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.
Comment on NRPM Foster Care Legal Representation (11/27/2023)
This comment letter was created after a thorough review of a proposed regulation update that would expand legal representation services offered under title IV-E. It includes an overview of the achievements of the and the challenges agencies face in the implementation and execution of IV-E legal representation requirements.
Comment on IV-E Clearinghouse Handbook of Standard Operating Procedures (11/24/2023)
This comment letter acknowledges that the aims of the Clearinghouse standards, which include an emphasis on inclusivity, diverse populations, and culturally adapted programs, is crucial to understanding of the challenges faced by families, while also providing recommendations that will enhance its ability to reach these and other stated goals.
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 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 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.
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.
Comment on Kinship Licensing Rulemaking (4/17/2023)
This response to the Notice of Proposed Rule Making on Separate Licensing Standards for Relative or Kinship Foster Family Homes was gathered from state and local human services executive leadership and by the leaders charged with administering child welfare and economic support services. In addition to voicing our strong support for finalizing the proposed rule, we outline several considerations that best support state child welfare agencies’ efforts to adopt new kinship licensing standards and identify existing and potential new structural issues related to kinship families.