TANF Time Limit and Increased Sanctions Will Worsen Inequality for DC Families

Despite TANF’s proven role in reducing family hardship and supporting child well-being, DC lawmakers approved major cuts to the program last year that will reduce or freeze cash benefits for more than 16,000 families beginning October 2026.

Testimony delivered on April 30, 2026

Chairperson Frumin and members of the committee, thank you for the opportunity to testify. My name is Maria Manansala, and I am a Policy Fellow at the DC Fiscal Policy Institute (DCFPI). DCFPI shapes racially-just tax, budget, and policy decisions by centering Black and brown communities in our research and analysis, community partnerships, and advocacy efforts to advance an antiracist, equitable future. I also co-chair the TANF is Still a Lifeline Coalition, a group of advocates working to support families with children by fighting to preserve and bolster DC’s Temporary Assistance for Needy Families (TANF) program.

Despite TANF’s proven role in reducing family hardship and supporting child well-being, DC lawmakers approved major cuts to the program last year that will reduce or freeze cash benefits for more than 16,000 families beginning October 2026. These changes include:

  • Eliminating cost-of-living adjustments (COLAs) for TANF benefits;
  • Reinstating time limits for families receiving TANF for 60 months or more; and,
  • Increasing sanctions for not meeting work readiness requirements.

In her fiscal year (FY) 2027 budget proposal, Mayor Bowser doubled down on the cuts, not only maintaining them but also making the time limit policy more punitive. Instead of a partial reduction to benefits that would phase in a 75 percent cut by FY 2029, her proposed budget would eliminate benefits entirely for families who have received TANF for more than 60 months by FY 2028. She also proposed a significant reduction to the TANF Employment and Training Program (TEP) with no stated plan on how to improve employment outcomes.

Both current law and the deeper reductions the mayor proposed threaten to push families with children deeper into poverty, with the greatest harm falling on Black, women-led households who are disproportionately represented in the TANF caseload. These reductions would take effect just as DC enters a local recession, child poverty is rising, and federal and local cuts to health care, food assistance, and other essential supports are beginning to compound.[1]

History shows that terminating assistance for families struggling to meet basic needs can lead to a downward spiral, making it harder for them to regain stability and contributing to long-term negative outcomes for children.[2] To protect the District’s most vulnerable families, the DC Council should reverse the cuts beginning in FY 2027 and reject the deeper reductions Mayor Bowser proposed.

The mayor’s proposal also provides funding to begin implementation of new federal changes to the Supplemental Nutrition Assistance Program (SNAP), including $790,000 in one-time dollars in the FY 2026 supplemental budget and $36 million in related higher administrative costs in FY 2027. DCFPI encourages the Committee to maintain those investments and continue to work closely with advocates to ensure effective implementation of these federal changes, particularly the harsher work requirements. The Committee should also interrogate whether the Department of Human Services (DHS) can absorb the large staffing cuts that the mayor proposes in the budget.

Eliminating TANF’s COLA Will Erode Families’ Purchasing Power, Worsen Poverty

Mayor Bowser’s proposed FY 2027 budget maintains the October 2026 elimination of TANF’s COLA, which DC lawmakers approved last summer. A COLA is an increase in benefits designed to protect purchasing power against inflation, and it is a standard feature of many public assistance programs, including SNAP and Supplemental Security Income (SSI). Current law automatically adjusts TANF benefits with a COLA tied to the Consumer Price Index for All Urban Consumers (CPI-U), allowing benefits to better keep pace with rising prices.

For its first two decades, DC’s TANF program operated without a COLA, meaning that families in the program effectively faced benefit cuts over time. During that period, DC lawmakers kept benefits frozen at levels insufficient to meet families’ basic needs. A family of three received up to $379 per month from FY 1997 to FY 2007 and $428 per month from FY 2008 to FY 2014 in nominal dollars.[3],[4] Inflation steadily eroded the value of benefits, diminishing families’ purchasing power by 23 percent (or $130) between FY 1997 and FY 2014.[5]

Lawmakers reversed this downward trend by introducing a COLA in FY 2015 and phasing in three years of substantial benefit increases from FY 2017 to FY 2019.[6] Together, these changes restored lost purchasing power and halted further erosion, allowing TANF benefits to gradually regain real value. As a result, benefits are now roughly equivalent to their 1997 level when measured as a share of the federal poverty level (37 percent in 2025 compared to 36 percent in 1997).[7]

