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Child care subsidy work requirements
Child care subsidy work requirements are mandated work-related activities that child care subsidy recipients must complete to qualify for benefits, such as applying for a job, interviewing for a job, or participating in job training or volunteer activities.
The Child Care and Development Fund (CCDF) is the primary source of federal child care subsidies in the United States.[1] States design child care assistance programs within federal guidelines and award CCDF and TANF funds for child care to low-income families so they can seek employment or job training.[2][3]
Background
This section provides information about the history, administration, and work requirements for child care subsidies.
History of child care subsidies
The Social Security Act of 1935 established the Aid to Dependent Children Program (ADC), which created subsidies to help families in which fathers were "deceased, absent, or unable to work," according to the text. ADC was changed to Aid to Families with Dependent Children (AFDC) in 1962.[4][5]
AFDC was replaced with two child care grants in the 1990s: the Child Care and Development Fund (CCDF) and Temporary Assistance for Needy Families (TANF). CCDF provides funds to assist low-income families in obtaining child care so they can work or attend education and training programs. TANF provides cash payments to help families pay for food, clothing, housing, and other essentials. States can transfer up to 30 percent of TANF funds to supplement CCDF child care initiatives. Families who receive cash assistance from TANF may receive child care funded by CCDF or TANF.[6][7][8]
Administration of child care subsidies
The U.S. Department of Health and Human Services (HHS) Office of Child Care oversees the distribution of federal CCDF grants and TANF funding to the states. CCDF programs are then administered by states, territories, and tribal governments.[9][10]
Work requirements for child care subsidies
The two main sources of child care subsidies in the U.S. are Temporary Assistance for Needy Families (TANF), which provides cash assistance to low-income families, and the Child Care and Development Fund (CCDF), which provides subsidies to assist low-income families with the costs of child care.
TANF work requirements
TANF is a federal block grant program that provides funding to states, which administer benefits and set program rules within federal guidelines. Federal law requires states to meet minimum work participation rates among families receiving assistance. States that fail to meet these rates may face financial penalties. Individual state policies that are aimed at keeping states compliant with the federal work participation rates vary greatly. States may require families to work a certain number of hours per week, may create individual plans with families, may have broader or narrower definitions of work activities, may offer different exemptions, or have different sanctioning practices. Ballotpedia doesn't currently cover these state-level variations in TANF policy.[11]
The two federally-set work participation rates for TANF are the all-families rate and the two-parent families rate:[11]
- All-families rate: 50% of families receiving TANF must participate in federally defined work activities for at least 30 hours per week.
- Two-parent families rate: 90% of families with two parents must participate in work activities for at least 35 hours per week (or 55 combined hours if receiving child care assistance).
Some states are not subject to the two-families rate. This may be because the state does not provide TANF funds to two-parent families, the state uses a simplified payment system that does not differentiate between single-parent and two-parent families, the state provides for two-parent families through Separate State Plans (SSP) that do not use federal funds, or another reason.[12]
The all-families and two-parent families rates can be adjusted by a caseload reduction credit. States earn these credits if their TANF caseloads have fallen since 2015. Many states have full caseload reduction credits, meaning that their work requirement participation rates are effectively 0% and the state would technically face no penalty if none of the state’s TANF recipients were working. However, that does not necessarily mean that TANF work requirements are not in place or enforced. Caseload reduction credits adjust state-level penalty thresholds, but families are still subject to work rules and possible sanctions from the state.[13]
Below are maps displaying the caseload reduction credits and the adjusted participation rates for each state:
CCDF work requirements
Federal law requires that parents receiving CCDF child care subsidies work or complete work-related activities. States are responsible for defining the activities that qualify a family for assistance through CCDF, including work requirements, education participation, and community service. Employment is an approved activity for CCDF funding in every state and some states also approve subsidies for parents participating in education and training activities. Working, periods of job search, self-employment, attending job training or education-related activities, foster care, and subsidized guardianship are activities that meet eligibility standards for CCDF subsidies in different states. State agencies have flexibility in determining eligibility for CCDF subsidies, according to HHS regulations.[14][15][16]
Below is a map showing the number of hours of work activities that qualify families for assistance through CCDF in each state:
History of child care subsidy work requirements
The section provides information on the history of work requirements for child care subsidies.
