 SFAG payment.  This is because section 1 16(1)(B) of PRWORA provides that total funding under AFDC, JOBS and TANF cannot exceed a State’s State Family Assistance Grant (SFAG), as determined under section 403(a)(1)(B) of the Act, for the fiscal year.  In these instructions, we will specifically identify those claims that could affect a State’s FY 1997 SFAG payment.  Because computations involving the JOBS program differ from the AFDC program, this PI includes separate procedures for JOBS.

The PI also includes procedures for the AFDC/JOBS Child Care, Transitional Child Care, and the At-Risk Child Care Programs.  Though a State may receive additional reimbursement for allowable childcare claims for expenditures made up to September 30, 1996, Mandatory and Matching Child Care allocations for FY 1997 will not be affected by such claims.  Unlike TANF, all States were required to implement Mandatory and Matching Child Care on October 1, 1996.  The AFDC/JOBS Child Care, Transitional Child Care, and At-Risk Child Care programs were eliminated effective September 30, 1996.

States should note that all expenditures that a State claims pursuant to these instructions are subject to the following conditions:

  • Expenditures must have been allowable expenditures at the time the assistance, service or administrative activity was provided;
  • Expenditures must be supported by documentation sufficient to determine the allocability of the claim;
  • Expenditures must be those for which Federal reimbursement was not already provided or disallowed; and
  • Claims for expenditures must meet the two year limit for filing claims for expenditures, in accordance with Section 1132 of the Social Security Act and 45 CFR Part 95, Subpart A. That is, the report to claim these expenditures must be received by ACF no later than (1) two years from the end of the calendar quarter in which the expenditure was made or (2) no later than deadlines established in Section F of this document, whichever is earlier.

A.  Claims for Expenditures made in FY 1997 for the AFDC Program[i]

FY 1997 claims for AFDC expenditures represent the following: (1) claims for expenditures that are made in FY 1997 for FY 1997; (2) claims made in FY 1997 for expenditures made prior to FY 1997, i.e., prior to October 1. 1996; and (3) claims for FY 1997 expenditures made for services, assistance and administration that were provided prior to September 30, 1995.[ii]

1.  Claim For Expenditures Made in FY 1997 (Federal reimbursement for these expenditures will affect the State’s FY 1997 SFAG payment.)

These expenditures represent expenditures made prior to the TANF date in FY 1997 for services, assistance and administrative activities that were provided by the State[iii] in FY 1997.

Reporting Instructions: For FY 1997. States must continue to use the ACF-231 to report AFDC and EA expenditures made in FY 1997 to claim expenditures made prior to their TANF date.  States must file an ACF-231 no later than 30 days after the end of the quarter in which the State implemented the TANF program.  The State may submit subsequent reports to claim such expenditures it identifies later, subject to the "timely filing" limits.

2.  Claims made in FY 1997 for expenditures made prior to FY 1997, i.e., October 1, 1996 (Federal reimbursement for these expenditures should not affect a State’s FY 1997 SFAG payment.)

Under the AFDC program, prior to welfare reform, States commonly claimed in later fiscal years expenditures made in a prior year.  Such expenditures made prior to FY 1997 do not reduce a State’s SFAG payment for FY 1997.  If these expenditures were claimed in the "Prior Quarter Adjustments" Column of the ACF-231 (the AFDC Financial Report) for FY 1997 and are identifiable as expenditures in quarters prior to October 1, 1996 these claims will not affect a State’s SFAG payment.

If a State has claimed expenditures made prior to October 1, 1996 as FY 1997 expenditures by including them in the "Current Quarter Expenditures" Column of an ACF-231 submitted for FY 1997, the State should submit a revised ACF-231.  Otherwise, ACF will treat these expenditures as expenditures made in FY 1997; this would reduce a State’s FY 1997 SFAG payment.  Thus, in order to assure that these expenditures are charged as FY 1996 expenditures, instead of FY 1997 expenditures, which would affect a State’s FY 1997 SFAG payment, the State must decrease its claim for FY 1997 and increase its claim for FY 1996 in the same amount.

Reporting Instructions: To increase claims for FY 1996 and decrease claims for FY 1997, States must submit a separate Part 2, "Prior Quarter Expenditure Adjustments," of the ACF-231.  Part 2 includes an attachment where States can identify the amount and period of the expenditures.  For these expenditures, the State must include in the "Other Comments" column, a statement declaring that these expenditures were claimed incorrectly initially.

