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TANF-ACF-PI-2011-05 (Final Reporting and Reconciliation Procedures for the TANF Emergency Fund)

Published: March 11, 2011
Audience:
Temporary Assistance for Needy Families (TANF)
Topics:
Data Collection and Reporting, Emergency Fund, Financial, TANF Financial Data
Types:
Data Document, Program Instructions (PI)
Tags:
Social Security Act, TANF Emergency Fund

TO:

State, Territory, and Tribal agencies administering the Temporary Assistance for Needy Families (TANF) Program.

SUBJECT:

Final Reporting and Reconciliation Procedures for the TANF Emergency Fund.

REFERENCE:

Section 403(c) of the Social Security Act, TANF-ACF-PA-2009-01, TANF-ACF-PI-2009-05, and TANF-ACF-PI-2010-06

PURPOSE:

To provide guidance about reporting final data and about final reconciliation procedures.

BACKGROUND:

In Program Instruction TANF-ACF-PI-2010-06, published on August 18, 2010, the Administration for Children and Families (ACF) outlined the process for funding Emergency Fund applications in the event that total requests for funds exceeded the $5 billion appropriated for the program by the American Recovery and Reinvestment Act of 2009. In fact, total qualifying requests did exceed $5 billion, meaning that we were able to obligate the entire $5 billion by September 30, 2010, but could not fund every application we received.

It has become apparent that some jurisdictions will be returning monies to the Emergency Fund when they update previously submitted data. For example, if a jurisdiction overestimated expenditures in an earlier application, it now must return those overestimated funds. This program instruction establishes a deadline for final Emergency Fund data and provides guidance on the process we will use for reconciling expenditures and award amounts. This program instruction also describes the procedures for redistributing returned monies after that date using a process designed to treat all jurisdictions equitably.

POLICY:

We are establishing a deadline of June 30, 2011, for jurisdictions to submit final Emergency Fund data. It is necessary to establish a deadline so that we can redistribute any returned monies in a timely fashion to jurisdictions that qualify for additional emergency funds; therefore, we will not consider requests to extend the final reporting date beyond June 30, 2011. After this date, jurisdictions will not qualify for additional award amounts by submitting new applications or revisions to prior applications.

If jurisdictions return monies to the Emergency Fund, we will use the three-tiered process described below to reconcile expenditures and award amounts, and redistribute those funds to jurisdictions that qualify for additional funds.

In the three-tiered process, we distinguish between new applications received by September 1, 2010, and those received after September 1, 2010, because ACF established September 1, 2010, as the deadline for submitting applications in the instructions for completing the OFA-100, published July 20, 2009, and revised March 3, 2010. We distinguish between updates received by and after September 30, 2010, because prior ACF guidance only provided for awarding more funds based on the submission of updated data through the end of fiscal year 2010.

We also distinguish between new applications and updates to prior data. For example, if a jurisdiction has previously had an approved application for basic assistance expenditures for the first three quarters in 2010, submitting expenditures for basic assistance in the fourth quarter would constitute a new application. Any revisions to the data for any of the three quarters for which it already has an approved application would constitute an update.

We were able to fund most, but not all applications we received by September 1, 2010. Funding the remaining applications in this group will be our first priority. In tier one, we will award returned funds as they become available to jurisdictions that submitted applications on or before September 1, 2010. In addition, tier one will include any updates to previously submitted data, as long as we received those updates on or before September 30, 2010. We will distribute these funds based on the procedures described in TANF-ACF-PI-2010-06.

If there are funds available after funding all tier one applications, we will award funds in tier two for applications that involve updates to data received between October 1, 2010, and June 30, 2011, for quarters or programs in applications originally received by September 1, 2010. If there are insufficient funds, we will adjust the award amounts in this tier on a pro rata basis as described below.

If there are funds available after funding all tier one and tier two applications, we will award any remaining funds in tier three for applications received after September 1, 2010, related to expenditures for new quarters or programs. By "new" we mean that the jurisdiction did not submit a request for emergency funds by September 1, 2010, based on expenditures in the quarter or program for which it is now requesting funds. As with tier two, we will fund tier three applications only after the reporting deadline of June 30, 2011, and will prorate revised awards as described below if there are insufficient funds for all qualifying requests.

The table below summarizes the three tiers:

Tier One

Tier Two

Tier Three

  • Applications for new quarters or programs received by September 1, 2010
  • Updates to prior data received by September 30, 2010 (meaning updates to data for quarters and programs in applications originally received by September 1, 2010) 
  • Updates to prior data received after September 30, 2010 (meaning updates to data for quarters and programs in applications originally received by September 1, 2010) 
  • Applications for new quarters or programs received after September 1, 2010

If we need to make pro rata adjustments for tiers two or three, then we will base them on the ratio of the amount available in the Emergency Fund to the amount for which all jurisdictions have newly qualified in the applicable tier. If a pro rata approach is necessary for tier two, there will be no funds left to make awards for applications in tier three.

We have designed the three-tiered process to be consistent with TANF-ACF-PI-2010-06; however, to simplify our procedures and reduce any inconvenience for jurisdictions, if it is possible we will combine the process of recovering overpayments and awarding additional funds rather than requiring jurisdictions to return overpayments prior to receiving awards for applications in tier two or tier three. Where it is not possible to simplify this process, we will deobligate overpayments first and use them to make payments to jurisdictions in accordance with the procedures outlined above; we will reconcile each tier sequentially and deobligate or make an award accordingly.

INQUIRIES:

Please direct inquiries to the TANF Program Manager in your Region.

 

/s/
Earl S. Johnson
Director
Office of Family Assistance