RIN0970-AD38_ReducingBureaucracyandBurdenforFamilyAssistancePrograms

Western Center on Law and Poverty, a legal services support center, expresses mixed feelings regarding the proposed repeal of certain TANF regulations. While they generally find the repeal unobjectionable, they oppose the removal of specific requirements regarding due process for hearings, single state agency oversight, and merit system personnel standards.

FGA Action supports the proposed rule to remove obsolete, duplicative, and unnecessary regulations from the family assistance regulatory framework. They argue that streamlining the Code of Federal Regulations will reduce administrative burdens and allow program administrators to focus on current statutory requirements and service delivery.

Chairman Serrell Smokey of the Washoe Tribe of Nevada and California expresses concerns that the proposed rule may diminish tribal sovereignty by applying uniform standards to tribes that differ from state and local programs. While the tribe supports reducing bureaucratic barriers, they advocate for more meaningful consultation and flexibility to address the diverse needs of tribal nations.

The Legal Aid Foundation of Los Angeles (LAFLA) provides feedback on the proposed repeal of several regulations, noting that while some may be obsolete, others provide important procedural and administrative frameworks. They specifically request clarification on which authorities will govern state plan administration, fiscal oversight, and—most importantly—hearing and administrative review procedures if the proposed repeals occur.

The Maryland Department of Human Services opposes the removal of specific regulations regarding the Family Violence Option, Work Participation Rates, and the Contingency Fund, arguing that these provisions provide essential interpretive certainty and operational clarity. They contend that removing them would create ambiguity, potentially jeopardize access to federal funding, and substitute stable regulations with less durable sub-regulatory guidance.