3.  Claims for FY 1997 Expenditures Made for Services. Assistance and Administration Provided Prior to September 30, 1995 (Federal reimbursement for these expenditures should not affect a State's FY 1997 SFAG payment.)

As noted.  Section 116(b)(3) of PRWORA provides that expenditures made on or before September 30.  1995 are to be treated as expenditures made during FY 1995 for reimbursement purposes even if the expenditure was made by the State on or after October 1, 1995.

Therefore, if a State makes new claims (subject to the timely filing limits) or revises claims already made, it must use the Federal matching rates in effect for FY 1995, not the Federal matching rates for FY 1997.  For AFDC benefit payments, this means the Federal Medical Assistance Percentage (FMAP).

If practicable, States should review all claims for expenditures made for services, assistance and administrative activities that were conducted prior to September 30, 1995 and submit revised claims for such expenditures if Federal reimbursement for such expenditures were made pursuant to FY 1997 Federal matching rates rather than FY 1995 matching rates.  If States find this impracticable, no further action need be taken.[iv]

Reporting Instructions: To assure that new claims (as addressed two paragraphs above) for FY 1997 expenditures do not affect a State’s FY SFAG Payment, a State must identify such expenditures as "increasing adjustments" to Part 2, "Prior Quarter Expenditure Adjustments" and identify these expenditures as FY 1995 expenditures in the "Other Comment" column of Part 2.  This will assure that the State receives reimbursement for these expenditures and that its FY 1997 SFAG payment is not reduced for these expenditures.

For claims in this category that have already been reported in FY 1997, if the State does not submit revised claims using FMAP rates, then the State must follow the instructions in the above paragraph.

If a State wants to revise claims already submitted for FY 1997 in order to receive Federal reimbursement at the FY 1995 Federal matching rates and/or assure that these payments do not affect the FY 1997 SFAG payment, the State should submit a revised Part 2, Section B

"Decreasing Adjustment" reducing the current expenditures for FY 1997 and simultaneously submit an increasing adjustment claim for FY 1995 on a revised Part 2.  Section A "Increasing Adjustment."  Alternatively, the State may submit with its next quarterly submission, a Part 2.  Section B "Decreasing Adjustment" for FY 1997, reducing the current expenditures for FY 1997.  It must then submit an increasing adjustment claim for FY 1995 on a revised Part 2, Section A "Increasing Adjustment."

B.  Claims for Expenditures Made Prior to FY 1997 for AFDC

In this group, we include expenditures made prior to October 1, 1996 that were not included in Item A, above.

FY 1996 Expenditures

Expenditures made in FY 1996 can be claimed as increasing claims on Part 2.  They should be claimed at the FY 1996 Federal matching rates if they were made for services, assistance and administrative activities conducted after September 30, 1995.

If they represent new expenditures for services, assistance and administrative activities conducted before September 30, 1995, States should use the FY 1995 Federal matching rates.  The "Other Comments" column of the attachment to Part 2 should note that these are FY 1996 expenditures for assistance, services and administrative activities claimed at the FY 1995 Federal matching rates.

For expenditures for services, assistance and administrative activities conducted before September 30, 1995 that have already been claimed at the FY 1996 Federal matching rates, a State may, if practicable, revise its claim for these expenditures using the FY 1995 matching rates.  To accomplish this, the State should use Part 2 indicating on the attachment as "increasing adjustments" those expenditures made at the FY 1995 Federal matching rates and as "decreasing adjustments" those expenditures made at the FY 1996 Federal matching rates.

FY 1995 Expenditures

If the State has allowable expenditures for services, assistance and administrative activities made in FY 1995, or before, these expenditures should be claimed as "increasing adjustments" on Part 2, provided they meet the timely filing requirement of section 1132 of the Social Security Act and section 116(b)(3) of PRWORA.

C.  Claims for AFDC/JOBS Child Care. Transitional Child Care and At-Risk Child Care

The AFDC/JOBS Child Care. Transitional Child Care and At-Risk Child Care programs were eliminated as of September 30, 1996 (see section 1 16(a)(4) of PRWORA).  Thus, TANF-PI-ACF-97-1 provided that childcare expenditures made on or after October 1. 1996, regardless of when obligated, must be charged to the State’s FY 1997 Mandatory and Matching Child Care Funds.  However, there is one exception.  Because of section 1 16(b)(3) is applicable to childcare expenditures, expenditures made after September 30, 1995 for childcare services[v] provided prior to September 30, 1995 should also be treated as expenditures made during FY 1995.  Thus, such childcare services payments should be claimed at the FMAP rate in effect for FY 1995.

