Comment on FR Doc # 2026-12514

System of Records Notice (SORN) 09-80-0375 Few of us would be thrilled to learn that our personal information has been forwarded to a third party who shares it around for uses outside and beyond the reasons it was collected. Such practices quickly destroy trust along that chain of possession. The All Families Deserve a Chance (AFDC) Coalition was established as an all-volunteer coalition in 1971. We promote public policies that help Coloradans who live in poverty. The extensive new federal data demands in this SORN require deeply personal information such as Social Security number, type and amount of assistance received, income, race, case numbers, citizenship/immigration status, hours of work, and “verification information, like name and address. This data demand expands beyond just those receiving TANF, to include other people in the household who are not receiving assistance, and even members of families who are no longer receiving assistance. This SORN seems to have a focus reflected in the Health and Human Services- Office of Family Assistance ‘s report The Prevalence of TANF Child-Only Cases Involving Immigration Status Ineligible Parents which postulates that a large percentage of such cases would be children of parents without work-authorization. Commonly, a child-only case reflects situations where a parent cannot support their child due to physical or mental ill health, substance abuse, incarceration, or other challenges, and a relative or other adult has stepped in in lieu of foster care. These other adults are not part of the grant. According to the Office of Family Assistance Report- they estimate that Colorado has 461 of such child-only cases with parent ineligible because of immigration status cases, with an unknown percentage of the 461 fitting a scenario of the parents of the child on TANF are undocumented. In Colorado, a child-only case receives a monthly grant (which can vary by county) between $200-299 per month. So, OFA estimates the annual cost of subsistence payments to 461 child-only cases who might, or might not, have an undocumented parent (who is ineligible for TANF themselves-hence identified as “child-only cases”), is approximately $1,700,000 annually. There does seem to be a strong connection between this SORN and HHS immediately freezing ALL TANF, Child Care and Community Services Block Grant Funding for five states on January 6, 2026. For Colorado alone this was over $275 million. Colorado did not hand over to ACF the massive, extremely detailed and personal TANF data to ACF with their deadline of January 20, 2026. ACF also froze the funds for California, Minnesota, Illinois and New York. All five states’ Attorneys General sued on January 9, 2026. In February, New York District Court issued a stay, and on June 19th the District Judge from Northern California posted her legal decision , which begins: “A generous reading of the record provided to this Court falls far short of the type of proof which might substantiate the government’s sweeping claims of fraud. The uninspiring evidentiary showing only adds insult to the injuries that families and children in New York, California, Minnesota, Illinois, and Colorado face as a result of the government’s attempted funding freeze. This Court, like its sister court in the Southern District of New York, takes seriously its obligation to hold accountable executive officials who exceed their authority. The rule of law requires such accountability.” The following Tuesday June 23, the proposed SORN was posted in the federal register. It appears to be a different path to the same end. It is one thing for auditors to review a sample of records, or when conducting investigations of suspected fraud based on reliable evidence. We need human service workers to have time to work with struggling families on finding employment and address family problems and challenges. We oppose this intrusive and time-consuming data overreach. Chaer Robert Legislative Chair All Families Deserve a Chance (AFDC) Coalition 7/19/2026 See attached file for January 6, 2026 letter from Agency for Children and Families to Governor Polis with original data ask referenced in my comment.