Federal Policy Responses

Letter of Support for the Tax Relief for American Families and Workers Act of 2024

APHSA, along with NACo. NACHSA, ICMA, NLC, and USCM, signed a letter of support for the Tax Relief for American Families and Workers Act of 2024 to expand the Child Tax Credit (CTC). While the changes to the CTC proposed in the Tax Relief for American Families and Workers Act of 2024 do not go as far as the expansion under the American Rescue Plan Act of 2021 (ARPA), they would still make meaningful improvements through 2025.

Comments in Response to OFA's Request For Information related to Sections 302 and 304 of the Fiscal Responsibility Act of 2023 (1/11/2024)

On June 3, 2023, the Fiscal Responsibility Act of 2023 was signed into law; four provisions impacted the federal TANF program. Sections 302 and 304 of the Act mandate a six-year pilot program as well as four outcome measures states must track for one year after individuals exit the TANF program. Both sections become effective on October 1, 2024. OFA published a Request For Information (RFI) in November 2023 soliciting public input on select topics related to these sections. Read NASTA's response to this RFI here.

Comment on the OMB Proposed Memorandum: Advancing Governance, Innovation, and Risk Management for Agency Use of Artificial Intelligence (12/5/2023)

The input reflected in this comment letter is deeply informed by the insight and input of member groups who are leading experts in data analysis, health and human services IT systems, workforce development and training, and legal dimensions of the sector.

APHSA Comment Letter on 2023 TANF NPRM (12/1/2023)

This comment shares APHSA member feedback regarding the cross-cutting proposed rules to the TANF program. APHSA's Leadership Council and its NASTA affinity group were incremental in raising these considerations and establishing these recommendations.

APHSA Response to NPRM on Improving SNAP Quality Control System (11/20/2023)

This comment shares APHSA feedback on the proposed changes to significantly alter the SNAP QC review process. The comment is informed by feedback from two APHSA affinity groups, AASD and NAPIPM.

APHSA comment in response to the Notice of Proposed Rulemaking (NPRM) Discrimination on the Basis of Disability in Health and Human Service Programs (11/13/2023)

The feedback detailed in this comment provides responses to the child welfare provisions of the NPRM. It was gathered from child welfare leaders responsible for the oversight of child welfare systems who play a key role in the successful implementation of the proposed changes in the rule.

Comments Regarding Title IV-B of the Social Security Act (10/12/2023)

Read our comment on the recent hearing on "Modernizing Child Welfare to Protect Vulnerable Children" held on September 28, 2023. This hearing highlighted the urgent need for Congress to address the reauthorization of Title IV-B, which allocates funds that play a pivotal role in providing vital and diverse supports to children and families.

APHSA Response to NPRM on Improving Child Care Access, Affordability, and Stability in the Child Care and Development Fund (08/28/23)

This APHSA letter offers a response to the Notice of Proposed Rulemaking (NPRM) Improving Child Care Access, Affordability, and Stability in the Child Care and Development Fund (CCDF) RIN number 0970–AD02.

APHSA Comment Letter on SNAP Quality Control 310 Handbook (07/13/23)

The current process and specific policy within the SNAP Quality Control 310 Handbook—which governs how states conduct Quality Control reviews—creates barriers for states when working to effectively meet the needs of households facing food and nutrition insecurity across the country. This letter provides recommendations to USDA FNS in addressing these barriers.

APHSA Comment Letter on Work and Welfare Subcommittee Hearing (07/12/23)

This APHSA letter offers comment on the Work and Welfare Subcommittee Hearing related to the spending of non-assistance TANF funds that took place July 12, 2023.

APHSA Special Statement: Release of FY 2022 SNAP Payment Error Rate (06/30/23)

On June 30, 2023, USDA released the FY 2022 payment error rate (PER) for SNAP, the first national error rate calculated since the start of the COVID-19 pandemic. This payment error rate captures a time when the ability of SNAP to agilely adapt to meet the health and well-being of families and support the economic resiliency of our nation was pivotal—and state and local agencies overwhelmingly stepped up to the challenge. Learn more in APHSA’s Special Statement.

Joint Letter on Implementation of SNAP Provisions in the Fiscal Responsibility Act of 2023 (06/29/23)

Written in partnership with GFOA, ICMA, NACo, NACHSA, NAWB, NGA, and NLC, this letter expresses the critical need for expedited guidance on implementation of SNAP provisions in the Fiscal Responsibility Act (FRA) of 2023.