Lawmakers’ decision to eliminate TANF’s COLA will wipe out years of progress, leaving maximum benefits frozen at $803 for a family of three instead of keeping pace with inflation. Nominally, a family of three receiving maximum benefits stands to lose $255 in FY 2027, with losses compounding each year to reach $724 by FY 2029 (Table 1).[8] Over the course of the financial plan, that adds up to $2,429 less in total TANF benefits. To put that figure in perspective, $2,429 is equivalent to nearly a month of housing or two months of food for a family of three[9]. For families in poverty, that support can mean the difference between crisis and stability.

TABLE 1.

A table showing the maximum annual loss in TANF benefits for a family of three if the COLA is not reinstated, FY 2027-FY 2030. Without a COLA, families will lose $2,439 in cash assistance.

Compounding families’ total benefit cuts in nominal dollars is the decline in purchasing power. Without a COLA, families receiving TANF would not only get lower total benefits, but those benefits would also buy less over time as prices rise. By FY 2030, the same $803 that families currently receive will be worth 9 percent less (or $80), meaning their benefits will cover even fewer essentials such as food, rent, and transportation.[10]

These projected losses are particularly concerning in DC, where the cost of basic necessities ranks among the highest in the country and is expected to keep rising.[11] While inflation affects everyone, it disproportionately harms households with low incomes—including those receiving TANF—because they have less flexibility to adjust their household purchases as prices rise. Research shows households with low incomes devote a far larger share of their income to essentials (77 percent) compared with higher-income households (31 percent); this leaves them with little room to cut discretionary costs.[12]

Against this backdrop, DC lawmakers’ decision to cut TANF’s COLA—which is designed to protect households least able to absorb rising costs—is particularly unjust, given that they continue to fund automatic and inflationary adjustments that primarily benefit middle- and higher-income residents, including increases to estate tax exemption thresholds and expanded recordation tax reductions for first-time homebuyers.[13]

Sanctions Fail to Improve Employment Outcomes Because They Do Not Address Structural Barriers to Work

Mayor Bowser’s proposed budget also maintains a policy that will significantly increase the penalty TANF enrollees face if they cannot meet work participation requirements, raising the reduction in their monthly benefit from 6 percent to 25 percent beginning in October 2026.

Evidence from other states overwhelmingly shows that work sanctions fail to improve employment outcomes for TANF enrollees. For example, research from Kansas found that employment rates among parents who left TANF due to sanctions were virtually unchanged in the year before exit (67 percent) and the year after exit (68 percent).[14] In the fourth year after exit, nearly 40 percent had no earnings at all, another 30 percent had earnings below the deep-poverty level, and overall median annual earnings were just $2,175 in 2016 dollars, or about 11 percent of the federal poverty level.[15]

Beyond failing to improve employment outcomes, sanctions actively harm families, particularly children. A Michigan study found that families subject to sanctions were far more likely than non-sanctioned families to experience utility shutoffs and to resort to extreme survival strategies—such as pawning belongings, searching trash cans, or begging.[16] Meanwhile, a six-city study of TANF enrollees seeking emergency room treatment found that children in sanctioned families were 30 percent more likely to have been previously hospitalized, 50 percent more likely to be food insecure, and 90 percent more likely to be admitted to the hospital at the time of the emergency visit compared with children in non-sanctioned families.[17]

Ultimately, sanctions are both ineffective and harmful because they stem from a fundamentally flawed—and historically racialized—assumption that TANF enrollees need a “stick” to compel them to work.[18] Hence, punitive policies do nothing to address the structural barriers TANF enrollees face to securing and maintaining long-term employment, including inaccessible child care, physical and mental health challenges, and a limited supply of jobs that offer adequate wages. By ignoring these realities, sanctions fail to tackle the root causes of unemployment and instead punish families for conditions beyond their control.

