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TANF-ACF-PI-1996-04 (Certification Pending Verification of Eligibility of Qualified Aliens With 40 Qualifying Work Quarters)

Published: December 19, 1996
Temporary Assistance for Needy Families (TANF)
TANF Guidance
Program Instructions (PI)
Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (P.L. 104-193)


State Agencies Administering The Temporary Assistance For Needy Families Program And Other Interested Parties


Certification Pending Verification of Eligibility of Qualified Aliens With 40 Qualifying Work Quarters


Section 402(b) of Public Law 104-193, the "Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA)," enacted August 22, 1996


The provision of PRWORA cited above authorizes States to determine the eligibility of qualified aliens for Temporary Assistance for Needy Families (TANF) except as provided in section 403 of the PRWORA and except for certain categories of qualified aliens under §402(b)(2)(B) who shall be eligible for TANF.  One of these eligible alien categories is permanent resident aliens who have worked 40 qualifying quarters.  The law provides that quarters worked by a parent while the individual was under age 18, or by an individual's spouse, as long as the individual and spouse are still married, may also be credited to the individual in determining the number of qualifying quarters.

The Social Security Administration (SSA) is currently developing an automated system that will be able to provide verification of quarters of coverage for applicants to State agencies on an overnight basis.  SSA expects this system to be operational in January 1997.


The purpose of this Program Instruction is to provide guidance to State and local welfare offices for certifying eligibility pending verification for TANF of permanent resident aliens who claim they have worked 40 qualifying work quarters.

Action Required:

Pending implementation of the automated verification system, the enclosed interim procedures have been developed with SSA for certifying TANF eligibility pending verification of qualified aliens who claim 40 work quarters.  State welfare agencies should follow these interim procedures in administering the 40 quarters determination.

As the enclosed procedures indicate, if a qualified alien, alone or in combination with his/her parents and/or spouse, has spent sufficient time in this country (10 years or more) to have acquired 40 quarters of coverage, the individual's claim of 40 quarters is sufficient.  The individual need only state that he or she, alone or in combination with his or her parents and/or spouse, has met the work requirement.

Please note that within 3 months after the month in which the SSA automated verification system becomes operational, State agencies should submit the required information for each qualified alien who received certification pending verification to SSA for overnight processing.  SSA will provide a quarters of coverage history for each individual and applicable family member requested.

While some qualified aliens already have 40 work quarters established in their Social Security records, others may have been employed in jobs in which earnings may not have been appropriately reported or where workers may have difficulty obtaining verification of employment.  If SSA's existing records do not verify that an individual claiming 40 quarters in fact has them and the individual believes SSA's records are not correct, SSA will work with the individual to determine whether additional quarters can be established.

Individuals in this situation should be advised of this option and should be advised that they will be allowed to participate for 6 more months provided SSA certifies that it is working to clarify their records.  The individual will be required to provide a document from SSA indicating that the number of quarters is under review.  SSA is developing a document to meet this requirement.


Certification Pending Verification Procedures for Legal Immigrants


Inquiries should be directed to the appropriate ACF Regional Administrator or to Toyo A. Biddle, Director, Division of Refugee Self-Sufficiency, Office of Refugee Resettlement at (202) 401-9250.


Lavinia Limón
Office of Family Assistance

Last Reviewed: May 20, 2019