Social Security Amendments of 1961 extend ADC to families with unemployed fathers, require job searches
The Social Security Amendments of 1961, signed by President John F. Kennedy (D) on June 30, 1961, permitted states to extend ADC to families with unemployed fathers. The amendments required unemployed fathers receiving ADC funds to work with public employment offices at the state level, register for job placement services, and prohibited the refusal of employment without good cause. The Social Security Amendments allowed federal and state governments to enter into cooperative agreements to promote employment and job training and permitted states to deny all or any part of ADC aid if a family failed to meet job search or training requirements. Twenty-five states adopted measures to extend ADC subsidies to families with unemployed fathers following the Social Security Amendments of 1961.[17][18]
Social Security Amendments of 1967 create the Work Incentive Program
The Social Security Amendments of 1967, signed by President Lyndon B. Johnson (D) on January 2, 1968, created the Work Incentive Program (WIN) for families receiving AFDC subsidies. The WIN program directed state welfare agencies to refer all persons deemed appropriate to job and training programs. Federal guidelines prohibited states from mandating work requirements for anyone under the age of sixteen attending school, anyone with an illness or advanced age, or anyone "whose substantially continuous presence in the home is required," according to the amendments. Under WIN programs, state welfare agencies made payments to employment offices, and the U.S. Department of Labor made arrangements for recipients to work on special work projects sponsored by local employment offices. AFDC funds were conditioned on participation in labor projects and terms were negotiated with the state agencies sponsoring work projects.[19]
The Family Support Act of 1988 creates the JOBS program
The Family Support Act of 1988, signed by President Ronald Reagan (R) on October 13, 1988, amended Title IV of the Social Security Act of 1935 to revise the AFDC program to emphasize work. It mandated that each state create a Job Opportunities and Basic Skills Training program (JOBS) to replace the WIN program by October 1, 1990. The Family Support Act mandated that each JOBS program include education, job skills training, job development and placement programs, and job readiness activities. The act required AFDC recipients to participate in state JOBS programs and accept legitimate offers of employment.[20]
CCDF provides child care subsidies to families with working parents
The Child Care and Development Block Grant Act of 1990 (CCDBG Act) created the Child Care and Development Fund (CCDF) to provide child care subsidies for low-income families with parents participating in certain work, education, or training activities.[21]
Lawmakers replace JOBS program with TANF, include work requirements for eligibility
The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), signed by President Bill Clinton (D) on August 22, 1996, replaced AFDC and the JOBS program with a block grant called Temporary Assistance for Needy Families (TANF). Under AFDC, the federal government created work requirement guidelines and states administered the program by determining eligibility. Under TANF, states are given block grants and authority to design and administer state-based programs within broad federal guidelines. Federal guidelines for TANF include a lifetime limit of five years during which a family may receive assistance, increased work requirements, and increased state flexibility for program design. Federal guidelines for TANF state that recipients must work as soon as they are job-ready or no later than three years after first receiving assistance. Federal guidelines require that single parents participate in work activities at least 30 hours per week. State governments oversee work requirements for TANF and the failure to participate in work requirements can result in the termination of child care benefits.[22][10]
The Deficit Reduction Act of 2005 (DRA), signed by President George W. Bush (R) on February 8, 2006, reauthorized TANF, raised work participation rates, increased the number of recipients subject to work requirements, and limited activities that counted as work. DRA mandated in part that 50 percent of all adults and 90 percent of two-parent households receiving TANF assistance must participate in work activities; that unpaid work activities must be supervised daily for recipients to maintain eligibility; and that all hours of participation in unpaid work activities be documented.[23]
The Claims Resolution Act of 2010 allows states to exempt TANF recipients from work requirements
The Claims Resolution Act of 2010, signed by President Barack Obama (D) on December 8, 2010, extended TANF and included two new state reporting requirements. The law required states to provide details about work participation for families that did not meet TANF's work participation requirements and required states to submit reports detailing TANF spending. The act allowed state policies to exempt individuals from work requirements but stipulated that work participation reporting included all work-eligible individuals within the states.[24]
Law prohibits states from removing TANF or CCDF funding for the first year of eligibility if parents do not meet work requirements
The Child Care and Development Block Grant Act of 2014, signed by President Barack Obama (D) on November 19, 2014, reauthorized the CCDF and set new guidelines for CCDF and TANF. The act said that the U.S. Department of Agriculture (USDA) and the states could not create additional work requirements for child care subsidies. The act mandated that states provide a minimum 12-month eligibility period for all children in families eligible for TANF or CCDF-funded child care, and did not permit states to remove parents' benefits during the first 12 months of receiving TANF or CCDF benefits.[25][26]
HHS implemented a final rule based on the Child Care and Development Block Grant Act of 2014 on November 29, 2016. The rule permitted agencies to alter or waive federal eligibility requirements, including work requirements, to determine parent eligibility for CCDBG and TANF subsidies.[27]
Executive Order 13828 calls for the review and enforcement of work requirements
Executive Order 13828: Reducing Poverty in America by Promoting Opportunity and Economic Mobility, signed by President Donald Trump (R) on April 10, 2018, called for a review of all public assistance programs, with and without work requirements, to "determine whether enforcement of a work requirement would be consistent with Federal law and the principles outlined in this order." E.O. 13828 called for a review of federally funded workforce development programs and mandated that programs be consolidated if more than one executive department or entity administers similar programs. State agencies were directed to enforce existing work requirements for public assistance programs, such as child care.[28]
Timeline of child care subsidy work requirements
The following timeline features a selection of noteworthy events related to the development and implementation of work requirements for child care subsidies:
- August 14, 1935: The Social Security Act of 1935 created the Aid to Dependent Children Program (ADC) to help families in which fathers were "deceased, absent, or unable to work."