TANF Enrollees Want to Work, but Structural Barriers and Labor Market Challenges Limit Their Opportunities

Contrary to prevailing stereotypes, many TANF enrollees want to work, and most in DC have substantial work experience—about 55 percent have worked for at least four years.[19] Despite this, TANF enrollees face persistent barriers to sustainable employment, like others in the low-wage labor force. In December, DCFPI held focus groups with 16 mothers receiving TANF in DC, who described these challenges in detail. A brief overview of the main barriers that emerged is outlined below—none of which the mayor addressed in the rationale for her budget proposal. These findings challenge the assumption that TANF enrollees can easily transition into work once DHS applies punitive sanctions.

Child care: Child care emerged as the most frequently cited barrier to employment.[20] Given their low incomes, all participants were likely eligible for child care subsidies. However, several mothers reported that they did not have a voucher, highlighting gaps in DHS’s ability to connect families with resources they’re entitled to receive. Among those who did have vouchers, many reported being unable to use them due to a lack of non-traditional child care options, such as care during evenings, nights, or weekends. DCFPI expects this challenge to worsen as the Office of the State Superintendent of Education begins implementing an enrollment freeze and waitlist for the DC Child Care Subsidy Program in May 2026.

Physical and mental health challenges: Multiple participants reported living with, or caring for someone with, physical or mental health conditions, including depression, anxiety, post-traumatic stress disorder, epilepsy, and autism.[21] Many of these participants likely qualify for the Program on Work, Employment, and Responsibility (POWER), which exempts TANF participants with disabilities from work participation requirements and pauses their TANF time limit. However, POWER suffers from severe under-enrollment because families cannot apply directly; a DHS caseworker must refer them.[22] As a result, only 143 families were enrolled in POWER as of December 2025.[23]

Limited job opportunities: Several participants reported spending significant time searching and applying for jobs but receiving no offers.[24] In part, their difficulty stemmed from the District’s weak labor market; when DCFPI held the focus groups last December, DC’s overall unemployment rate reached 6.7 percent, a four-year high and 2.3 percentage points above the national average.[25],[26] Even when participants were able to find work, the jobs available to them often provided wages too low to meet basic needs. When they also considered the “benefits cliff”—the steep decline in public benefits as earnings rise, mostly due to strict federal requirements—they reported that the financial incentive to accept low-wage work diminished further. Participants described wanting to work but being reluctant to lose their benefits for work that would not fully support them or could even leave them worse off.

The Mayor’s Budget Cuts Employment Supports for TANF Enrollees While Maintaining Work Sanctions

Although TANF enrollees face significant barriers to employment, DHS offers resources aimed at helping TANF participants secure jobs. The primary employment service DHS offers to TANF families is the TANF TEP, which provides parents with coaching toward education and employment goals.

Although TEP has the potential to be a helpful resource for families receiving TANF, the program has produced consistently poor outcomes in terms of connecting participants to work. In FY 2025, TEP had an average of just ten job placements for every 1,000 work-eligible TANF recipients—well below DHS’s alarmingly low target of 18 placements.[27] This represents virtually no improvement from FY 2024, when the placement rate was just 11 per 1,000 participants.[28] Due to its weak performance, the mayor proposed cutting TEP funding by $11 million in the FY 2027 budget (leaving $20 million available) but failed to mention her vision or strategy for revamping the program to improve outcomes.[29] While the full impact of these reductions remains unclear, it’s our understanding that TEP will remain the primary pathway through which TANF enrollees meet work participation requirements, based on information shared by DHS leadership.[30]

Although sustaining current levels of investment in an underperforming program may not be warranted (especially without a plan to reinvest those dollars into meaningful TEP improvements), it is fundamentally unfair to impose stricter work sanctions on TANF enrollees while simultaneously making it harder for them to meet work participation requirements. In addition to the DC Council reversing the sanctions policy, DHS must better evaluate and address the drivers of TEP’s poor performance and, in the interim, connect TANF enrollees to more effective workforce development programs, as DCFPI argued in its new TANF report.[31]

Time Limits Risk Cutting Assistance While Families Are Still in Need

Lastly, the mayor’s budget not only maintains the reintroduction of the 60-month time limit for TANF benefits but also proposes making it more punitive. In the FY 2027 budget proposal, Mayor Bowser eliminates TANF benefits entirely for families who have received assistance for more than 60 months, beginning in FY 2028. This marks a shift from current law, under which benefits were set to phase down gradually—reduced by 30 percent in FY 2027, 50 percent in FY 2028, and 75 percent in FY 2029—rather than being fully eliminated. If her proposal is adopted, TANF enrollees will face not only deeper benefit cuts, but the complete elimination of this key income support, leaving many families without the resources they need to stay afloat (Table 2).

