Comment on FR Doc # 2026-12514

Thank you for the opportunity to comment. I support strong program integrity in TANF and understand the importance of accurate verification, responsible data use, and public accountability. At the same time, I am concerned that the proposed system of records notice could unintentionally create additional barriers for eligible children in child-only TANF cases, particularly children being raised by kinship caregivers. These caregivers are often grandparents, relatives, or close family friends who have stepped in to keep children safely with family and out of foster care. The notice appears to expand ACF’s use of data matching, verification, audits, and information sharing for program-integrity purposes. However, it is unclear whether states will be expected to collect additional information or change their application and verification processes. Without clear guidance, states may interpret the notice differently, which could lead to inconsistent documentation requests, delays, or confusion for eligible child-only TANF cases. In Nevada, caregiver income is already considered. Even so, expanded verification could create additional paperwork or delays for caregivers who are already navigating complex systems while caring for children. Employment, work-hour, Social Security, citizenship, or immigration-related information should not be requested from nonrecipient caregivers unless it is directly relevant under the state’s eligibility rules. Data matching can support accuracy, but it can also produce incorrect, incomplete, or outdated results. Families should not experience automatic denials, closures, or delays based solely on a data mismatch. They should receive notice, human review, and a meaningful opportunity to correct inaccurate information before any adverse action is taken. Additional scrutiny or unclear documentation requests may also discourage some caregivers from applying or completing the process, even when the child may be eligible. This is especially important in child-only TANF cases, where the purpose of the benefit is to support the child and help maintain stability in the home. I respectfully recommend that ACF clearly state that this notice does not create new eligibility or documentation requirements for child-only TANF cases; clarify exactly what information states must collect and how it may be used; limit verification of nonrecipient caregivers to legally relevant information; distinguish data used for federal reporting or program integrity from information used to approve or deny benefits; prohibit automatic denials or closures based only on data mismatches; and issue specific guidance and training for child-only TANF and kinship caregiver cases before expanding program-integrity reviews. These recommendations support both accountability and access. Program integrity is important, but it should not unintentionally prevent eligible children from receiving support intended to help them remain safely with family.