- June 30, 1961: The Social Security Amendments of 1961 extended ADC to families with unemployed fathers and mandated that unemployed fathers receiving ADC funds work with employment offices at the state level to find employment.
- January 2, 1968: The Social Security Amendments of 1967 created the Work Incentives Program (WIN), and families receiving AFDC were referred to job and training programs to maintain eligibility for AFDC.
- October 13, 1988: The Family Support Act of 1988 mandated that each state create a Job Opportunities and Basic Skills Training Program (JOBS) that included education, job skills training, job development and placement programs, and job readiness activities for families receiving AFDC.
- November 5, 1990: The Child Care and Development Block Grant Act of 1990 (CCDBG Act) created the Child Care and Development Fund (CCDF) to provide child care subsidies for low-income families with parents participating in certain work, education, or training activities.
- August 22, 1996: The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) replaced AFDC with Temporary Assistance for Needy Families (TANF) and required that TANF recipients participate in work-related activities at least 30 hours a week to maintain benefits.
- February 8, 2006: The Deficit Reduction Act of 2005 (DRA) renewed TANF, increased the number of recipients subject to work requirements, and limited activities that counted as work.
- November 19, 2014: The Child Care and Development Block Grant Act of 2014 (CCDBG Act) reauthorized CCDF child care subsidies.
- November 29, 2016: HHS implemented a final rule based on the Child Care and Development Block Grant Act of 2014. The rule permitted agencies to waive federal work requirements for low-income families.
- April 10, 2018: Executive Order 13828 called for review and enforcement of existing work requirements for public assistance, including child care subsidies.
See also
- Arguments about work requirements for public assistance programs
- Court cases related to work requirements for public assistance programs
- Scholarly work related to work requirements for public assistance programs
- Child care subsidy work requirements in the states
- Child care subsidy work requirements during the Biden administration
- Child care subsidy work requirements during the Trump administration
External links
Footnotes
- ↑ acf.gov, "OCC Fact Sheet," accessed August 21, 2025
- ↑ ACF, TANF, accessed May 30, 2023
- ↑ First Five Years Fund, CCDBG, accessed May 30, 2023
- ↑ Social Welfare Library, Aid to Dependent Children, accessed May 30, 2023
- ↑ Social Welfare, Mothers Aid, accessed May 30, 2023
- ↑ Urban Institute, Child care subsidies, accessed May 31, 2023
- ↑ CLASP, Implications for CCDBG Reauthorization, accessed June 2, 2023
- ↑ HHS, TANF cash help, accessed June 2, 2023
- ↑ ‘’HHS,’’ ‘’Child Care and Development Fund,’’ accessed May 31, 2023
- ↑ 10.0 10.1 First Five Years Fund, Temporary Assistance for Needy Families, accessed June 1, 2023
- ↑ 11.0 11.1 Center on Budget and Policy Priorities, "Policy Basics: Temporary Assistance for Needy Families," accessed September 25, 2025
- ↑ U.S. Office of Family Assistance, "Graphical Overview of State and Territory TANF Policies as of July 2022," accessed September 25, 2025
- ↑ U.S. Office of Family Assistance, "TANF Provisions in FRA of 2023," accessed September 2025
- ↑ Urban Institute, Child care subsidies, accessed May 31, 2023
- ↑ HHS Child care, parental activities and reason for care, accessed May 31, 2023
- ↑ Child care aware, child care and development block grant, accessed May 31, 2023
- ↑ Congress, Statute 75, accessed May 30, 2023
- ↑ Encyclopedia, Aid to Dependent Children, accessed May 30, 2023
- ↑ Senate, Social Security Amendments of 1967, accessed May 30, 2023
- ↑ University of Wisconsin, Family Support Act of 1988, accessed May 30, 2023
- ↑ Congress.gov, "Child Care and Development Block Grant Act of 1990," accessed December 21, 2023
- ↑ HHS, AFDC, TANF, work requirements, accessed May 30, 2023
- ↑ CPBB, Changes to TANF Requirements Under the Deficit Reduction Act and Interim Final Regulations, accessed May 31, 2023
- ↑ HHS, The Claims Resolution Act of 2010, accessed June 1, 2023
- ↑ HHS, 2014 Child Care Reauthorization, accessed June 1, 2023
- ↑ Gov Info, Public law 113-186, accessed June 1, 2023
- ↑ Federal Register, Child Care and Development Fund Rule, accessed June 1, 2023
- ↑ Gov Info, Executive Order 13828, accessed June 1, 2023
