FCASPL 289 (TANF Independent Living Allocation and Spending)
Family, Children and Adult Services Procedure Letter No. 289
November 30, 2015
TO: Family, Children and Adult Services Manual Holders
FROM: Cynthia C. Dungey, Director
SUBJECT: TANF Independent Living Allocation and Spending

The Ohio Department of Job and Family Services (ODJFS) distributes the TANF Independent Living Allocation to Public Children Services Agencies (PCSA) to enable youth who have or who will emancipate from foster care to have the skills and support necessary to help them achieve self-sufficiency and lead productive lives.

The activities funded under the allocations are to support the provision of independent living (IL) services and assistance to youth ages 14 and older who are in the agency's custody and young adults ages 18 to 21 who have emancipated from the agency's care in accordance with Ohio Administrative Code (OAC) rules 5101:2-42-19 Requirements for the Provision of Independent Living Services to Youth in Custody and 5101:2-42-19.2. Requirements for Provision of Independent Living Services to Young Adults Who Have Emancipated. In accordance with OAC rule 5101:9-6-08.6 Temporary Assistance to Needy Families (TANF) Independent Living (IL) Allocation, PCSAs may also use the funds to support the provision of independent living services to youth in their custody under the age of 14 when the youth is likely to remain in agency care until the youth's eighteenth birthday.

In addition to supporting activities directly related to IL services, ODJFS has identified the following activities that are also allowable services under this allocation:

Allowable Expenditures for Youth in the PCSA's Custody

  • For youth in a PCSA's custody, the agency may purchase services, make contractor payments, and make incentive payments consistent with the youth's life skills assessment and written independent living plan developed in accordance with rule 5101:2-42-19. With the exception of medical services, PCSA's may use the funding to purchase services using the service categories outlined in rule 5101:2-42-19.
  • A PCSA may also offer incentives to eligible youth to promote successful behavioral outcomes. Such outcomes may include: academic achievement such as honor roll or election to student council; acts or recognition of good citizenship in the community; or the achievement of milestones that further the youth's accomplishment of goals/expectations outlines in the youth's independent living plan. Incentives may be provided to youth in the form of a cash payment. The value of incentive should not be disproportionately large.
  • Payments to contractors for room and board are not allowable for youth in the PCSA's custody unless they are eighteen or older and voluntarily remain in foster care. In addition, services and payments may not fall within the definition of "assistance" under TANF nor otherwise prohibited by TANF regulations.

Allowable Expenditures for Young Adults Who Have Emancipated from Agency Care

  • Allocation funding may be used to purchase services, make contractor payments, and provide incentive awards for young adults who have emancipated from foster care. Such persons must enter into a written plan developed in accordance with rule 5101:2-42-19.2. Purchased services, contractor payments, or incentive awards must be consistent with the aforementioned plan. In developing the plan, the PCSA must place a special emphasis on defining goals and outcomes which assist the young adult in achieving and maintaining self-sufficiency.
  • Except for medical services, PCSAs may purchase services using the service categories outlined in rule 5101:2-42-19.2. PCSAs may also purchase other services, make payments to contractors, or provide incentives to the young adult to assist in furthering the young adult's achievement of self-sufficiency as outlined in the written plan. Services and payments may not fall within the TANF definition of "assistance" or be designed to continuously meet a youth's ongoing basic needs.
  • Some allowable expenditures which a PCSA may consider on a case-by-case basis for a young adult who has emancipated or a young adult who is eighteen and older and voluntarily remain in foster care include:
  • Security deposits, utility deposits, and rent and utility payments for up to four months when there is a clear plan that the young adult will be able to maintain ongoing payments beyond those for which he or she has received assistance from the PCSA.
  • Up to $1000 to assist with furniture.
  • Driver's education classes and driver's license fees.
  • A one-time payment to a contractor to purchase or help to purchase a used car to support the young adult's employment when there is a clear plan that the young adult will be able to maintain the costs and responsibilities associated with a car.
  • A one-time payment to a contractor up to $2000 to cover the cost of repairs to a car that is used to support the young adult's employment, provided that such repairs are necessary to the functioning of the car and are not considered ongoing car maintenance (e.g. an oil change).
  • Work clothes, tools, supplies, examinations/testing, and/or permit fees needed to obtain or maintain employment.
  • Payment of a membership to join a YMCA or other activity which would help a young adult to maintain a responsible lifestyle. The membership should be limited in time.
  • Employment mentoring.
  • Nominal incentive awards in the form of cash payment for the achievement of specific behavioral outcomes outlined in the written plan between the youth and the PCSA.

Case-by-Case Considerations for Emancipated Youth

These funds are intended to allow PCSAs flexibility in designing a service plan which meets the individual needs of each youth on a case-by-case basis while also weighing the young adult's level of maturity, ability to accept responsibility and the various options that are available to that young adult in the county.

For example, one county may have an excellent public transportation system where another county has minimal public transit services available. One young adult may have demonstrated responsibility through having been employed while under agency custody and responsibility driving the car of his foster family while in their care. Perhaps he or she would only need some assistance from the PCSA to make a one-time purchase or repair a car to be used in employment or to assist with initial housing costs. When considering the purchase of a car that can support the young adult's employment, the PCSA should take due care to consider that young adult's ability to pay for car insurance, fuel, and ongoing maintenance costs. Agencies are encouraged to dialogue with their legal counsel to discuss any additional parameters the county wishes to be factored into the written plan developed with the emancipated youth in regard to the services and supports the PCSA will provide.

General Prohibition Relevant to the TANF IL Allocation

  • Funds may not be used for the purchase of child care.
  • Funds may not be used to provide transportation for unemployed youth or young adults.
  • Funds may not be used for the following activities:

1)To support staff salaries or to pay contractors for room and board for youth in the PCSA's custody;

2)Services and payments that are assistance as defined in 45 C.F.R 260.31 (a);

3)Medical services;

4)Juvenile Justice services;

5)Title IV-D child support;

6)Title IV-E services;

7)Foster care maintenance

8)Construction or purchases of buildings or facilities;

9)Purchase of real property;

10)Public education; or

11)To provide cost sharing or matching requirements of another federal program.

  • The TANF IL funds are made available to enhance current funding. Funds available through the Chafee IL program, the education and training voucher (ETV) program, the Workforce Investment Act (WIA), the Workforce Innovation and Opportunity Act (WIOA), and other community resources must be utilized first for services allowable under these programs.

Availability and Claiming

All PCSAs received a SFY15 notice from the Bureau of County Finance and Technical Assistance that provides the allocation amount for each county and applicable time periods. Please refer to the Fiscal Administrative Procedure Manual rule 5101:9-6-08.6 Temporary Assistance to Needy Families (TANF) Independent Living (IL) Allocation for instructions on claiming allowable costs against the allocation.

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FCASPL No. 289