TABLE 2.

Source: DCFPI analysis of projected TANF benefit levels.[32]

 

Imposing a time limit on TANF benefits—though standard across the country—is a flawed policy because it unrealistically assumes that families can achieve lasting financial stability within a fixed period of just five years. In reality, the barriers that keep families in poverty are rarely short-term. Physical and mental health challenges, lack of affordable child care, housing instability, and broader economic downturns (such as the Great Recession and COVID-19 pandemic) are not one-time obstacles that neatly resolve within a predetermined timeline; they are persistent and often recurring challenges that require sustained support to overcome. Thus, time limits can sever support not when families have fully stabilized, but simply when they have reached an arbitrary cutoff date.

Even in rare cases where a family does manage to achieve stability within that short window, time limits rest on the misguided assumption that hardship will never return. This ignores the volatility of low-wage work and the reality that financial stability can quickly unravel due to events like sudden job loss, reduced hours, illness, pregnancy, or a family emergency. In practice, some families do not receive TANF continuously for five years but instead, cycle on and off the program as circumstances change. A cumulative time limit does not account for these fluctuations and can therefore leave families without support precisely when they experience renewed need.[33]

As one of the few jurisdictions without a TANF time limit, DC can look to evidence from other states to understand the likely consequences of adopting such a policy. The same Kansas study discussed above finds that TANF enrollees who exited the program because they reached the time limit fared worse than both all leavers and those who exited due to work sanctions. Four years after exit, more than 60 percent had either no earnings or earnings below 25 percent of the federal poverty line ($5,040 for a family of three in 2016).[34]

A Hardship Exemption Policy Must Be Effectively Implemented So Eligible Families Don’t Fall Through the Cracks

This February, DHS convened a working group comprised of DHS staff, Councilmembers, advocates, and TANF enrollees, and tasked with developing a hardship exemption policy that would allow some households to continue receiving benefits beyond 60 months. While a robust hardship exemption policy could help mitigate some of the harms associated with a time limit, we are not confident it will effectively reach all eligible households, and some individuals are likely to fall through the cracks. This concern is grounded in existing implementation challenges, including the fact that DHS is not connecting many eligible families to the POWER program, which already exempts TANF enrollees with disabilities from the time limit.[35]

In addition, implementing a hardship exemption policy would require significant administrative capacity from an already strained DHS in order to train staff, disseminate notices, and screen at-risk TANF enrollees ahead of the October implementation date. Given that DHS has neither drafted nor approved the hardship policy as of April, it is unclear whether there will be sufficient time to build the infrastructure needed to ensure timely and accurate access to exemptions. The complexity of implementing work requirement policies—including identifying and processing exemptions—is underscored by DHS’s own decision to delay implementation of changes to SNAP work requirements from May to June.[36]

The DC Council Should Reverse TANF Cuts to Protect the District’s Most Vulnerable Families

The TANF cuts scheduled to take effect in October 2026 will deepen hardship for families, while doing nothing to improve employment in a worsening economy or address the complex life challenges TANF enrollees face. DC lawmakers must maintain cost-of-living adjustments, the absence of a time limit, and sanctions at their current levels so that children aren’t pushed into deeper hardship—an outcome that should be an explicit and central goal of any TANF reform. The Council should also reject Mayor Bowser’s newly proposed deeper cuts to TANF.

DC Council Needs a Plan for Safeguarding Economic Security Programs, Including SNAP

DC residents are facing what is likely the largest reduction to the safety net in a generation—from local cuts to TANF, housing, health, and economic security tax credit programs to deep federal cuts to SNAP, Medicaid, and housing programs. Some DC families will face overlapping cuts and punitive measures, as DHS acknowledged in its budget oversight responses. For example, of the 14,900 residents receiving both TANF and SNAP, DHS estimates that 52 percent of them are at risk of losing benefits due to looming policy changes.[37] This harm will largely fall on Black and brown residents (including children), worsening already drastic levels of racial inequity and causing DC to lose ground on the progress the District has made to strengthen the safety net in the last decade.

