TO:	  Commissioners; TA Directors, Local Finance Directors

FROM:	Patricia A. Stevens, Deputy Commissioner Division of Temporary Assistance

SUBJECT:	Maintenance of Effort (MOE) Claiming

EFFECTIVE DATE:	Wednesday, January 15, 2003

CONTACT PERSON:	Paul Dichian @ 1-800-343-8859, extension 3-0684

Maintenance-of-Effort (MOE) was one of the more significant program requirements enacted by the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA). Under the Temporary Assistance for Needy Families (TANF) block grant, a state must spend 75% (80% if employment participation rates are not met) of the amount of State funds spent on assistance for Federal Fiscal Year 1994.  Failure to meet the State’s MOE requirement has the potential to increase the State and Local share of TANF expenditures.

Districts meet a large part of the State’s MOE requirement when families categorically eligible for Family Assistance (FA) must go to Safety Net Assistance (SNA) because of the State sixty-month time limit.  OTDA staff discussed the importance of MOE in the 2001 Spring Regional Training on Time Limits and Time Limit Exemptions. Additional information on MOE claiming for time limit cases is found in 01-ADM-3: “Exemptions to the State Sixty-Month Time Limit/Evaluation for Safety Net Assistance.”

When a FA case moves to SNA because of the time limit, local district staff must enter on WMS Screen 3 State/Federal Charge code 63 for every individual who remains categorically eligible for FA.  A recent review of local district claims has found that State/Federal Charge Code 63 and Code 64 for Native Americans has not been universally entered for time limited FA individuals that are now receiving Safety Net Assistance. This lack of proper coding for MOE may cause the State to report less than all qualified MOE expenditures.

The importance of correct MOE claiming cannot be overemphasized. On every case type 11 (FA) and case type 12 (non-cash SNA-FP) that moves to SNA Case (Types 16 or 17) after the time limit, districts must ensure that State/Federal Charge code 63 (TANF Individual Exceeding the 5 year limit) is entered for every categorically FA individual.  Districts should utilize “WINR 8113 – PA Caseload Tracking Report” or the “WINR 8116 – Converted Cases” to verify that State/Federal Charge Code 63 has been entered on former Family Assistance individuals who are now receiving Safety Net Assistance. 

Districts are reminded that State/Federal Charge code 63 is also used when a Family Assistance case at the State sixty-month time limit requests a fair hearing and aid-to-continue. For these cases, districts must enter time limit exemption indicator “A” (Fair Hearing) and State/Federal Charge code 63. Special Claiming code “P” must also be used.  This WMS entry insures that districts receive proper MOE credit and these cases are claimed properly. Federal reimbursement can only be claimed on Family Assistance cases beyond the State sixty-month time limit that qualify for a time limit exemption. 

We also want to reemphasize that eligible alien costs also need to be properly coded so that the State receives appropriate MOE credit.  Please remember that the failure to properly code SNA expenditures will cause increased State and Local expenditures and reduce Federal reimbursement.