As with AFDC expenditures, if a State has claimed these AFDC/Transitional childcare services expenditures made after September 30, 1995 as FY 1996 expenditures for childcare services provided before September 30, 1995, a State may, if practicable, revise its claim for these expenditures using the FY 1995 rates.  To accomplish this, the State should use Part 2 indicating on the attachment as "increasing adjustments" those expenditures made at the FY 1995 Federal matching rates and as "decreasing adjustments" those expenditures made at the FY 1996 Federal matching rates.  In the "Other Comments" column, the State should note that these are FY 1996 expenditures that the State is now claiming as FY 1995 expenditures at the FY 1995 Federal matching rates.

It is possible that a State could make in FY 1997 expenditures for childcare services and administration provided prior to September 30, 1995 that would meet the timely filing limits.  These expenditures should not be reported for the new Mandatory and Matching Child Care Funds.  The State should submit claims for these expenditures using Part 2 of the ACF-231, identifying these as "increasing adjustments."

Expenditures made prior to October 1, 1996 may still be claimed for Federal reimbursement under the applicable pre-PRWORA program.  For this purpose, the State should also use Part 2 of the ACF-231 and identify such expenditures as "increasing adjustments."

At-Risk Child Care

The At-Risk Child Care program was not an open-ended entitlement like the AFDC program and AFDC/JOBS and Transitional Child Care programs.  In accordance with action transmittal CC-ACF-AT-93-2 dated February 5, 1993, an account for a fiscal year was closed on May 1 of the following fiscal year so that the carry forward of funds, where permitted, could be executed.  Thus, no adjustments can be made to fiscal year accounts prior to FY 1996.  Because FY 1996 funds cannot be carried forward to FY 1997, as there is no ARCC program effective October 1, 1996, the May 1 deadline is no longer applicable.  Thus, States have until August 21, 1998 to file claims for ARCC expenditures up to their FY 1996 maximum grant.  As with other expenditures, the claims must be made within the two-year timely filing limit.

As with other child care and AFDC expenditures, a State may, if practicable, revise for FY1996 expenditures using FY 1995 matching rates, as discussed in the second paragraph of this section, "C. Claims for AFDC/JOBS Child Care, Transitional Child Care and At-Risk Child Care," using instead the ACF-233 (the ARCC Financial Reporting Form).

D.  Claims for the JOBS Program[vi]

For the JOBS program, States will generally follow the previously prescribed reporting requirements for the ACF-33 1 Financial Reporting Form.

For FY 1996, States must liquidate by September 30. 1997 all reported obligations made in September 30, 1996 and submit a final report no later than October 30, 1997.[vii]

For FY 1997, JOBS obligations made before a State’s TANF date will be charged to the State’s FY 1997 JOBS grant.  Obligations made on or after a State’s TANF date must be charged to the State’s SFAG.  States must submit an initial ACF-331 report within 30 days after the end of the quarter their JOBS program terminates.  This report will identify the amount of funds obligated by the State as of the date the JOBS program terminates. States will have until September 30, 1998 to liquidate these obligations.  Based on amounts reported as obligated by a State, we will make an interim adjustment to a State’s FY 1997 SFAG payment.

E.  Charging of Expenditures During Transition to TANF

Consistent with the instructions contained in TANF-ACF-PI-97-1, States are reminded of the following:

For AFDC, EA and administration, expenditures made prior to the TANF Date must be reported as AFDC or EA expenditures.  For example, if a State’s monthly assistance payments for October are issued on October 1 and the State implements TANF on October 15, the total sum of the assistance payments are to be recorded as AFDC, not TANF, expenditures.  Similarly, State expenditures made after a State has started TANF, even if they are expenditures that were obligated when the State operated an AFDC program, are to be reported as TANF expenditures.

For JOBS, expenditures made to liquidate JOBS obligations made prior to a State’s TANF Date for FY 1997 continue to be reported as JOBS expenditures against the State’s FY 1997 JOBS grant; not TANF expenditures.

ACF is developing a TANF financial reporting form, which is pending 0MB approval.  Once the form is approved, the first report will be cumulative in nature and cover all prior quarters for FY 1997 for the TANF Program.