The scale and urgency of this threat requires the DC Council to work with DHS and other agencies to advance a unified and comprehensive strategy to reduce poverty, grow median incomes, and shore up the economy in ways that build inclusive economic growth.[38] DCFPI appreciates the DC Council’s efforts to raise alarms on these cuts, and we continue to urge members to develop a joint strategy to safeguard DC’s economic security programs. If lawmakers fail to advance an inclusive economic growth agenda and protect critical benefits, Black and brown residents will pay the largest price, and it could easily take at least a decade to regain our economic footing and restore cuts to economic security programs.

With that said, the mayor’s budget proposal reverses a few of her planned cuts to safety net programs outside of TANF (such as restoring dental and vision benefits to local health programs), and Council should build upon those improvements, including in food assistance programs, in their budget.

DC Council Should Maintain and Build Upon SNAP Improvements in the Mayor’s Proposal

Council should maintain the mayor’s proposed efforts to safeguard SNAP, which is the nation’s most important anti-hunger program, including:

  • An additional $1.7 million to DHS for SNAP services in the FY 2026 revised budget, including $791,000 to improve SNAP error rates, $500,000 to reimburse SNAP enrollees for stolen benefits, and $375,000 to fund new chip cards for SNAP enrollees to help prevent benefits theft; and,
  • An additional $2.1 million to implement chip card changes and $36 million to fund the increase in the required local share of SNAP administrative costs previously covered by the federal government due to the One Big Beautiful Bill Act (OBBBA) in the FY 2027 proposal.

This proposed funding will help to protect residents’ food assistance. But given the deep OBBBA cuts to SNAP eligibility and benefits, this Committee should further interrogate whether more DHS funding—including for staffing needs—is needed to prevent a spike in hunger. DCFPI is concerned about the proposed cut to 55.5 full-time equivalent positions in the Eligibility Determination Services unit. It is difficult to understand how DHS can afford to lose dozens of staffers when the agency is in the process of implementing SNAP work requirements for 17,000 adults this year, TANF eligibility changes later this year if lawmakers fail to reverse those cuts in the budget, and Medicaid work requirements next year.[39]

The quality of the approach DHS takes to implementing OBBBA cuts will affect how deep the damage goes. For example, how DHS ensures that no residents lose benefits for which they remain eligible due to bureaucratic processes and complexity will determine whether more or fewer District residents can put food on the table. And DHS’s ability to improve its SNAP error rate—which stands at 19.8 percent—amidst their intensive implementation workload could save, or cost, DC millions of dollars in administrative costs under new OBBBA rules.[40]

DCFPI strongly encourages the Committee to reflect on whether DHS can afford to lose 55.5 eligibility determination positions given the enormous workload facing the agency. We also appreciate Councilmember Frumin’s efforts to push DHS for clarity on advocates’ implementation questions and his work to achieve effective implementation of the OBBBA changes to ensure that not a single resident loses their SNAP benefits unnecessarily.

Thank you for the opportunity to testify. I am happy to answer any questions.

 

Endnotes:

[1] Maria Manansala, “TANF Should Be an Element of DC’s Economic Growth Agenda,” DC Fiscal Policy Institute, March 2026.

[2] LaDonna Pavetti, “Work Requirements Don’t Cut Poverty, Evidence Shows,” Center on Budget and Policy Priorities, June 2016.

[3] Ed Lazere, “Not Enough To Live On: DC’s TANF Benefits Are Among The Least Adequate In The Nation,” DC Fiscal Policy Institute, March 2006.

[4] Final rulemaking published at 58 DCR 1008, 1024, February 2011.

[5] Maria Manansala, ”Eliminating TANF’s COLA Will Harm the District’s Most Vulnerable Families,” DC Fiscal Policy Institute, April 2026.

[6] DC Fiscal Policy Institute, “What‘s in the FY 2016 Budget for Temporary Assistance for Needy Families (TANF)?,” June 2015.

[7]Maria Manansala, ”Eliminating TANF’s COLA Will Harm the District’s Most Vulnerable Families,” DC Fiscal Policy Institute, April 2026.

[8] Ibid.

[9] Economic Policy Institute, “Family Budget Calculator,” accessed April 2026.