APHSA issues letter in SNAP Customer Service Strategies Study (06/26/23)

This letter was written as a response to the proposed study on SNAP by the USDA Food and Nutrition Service (FNS), as they work to understand states' SNAP customer service strategies. Specifically directed to the Office of Policy Support, it provides APHSA’s recommended priorities for case studies as well as general methodology suggestions.

APHSA Summary of Debt Ceiling Human Services Provisions (updated 06/06/23)

On June 3, 2023, the Fiscal Responsibility Act of 2023 was signed into law, a legislative package previously agreed upon by the White House and House Speaker to suspend the national debt ceiling limit through January 1, 2025 in exchange for a package of spending cuts and policy changes, including changes to work requirements in SNAP and TANF. APHSA has summarized the relevant human services provisions and noted dates they will take effect.

APHSA Comment Letter on Improving Coordination Between SNAP and Medicaid in State Agencies (06/05/23)

In partnership with the National Association of Medicaid Directors (NAMD), APHSA provided comments in support of the proposed research to improve the coordination between SNAP and Medicaid in state agencies.

APHSA Issues Letter Raising Concerns with TANF Provisions in Debt Ceiling Bill (05/18/23)

This letter to Congress elevates deep concerns that, as a whole, the TANF provisions in the Limit, Save, Grow Act of 2023 will work counter to the goal of helping families experiencing poverty succeed in entering careers that lead to family-sustaining wages.

APHSA Comment Letter on House Ways and Means Work and Welfare Subcommittee Hearing on Work Requirements (04/12/23)

This APHSA comment letter is in response to the Work and Welfare Subcommittee hearing on work requirements that took place March 29, 2023.

Recommendations to Strengthen the Impact of SNAP-Ed on Food and Nutrition Security: Perspectives from State SNAP-Ed Agency Leaders (01/23)

This APHSA report shares policy recommendations for the USDA Food and Nutrition Service (FNS) and Congress to support state Supplemental Nutrition Assistance Program Education (SNAP-Ed) teams in building more equitable and effective SNAP-Ed programs.

APHSA Summary of FY 2023 Appropriations and Policy Omnibus Package 12/21/22

Congress released text for a FY 2023 spending package with bipartisan and bicameral support. The bill includes annual funding for key human services provisions in addition to other major policy changes. APHSA has developed a summary of key human services policy and appropriations provisions, which should be viewed as highlights of the most critical updates for state and local human services agencies.

APHSA Comment Letter to FNS on the Interim Final Rule for the National Accuracy Clearinghouse 12/02/22

APHSA Comment Letter re the Supplemental Nutrition Assistance Program (SNAP) Requirement for Interstate Data Matching To Prevent Duplicate Issuances, 87 FR 59633

APHSA Comment Letter to Centers for Medicare & Medicaid Services (CMS) 11/07/22

APHSA Comment Letter in response to the CMS Eligibility Rule, focusing on the impacts to SNAP agencies and emphasizing program alignment to reduce burden and confusion for clients and staff.

APHSA Comment Letter to FNS for 2022-2023 P-EBT Administration 10/14/22

APHSA Comment Letter to the USDA Food and Nutrition Service (FNS) highlighting the administrative challenges states are facing to implement federal guidance for the Pandemic Electronic Benefits Transfer (P-EBT) program for school year 2022-2023.

APHSA Comment Letter on Engagement and Accountability RFI 10/03/22

APHSA Comment Letter in response to the White House Office of Science and Technology Policy (OSTP) Request for Information, offering insights on how Federal agencies can better support collaboration with other levels of government, civil society, and the research community around the production and use of equitable data.

APHSA Summary on DHS Final Rule for Public Charge Ground of Inadmissibility 09/09/22

The U.S. Department of Homeland Security (DHS) publicized the final rule on the Public Charge Ground of Inadmissibility, which will take effect on December 23, 2022. This rule provides clarity and consistency in how a noncitizen is deemed likely to become a public charge. Under this rule, receipt of the Supplemental Nutrition Assistance Program (SNAP) and other nutrition supports or non-cash benefits will not be considered as grounds of inadmissibility.

APHSA Joint Letter to Congress on TANF Extension 09/09/22

APHSA submitted a joint letter this week on behalf of our coalition of membership associations urging Congress to provide a one-year extension to the Temporary Assistance for Needy Families (TANF) program, while we continue to work towards a bipartisan solution for a long-term reauthorization.

