TANF-ACF-PI-2009-12 (Use of Federal TANF funds and State Maintenance-of-Effort (MOE) funds to assist individuals from eligible families in need of mental health and substance use treatment services)
TO:
State agencies and Tribes administering the Temporary Assistance for Needy Families (TANF) program under title IV-A of the Social Security Act, and other interested parties.
SUBJECT:
Use of Federal TANF funds and State Maintenance-of-Effort (MOE) funds to assist individuals from eligible families in need of mental health and substance use treatment services.
PURPOSE:
To remind States of ways that Federal TANF funds (including TANF Emergency Fund awards issued as a result of the American Recovery and Reinvestment Act of 2009) and State MOE funds can be used to assist individuals from eligible families in need of short-term mental health and substance use treatment services.
REFERENCES:
Office of Family Assistance Funding Guide available at http://archive.acf.hhs.gov/programs/ofa/resources/funding_guide.htm.
BACKGROUND:
In this period of economic distress and hardship, mental health and substance use treatment services are in greater demand. The suicide prevention lifeline funded by the Substance Abuse and Mental Health Services Administration (SAMHSA) has seen a steady increase in call volume for the past two years and unprecedented highs in recent months. Up to 30% of these callers have cited economic and financial difficulties as the reason for their call—a difficulty that is universal to TANF recipients.
Lack of access to short-term mental health and substance use treatment services can sometimes be an underlying issue for individuals in long-term need for public assistance. Some studies have found that problematic substance use is prevalent in as many as 8%-10% of adult TANF recipients, and an overlap of serious substance use problems and mental health problems is not uncommon. The impact of mental health and substance use disorders can extend to other members of a family as well.
GUIDANCE:
To help communities address this important issue, we would like to remind States and Tribes that they have the discretion to use Federal TANF funds—including TANF Emergency Fund awards issued under the American Recovery and Reinvestment Act of 2009—and State MOE funds to assist individuals in need of mental health and substance use treatment services consistent with TANF rules on providing benefits and services to individual members of needy or eligible families. Collaboration between State Mental Health and Substance Use authorities and TANF offices in the use of TANF funds to expand the accessibility of mental health and substance use treatment services for their communities is particularly encouraged.
While TANF grantees are prohibited from using Federal TANF funds and commingled MOE funds for medical services, some mental health and substance use treatment services and supports are non-medical in nature. In addition, State MOE funds that have not been commingled with Federal TANF funds may be used to pay for some medical services (45 CFR 263.2(a)(4)(i)).
A TANF program can support an array of benefits and services to help individuals in need of mental health and substance use treatment services. For example, a jurisdiction can use Federal TANF funds to provide appropriate counseling services such as mental health services, anger management counseling, and non-medical substance use treatment services to family members with barriers to employment and self-sufficiency; Federal TANF or State MOE funds to provide non-medical substance or alcohol abuse services, including room and board costs at a residential treatment program; and State MOE funds (that have not been commingled with Federal TANF funds) to pay for medical services such as treatment of substance abuse that are not paid by Medicaid.
Services to such individuals could be considered non-recurrent short-term benefits, provided that they meet the criteria in 45 CFR 260.31(b)(1). To be a non-recurrent short-term benefit, the benefit must: be designed to deal with a specific crisis situation or episode of need; not be intended to meet recurrent or ongoing needs; and not extend beyond four months. Such benefits will not make the recipients newly subject to rules governing the receipt of assistance (e.g., subject to work requirements). Moreover, non-recurrent short-term benefits can be paid for with funds from a TANF Emergency Fund award if the State is otherwise eligible to draw down these funds in this category.
TECHNICAL ASSISTANCE RESOURCES:
TANF jurisdictions also have more resources available to them. The Office of Family Assistance has technical assistance available on its Welfare PeerTA website at https://peerta.acf.hhs.gov/ . In addition, technical assistance can be obtained through the Substance Abuse and Mental Health Administration’s website at http://www.samhsa.hhs.gov, the Treatment Referrals hotline at 1-800-662-HELP, and the National Suicide Prevention Lifeline at 1-800-273-TALK.
INQUIRIES:
Please direct inquiries to the TANF Program Manager in your Region.
/s/
Ann H. Barbagallo
Acting Director
Office of Family Assistance