F.  Deadline for Submitting Claims for Closing Out Programs

For AFDC (including Emergency Assistance and Administration)

For AFDC, reports to claim expenditures made in accordance with these instructions for expenditures must be received by ACF no later than (1) two years from the end of the calendar quarter in which the expenditure was made or (2) August 21, 1998, whichever is earlier.  If claims are not received by August 21, 1998, the most recent financial report submitted will be used as the basis for any adjustments, especially those adjustments that are necessary to determine a State’s final FY 1997 SFAG payment.

For AFDC/JOBS Child Care and Transitional Child Care

For AFDC/JOBS Child Care and Transitional Child Care, reports to claim expenditures made in accordance with these instructions must be received by ACF no later than (1) two years from the end of the calendar quarter in which the expenditure was made or (2) August 21, 1998, whichever is earlier.  If claims are not received by August 21, 1998, the most recent financial report submitted will be used as the basis for any adjustments.

For At-Risk Child Care

For FY 1996 maximum grants, reports to claim expenditures made in accordance with these instructions must be received by ACF no later than (1) two years from the end of the calendar quarter in which the expenditure was made or (2) August 21, 1998, whichever is earlier.  If claims are not received by August 21, 1998, the most recent financial report submitted will be used as the basis for any adjustments.

For FY 1996 JOBS grants, States have until September 30, 1997 to liquidate obligations.  The ACF-331 is due in to ACF by October 30, 1997. If, after submitting the ACF-331, the State determines that it has failed to properly claim expenditures, revised reports may be submitted.   They must be received in ACF no later than August 21, 1998.

For FY 1997 JOBS grants, States have until September 30, 1998 to liquidate obligations made as of September 30, 1997. A State’s final ACF-331 report must be received in ACF no later than October 30, 1998.

(JOBS program expenditures are also subject to the two-year limit on the filing of claims. Thus, only claims that have not yet met this limit may be filed in accordance with the instructions above.)

States should note that, unlike the two year timely filing deadline established by section 1132 of the Social Security Act, the Secretary has no authority to waive the deadlines under section 116 of PRWORA.

We encourage States to complete the closeout of their accounts as soon as possible.  Closeout of the AFDC payments, administration, EA and JOBS are necessary in order to finalize certain State’s SFAG payments for FY 1997.  If ACF determines that a State is due a higher SFAG for FY 1997 after the end of FY 1997, the SFAG will be increased to represent the amount to which the State is entitled.

G.  Overpayments and Underpayments

ACF is considering the policies and procedures pertaining to the collection of overpayments and the correction of underpayments in light of Section 1 16(b)(2) of PRWORA.  We will soon be issuing guidance in a separate program instruction on t


[i] States with a TANF date of September 30 or October 1, 1996 will receive their entire FY 1997 SFAG payments. Since, for these States, all FY 1997 expenditures are TANF expenditures, instructions in this section pertaining to expenditures made in FY 1997 do not apply to these States.  Note: As stated in TANF-PI-ACF-97-l, the "TANF date" is the date the State comes under the TANF program rules.  In our letters notifying States that their TANF plans have been deemed complete, this is identified as the TANF implementation date.

[ii] As noted in TANF-PI-ACF-97-l, there is a special provision in section 116(b) (3) of PRWORA with respect to certain AFDC, Emergency Assistance and Child Care expenditures.  If the State can document that it provided assistance, service, or administrative activities prior to September 30, 1995, then the expenditures associated with these activities are to be treated as if they were expenditures made in FY 1995, even if the expenditures actually were made after September 30, 1995.

[iii] These activities would have been conducted after September 30, 1995.  As explained, Item (3) pertains to FY 1997 expenditures made for activities conducted prior to or on September 30, 1995.

[iv] Distinguishing such expenditures may be beneficial to a State if: (1) the FMAP for FY 1995 is higher than the FMAP for the year in which such expenditures were made; or (2) if the expenditures were made in FY 1997, such that our treating them as FY 1995 expenditures would increase the State’s SFAG.

[v] As the Federal reimbursement rate for AFDC/JOBS and Transitional Child Care (50 percent) is the same for FY 1995 and later years and as the implementation of this provision does not affect the method for calculating Mandatory Child Care allocations, there is no reason for States to adjust for administrative costs. Thus, we are excluding them from this discussion.

[vi] States that implemented TANF on September 30 or October 1, 1996 are subject only to the second paragraph of the instructions in this section.

[vii] JOBS expenditures made in FY 1997 to liquidate FY 1996 obligations will not affect a State’s FY 1997 SFAG payment.  The reporting deadline of October 30, 1997 applies to States with TANF dates of September 30 and October 1, 1996.