APHSA Comment Letter in response to NPRM on Student Loan Programs 08/12/22

APHSA Comment Letter in response to the Notice of Purposed Rulemaking (NPRM) regarding the Student Assistance General Provisions, Federal Perkins Loan Program, Federal Family Education Loan Program, and William D. Ford Federal Direct Loan Program (Document Citation: 87 FR 41878 Docket ID ED-2021-OPE-0077).

APHSA Comment Letter: SNAP Revision of Civil Right Data Collection Methods 08/26/22

APHSA letter in response to FNS’s notice of proposed rulemaking on Supplemental Nutrition Assistance Program: Revision of Civil Right Data Collection Methods, which would remove visual assignment as a way to collect race and ethnicity data of SNAP applicants.

Supplemental Nutrition Assistance Program Education and Obesity Prevention Grant (SNAP-Ed) National Program Evaluation and Reporting System (N-PEARS) 08/09/22

APHSA letter to the USDA Food and Nutrition Service (FNS) on the importance of working directly with states and implementing agencies to understand their needs for flexibility and capacity support in the development of the N-PEARS system.

APHSA Recommendations for the White House Conference on Hunger, Nutrition, and Health 07/22

APHSA recommendations to the White House on developing and implementing initiatives that work to reduce hunger and increase health, including policy levers that should be pulled through a racial equity lens in developing the conference content and related policy agenda.

APHSA Calls on Congress to Provide Immediate, Guaranteed Long-Term Investments in our Nation’s Child Care System 06/02/22

APHSA Call to Action urging Congress to provide immediate, guaranteed long-term investments in our nation’s child care system. The principles reflected represent a bold, comprehensive, and practical approach that ensures all states have the tools required to transform and strengthen their early childhood systems.

FNS Consideration of Winnings Threshold in Lottery and Gambling Rule 05/03/22

APHSA Comment letter regarding design and implementation of the Lottery and Gambling Winners Final Rule urging USDA to consider changes within its purview.

APHSA Comment Letter: Notice of Proposed Rulemaking – Public Charge Grounds of Inadmissibility 04/25/22

This APHSA comment letter to the Department of Homeland Security is in response to a proposed rulemaking on public charge, which re-examines how public charge is defined.

APHSA Joint Comment Letter with NAMD on SNAP PHE Flexibilities 03/14/22

This APHSA Comment Letter to Congress created with the National Association of Medicaid Directors (NAMD)requests that Congress provide Medicaid and SNAP programs with extended flexibilities, sufficient planning time, and adequate resources to smoothly transition out of the public health emergency.

APHSA Summary of DHS Proposal for New Rule on Public Charge 03/03/22

On February 24, 2022 the Department of Homeland Security (DHS) published a Notice of Proposed Rulemaking (NPRM) Public Charge Ground of Inadmissibility to reconsider public charge grounds of inadmissibility determinations. The proposed rule stands in contrast to the August 2019 Final Rule, and would not consider non-cash benefits such as the Supplemental Nutrition Assistance Program (SNAP) and most forms of Medicaid when making public charge determinations.

APHSA Comment Letter on SNAP PHE Flexibilities 03/03/22

This APHSA Comment Letter to Congress requests waiver and staffing flexibilities to assist SNAP agencies in the transition out of the public health emergency.

APHSA Response - FNS RFI Center for WIC Modernization 12/08/21

APHSA Comment letter in response to a Food and Nutrition Services (FNS) Request for Information: Center for WIC Modernization and Delivery, encouraging the prioritization of cross-program and cross-agency alignment in the services provided and resources made available through the Center so that modernizations to the WIC program are in service of families’ needs.

APHSA SOS Response - FNS RFI Center for WIC Modernization 12/08/21

APHSA comment letter in partnership with Share Our Strength & No Kid Hungry, in response to a Food and Nutrition Services (FNS) Request for Information: Center for WIC Modernization and Delivery. Reflecting the work of six sites - Hawai‘i, Kansas, Michigan, New Jersey, New Mexico, and Mecklenburg County, North Carolina - through the Coordinating SNAP and Nutrition Supports (CSNS) project.

APHSA Coalition Letter on SNAP Appropriations 11/17/21

APHSA and a coalition of national organizations representing the state and local governments that administer the Supplemental Nutrition Assistance Program (SNAP) sent a comment letter to the House and Senate Appropriations committee urging them to adopt language in the FY2022 budget to ensure that SNAP is adequately funded for the entire fiscal year, protecting program participants from losing benefits in the event of a government shutdown.