[10] Maria Manansala, “Eliminating TANF’s COLA Will Harm the District’s Most Vulnerable Families,” DC Fiscal Policy Institute, April 2026.

[11] Urban Institute, “The American Affordability Tracker,” October 2025.

[12] Lael Brainard, “Variation in the Inflation Experiences of Households,” Board of Governors of the Federal Reserve System, April 2022.

[13] Maria Manansala, “Eliminating TANF’s COLA Will Harm the District’s Most Vulnerable Families,” DC Fiscal Policy Institute, April 2026.

[14] LaDonna Pavetti, ”Evidence Doesn’t Support Claims of Success of TANF Work Requirements,” Center on Budget and Policy Priorities, April 2018.

[15] Ibid.

[16] Ariel Kalil, Kristin Seefeldt, and Hui-chen Wang, “Sanctions and Material Hardship under TANF,” Social Service Review, December 2002.

[17] Ann Skalicky and John T. Cook, “The Impact of Welfare Sanctions on the Health of Infants and Toddlers,” Children’s Sentinel Nutrition Assessment Program, July 2002.

[18] Floyd et al., “TANF Policies Reflect Racist Legacy of Cash Assistance,” Center on Budget and Policy Priorities, August 2021.

[19] DC Department of Human Services, ”Characteristics of Residents Receiving TANF,” February 2026. ↑

[20] Maria Manansala, ”Punitive TANF Policies Will Push DC Families with Children Deeper Into Hardship,” DC Fiscal Policy Institute, April 2026.

[21] Ibid.

[22] Jennifer Mezey, “POWER/Exemption Analysis of TANF time limit provisions in BSA as adopted in July 2025,” Children’s Law Center, September 2025.

[23] DC Department of Human Services, “DHS Responses to Pre-FY25 POH Questions,” February 23, 2026.

[24] Maria Manansala, ”Punitive TANF Policies Will Push DC Families with Children Deeper Into Hardship,” DC Fiscal Policy Institute, April 2026.

[25] Federal Reserve Economic Data, ”Unemployment Rate in the District of Columbia,” accessed April 2026.https://data.epi.org/labor_force/labor_force_unemp/line/month/state11/percent_unemp_12_month/overall?timeStart=1978-12-01&timeEnd=2025-09-01&dateString=2025-09-01&highlightedLines=overall

[26] Federal Reserve Economic Data, ”Unemployment Rate,” accessed April 2026.

[27] DC Department of Human Services, “FY 2025 Performance Accountability Report,” January 2026.

[28] DC Department of Human Services, “FY 2024 Performance Accountability Report,” January 2025.

[29] Executive Office of the Mayor, “Mayor Muriel Bowser’s FY 2027 Budget,” April 10, 2026.

[30] DC Fiscal Policy Institute and Fair Budget Coalition, ”Budget Briefing and Q&A from Department of Human Services Director Rachel Pierre,” April 2026.

[31] Maria Manansala, ”Punitive TANF Policies Will Push DC Families with Children Deeper Into Hardship,” DC Fiscal Policy Institute, April 2026.

[32] Ibid.

[33] Ibid.

[34] Mitchell et al., ”Life After TANF in Kansas: For Most, Unsteady Work and Earnings Below Half the Poverty Line,” Center on Budget and Policy Priorities, February 2018.

[35] Maria Manansala, ”Punitive TANF Policies Will Push DC Families with Children Deeper Into Hardship,” DC Fiscal Policy Institute, April 2026.

[36] DC Department of Human Services, ”SNAP Work Requirements,” accessed April 2026.

[37] DC Department of Human Services, “Post-Hearing POH Questions with DHS Responses FINAL,” accessed April 29. 2026.

[38] See for example recommendations for supporting workers and addressing racial disparities in: Shira Markoff and Connor Zielinski, “Chronic Racial Inequality Holds Back Workers and Equitable Economic Growth,” DC Fiscal Policy Institute, March 9, 2026.

[39] Department of Human Services, “2026-2-23 DHS Responses to Pre FY25 POH Questions FINAL,” accessed February 2025. See page 179/241.

[40] An error rate measures the over- and under-payments that DC’s SNAP program makes in a year. Ibid, page 170/241.