Key to understanding the flexibility offered and constraints imposed by TANF is the concept of TANF "assistance." This is important because two of the more widely talked-about aspects of TANF policy - time limits and work requirements - apply when federal TANF "assistance" is provided. Therefore, decisions about providing services are influenced by whether or not the service falls within the definition of "assistance."
The final TANF regulations provide a fairly narrow definition of "assistance," thus broadening the range of services states and localities can offer clients without subjecting them to time limits and work participation requirements. "Assistance" includes cash payments, vouchers, and other non-cash benefits designed to meet a family's on-going, basic needs. There are specific exclusions from this definition including supportive services to employed families, short-term benefits,35 wage subsidies to employers, and other services that do not provide basic income support.
The federal definition of "assistance" allows states attempting to identify barriers latitude in the services they can offer without subjecting clients to time limits and work participation requirements.
This definition offers states undertaking efforts to identify barriers to employment some latitude in providing a range of services. For example, counseling and case management services - services that do not provide basic income support but that are thought to be important for clients with unobserved barriers to employment - are examples of services excluded from the definition of "assistance." Therefore, states have the flexibility to provide these services without subjecting clients to federal time limits or work participation requirements. However, if for example, federal TANF funds are used to provide a cash benefit while a client is in counseling, time limits and work requirements do apply to that family.
35 States may use TANF funds to provide "short-term" benefits or support "short-term" services for an "episode of need" - defined as four months or fewer - without being considered assistance.