APHSA Response - Title IV-E Standards and Procedures 09/16/21

APHSA letter in response to HHS/ACF’s request for public comment on Title IV-E Prevention Services Clearinghouse Handbook of Standards and Procedures, summarizing changes that would aid child welfare agencies in their efforts to keep children and families safely together and address systemic inequities.

APHSA Response - EBT Modernization 8/9/21

APHSA comment letter to the USDA Food and Nutrition Service (FNS) in response to requests for stakeholder feedback on Electronic Benefit Transfer (EBT) Modernization for the Supplemental Nutrition Assistance Program (SNAP).

APHSA Response - USDA Equity RFI 7/16/21

APHSA comment letter in response to a Request for Information issued by the federal government on "Identifying Barriers in USDA Programs and Services; Advancing Racial Justice and Equity and Support for Underserved Communities at USDA."

APHSA Response – OMB Equity RFI 7/6/21

APHSA comment letter in response to a Request for Information issued by the federal government on "Methods and Leading Practices for Advancing Equity and Support for Underserved Communities."

Comment Letter - Thrifty Food Plan Revisions 6/28/21

In response to the 2018 Farm Bill and President Biden's Executive Order on 1/22/21, the USDA Food and Nutrition Service (FNS) is currently in the process of re-evaluating the Thrifty Food Plan, which is the basis for the calculation of Supplemental Nutrition Assistance (SNAP) benefits. APHSA has provided this commentary for consideration during the re-evaluation process.

Summary of Final Rule Employment and Training Opportunities in the Supplemental Nutrition Assistance Program 1/8/21

On January 4, 2021, the Food and Nutrition Service (FNS) issued a final rule, “Employment and Training Opportunities in the Supplemental Nutrition Assistance Program,” effective March 8, 2021, to implement changes made by section 4005 of The Agriculture Improvement Act of 2018 (Pub. L. 115- 334) to the Supplemental Nutrition Assistance Program Employment and Training (SNAP E&T) program. APHSA has summarized the new rule, which includes a number of provisions impacting SNAP E&T programs.

COVID-19 Response and Relief Supplemental Appropriations Act, 2021 12/30/20

On Monday, December 21st, Congress passed the COVID-19 Response and Relief Supplemental Appropriations Act as part of an appropriations package that funds the federal government through federal fiscal year 2021. The bill was signed into law by the President on December 27th. The over $900 billion COVID-19 relief package covers a wide range of human services and related priorities. APHSA has summarized the relevant provisions that impact human services delivery.

Comment Letter on Regulatory Relief to Support Economic Recovery 12/28/20

APHSA has submitted comments in response to the Request for Information on Regulatory Relief to Support Economic Recovery published on November 25, 2020 by the U.S. Department of Health and Human Services (HHS). The request for information seeks input on the importance of waivers and flexibilities issued by HHS during the public health emergency and their potential need to be continued after the public health emergency. APHSA’s response reflects feedback received from its members responsible for administering human services programs funded through HHS.

TANF Extension Coalition Letter to Congress 11/24/20

APHSA and a coalition of membership organizations representing the nation’s state legislatures, counties, cities, and state and local workforce and health and human services agencies submitted a letter to Congress to provide a one-year extension to the Temporary Assistance for Needy Families (TANF) program, effective through December 31, 2021.

TANF Extension Coalition Letter to Congress 11/24/20

APHSA and a coalition of membership organizations representing the nation’s state legislatures, counties, cities, and state and local workforce and health and human services agencies submitted a letter to Congress to provide a one-year extension to the Temporary Assistance for Needy Families (TANF) program, effective through December 31, 2021.

APHSA Comment Letter Affidavit of Support 11/2/20

Letter to the Department of Homeland Security in Response to Proposed Rulemaking: Affidavit of Support on Behalf of Immigrants, published on October 2, 2020 on the Federal Register by the Department of Homeland Security (DHS).

Final Rule: SNAP Requirements for Able-Bodied Adults Without Dependents (ABAWD) - 10/19/20

A federal judge formally struck down the ABAWD final rule on October 18, 2020. This summary is an update including key points of what the final rule does, including Core Standards for Considering Waiver Requests, Criteria for Establishing Geographic Areas for Consideration for ABAWD Waivers, and Additional Implementation Requirements.

