States have the option to provide monthly cash payments to families through a Separate State Program (SSP) which is funded only with state dollars that can be counted towards a state’s maintenance of effort (MOE) requirement. (Separate State Programs are not the same as Solely State Funded programs that are funded with state funds that do not count towards a state’s MOE requirement.) There are both advantages and disadvantages to providing monthly cash benefits through an SSP which we highlight below.  

Background: States can provide cash assistance to families in several ways — they can provide them with federal TANF-funded assistance, assistance that is partially funded with TANF or MOE funds, assistance that is MOE-funded but provided within a TANF-funded program, or MOE-funded assistance in a program that receives no federal TANF funds – the latter is what is called an SSP or “Separate State Program.” Historically, HHS has considered everyone receiving assistance (TANF or MOE-funded) part of the cash assistance caseload, but they provide data separately for the TANF and the SSP caseload. That is because SSP technically are not considered part of the TANF caseload and requirements that apply to the TANF caseload do not always apply to SSP cases. This Guide to Use of TANF and MOE Funds | CLASP by CLASP provides a very useful table that shows which TANF provisions do not apply to SSP cases.

States have established SSPs primarily for three reasons: (1) to provide assistance to immigrant families who are subject to the five-year bar; (2) to provide assistance to families who have reached or are close to reaching the five-year time limit and (3) to provide cash payments to SNAP recipients. SSP programs appear to be underutilized, possibly because states prefer to pay for cash payments to families using at least some federal funds.

Key things to know about what TANF requirements do and do not apply to SSP cases:

• SSP recipients are subject to work requirements and are counted in calculation of the state’s work participation rate.
• Immigrant status restrictions (i.e., the five-year bar) does not apply.
• The five-year time limit does not apply.
• The teen parent residency and school requirements do not apply.
• The felony ban does not apply.
• Recipients are not required to meet child support cooperation or assignment requirements.
• States are not required to screen SSP recipients using the Income and Eligibility Verification System (IEVS).
• Funds use to provide cash payments count towards a states’ MOE requirement, but they are not counted when determining a state’s eligibility for the Contingency Fund.
• References in the statute or regs to “the State program funded under this part” does not include separate state programs.
• Administrative costs count towards a state’s overall administrative cost limitations.
• Families participating in separate state programs are considered “former” or “never” TANF families (depending on their history of TANF receipt) under the IV-D child support distribution statute. You can find more at this link: at_07_02a.pdf (hhs.gov)