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Iowa’s TANF State Plan: Attachments 11. Information describing the policies and practices were added to the State TANF Plan when it was renewed in December 2013 effective October 2013 (See Exhibit 10).

12. After confirming with the Office of Refugee Resettlement that there was no federal prohibition, the state elected to apply the same policies and procedures with respect to Refugee Cash Assistance (RCA).

Final federal regulations issued on January 15, 2016, provided additional clarification concerning states’ responsibilities in complying with section 4004 of P.L. 112-96. The regulations specified the four components that must be addressed in a state’s policies and procedures, as well as provided guidance and suggestions for different ways that states can comply with each component. While states are required to include all four components in their policies and procedures, the final regulations also stress that states have some flexibility in how they do so.

The final federal regulations described nine options or steps that states could use to comply with the first required component. These options focus on who is responsible for preventing EBT transactions of TANF benefits at the types of businesses listed. Options fall into three categories: (1) requirements for ‘third-party processors” – entities that actually process EBT transactions; (2) retailers – the actual businesses where transactions are prohibited; and (3) the families receiving TANF benefits. The regulations do not require that states utilize any particular option(s) listed, or that states use options under more than one category. The preamble to the regulations does clarify that notification approaches to TANF applicants/recipients alone are not sufficient, except for EBT transactions from private bank accounts, on tribal lands and in other states.

In evaluating each of the nine options identified in the final regulations, the state determined that several options were not separate but rather were an integral part to one or more other options. Other options were not readily available to the state and /or would not be cost effective.

Iowa’s policies and procedures continue to focus on applicants and recipients. In addition to the extensive notification practices described above, Iowa also holds applicants and recipients responsible for any failure to comply. As described above, under FIP administrative rules already in effect at the time the final federal regulations were published, recipients found to have accessed their TANF benefits at a prohibited location by way of EBT have committed fraud, must repay any benefits accessed at such location, and are ineligible for FIP for a period of three months for a first-time violation, and for a period of six months for each subsequent violation.

The final regulations identify “Requiring cardholders to agree in writing not to use TANF assistance at prohibited locations as a condition of receipt” as a separate means or option than notification. Effective January 1, 2017, FIP administrative rules were amended to require that “as a condition of eligibility, applicants and recipients must agree in writing to not use an electronic access card at prohibited locations.” See Exhibit 11 for