Comment Letter - 10/02/20

Comments to the Federal Interagency Council on Economic Mobility in response to the Request for Information (RFI) on Federal Coordination to Promote Economic Mobility for All Americans. APHSA’s comments reinforce the structure and approach the Council should take to creating structures and areas of investment that can achieve the greatest impact through interagency collaboration.

Letter to Congress - 08/7/20

This letter on SNAP Implementation Considerations outlines priorities and technical considerations for human services agencies in the next COVID relief package. The letter addresses the need to increase the minimum and maximum SNAP benefit levels, to simplify, extend, and expand Pandemic EBT (P-EBT), to provide fiscal relief for both SNAP implementation and P-EBT, and to establish waivers to support SNAP implementation for the duration of the pandemic.

Letter to Congress - 6/24/20

This letter highlights the key policy priorities that child care administrators recognize are needed to ensure the availability of safe and stable care, and to urge Congress to prioritize child care in negotiations for the next stimulus package. The recommendations cover policy issues focused on supporting child care operations, instituting effective health and safety protocols, and supporting the education system and working parents.

Comment Letter – 6/17/20

Comments in response to proposed rule: Employment and Training Opportunities in the Supplemental Nutrition Assistance Program, Docket ID Number [FNS-2019-0008]. APHSA affirmed its commitment to providing pathways to economic mobility for SNAP recipients and acknowledged the progress that has been made in recent years by states with the support of USDA.

Letter to Congress – 6/3/20

Building on our members’ prior recommendations to address rapid response issues caused by the COVID-19 pandemic and to meet urgent community needs and stabilize the underlying human services infrastructure, this letter provides additional recommendations to Congress to adopt specific policies that invest in people and communities to drive an economic resurgence.

Letter to Congress – 4/10/20

Based on feedback from our members across the nation, this letter identifies the most urgent legislative tools needed to support human services agencies during the COVID-19 pandemic and its immediate aftermath including investment in the infrastructure needed to create economic opportunity, keeping children safe and mitigating the trauma families are experiencing, ensuring access to basic nutritional supports, and reinforcing the ability of our child care system to provide quality care to families impacted by the pandemic.

Letter to Congress – 3/25/20

Based on feedback from our members across the nation, this letter provides priority recommendations that are vital to support human services agencies and their partners. APHSA will continue to work with Congress in order to delve into more nuanced issues to support the immediate, interim, and long-term needs of communities responding to and recovering from COVID-19.

Comment Letter – 01/31/20

Comments in Response to Proposed Rulemaking: Rules Regarding the Frequency and Notice of Continuing Disability Reviews.

Summary of Final Rule – 12/11/19

SNAP Requirements for Able-Bodied Adults Without Dependents.

Comment Letter – 11/27/19

Response to USDA's proposed rule for Standard Utility Allowance.

Comment Letter – 09/19/19

As a coalition of member organizations representing the nation’s governors, state legislatures, counties, cities, and state and local health and human services agencies, we urge the House Committee on Ways and Means to provide a one-year extension to the Temporary Assistance for Needy Families (TANF) program.

Comment Letter – 09/12/19

Response to the Notice of Proposed Rulemaking (NPRM) entitled "Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program (SNAP)", Docket ID Number (FNS-2018-0037).

Comment Letter – 06/21/19

Response to the Office of Management and Budget’s (OMB) request for comments on Changes to the Census Bureau’s Official Poverty Measure (OPM), (FR Doc. 2019-09106) published on May 7, 2019.

Comment Letter – 06/11/19

APHSA and our affinity group, the National Association of Public Child Welfare Administrators (NAPCWA), on behalf of the state child welfare administrators, submits comments in response to the notice regarding the Adoption and Foster Care Analysis and Reporting System (AFCARS) by the Children’s Bureau within the Administration for Children and Families (ACF) on April 19, 2019.

Comment Letter – 04/01/19

APHSA and our affinity group, American Association of SNAP Directors (AASD), responds to the USDA Food and Nutrition Service’s (FNS) Request for Comments on Proposed Rule entitled "Supplemental Nutrition Assistance Program: Requirements for Able-Bodied Adults Without Dependents (FNS Docket No. FNS-2018-0004)" posted in the Federal Register on February 1, 2019.

Comment Letter – 01/07/19

Response to the Administration for Children and Families (ACF) request for comment on aspects of a planned Data Exchange Standards Regulation entitled, "Data Exchange Standards for Improved Interoperability of Multiple Human Service Programs" posted in the Federal Register on November 8, 2018.