Date: March 4, 2025
To: Rep. Ben Baker, Chairman, and Members, Committee on Government Efficiency
From: Christine Woody, Food Security Policy Manager, Empower Missouri
Re: Our Opposition to HB 315
Founded in 1901, Empower Missouri advocates for the well-being of Missourians through civic leadership, education, and research. As part of our work, we organize a statewide coalition called the Food Security Coalition. This coalition is made up of individuals and organizations who are working to ensure every Missourian has access to healthy and nutritious food and that Missouri has a strong safety net for those who need it. On behalf of our staff, board, and all of the members of the Food Security Coalition convened by Empower Missouri, I stand in opposition to HB 315
HB 315 would end the ability for TANF recipients to access cash with their TANF benefits. Empower Missouri believes that parents on TANF need access to cash to survive in the extremely dire financial circumstances their families are already living in. In Missouri, someone has to make less than $3,504 per year to qualify for TANF benefits and they only receive approximately $233 per month, not nearly enough to survive.
There are still many situations in which paying with cash is the only option for families. A few examples of when a person on TANF may need to access to cash include:
- To put cash into a washer and dryer at a public laundry
- To pay for things their children may need at school, like class parties, field trips, fundraising, etc.
- To shop at a yard sale in their neighborhood – most such sales would not use machines that read EBT cards
- To offer $5 to a neighbor who provides a ride to a job interview or medical appointment
- To pay rent to a landlord who accepts only cash, checks, and money orders as payments
- To compensate a neighbor for babysitting
Besides making it more difficult for families on TANF, this new law would not be allowable through current federal government regulations. The language of the bill states that Missouri would ask for a waiver to be allowed to do this. That sort of waiver has never been granted. In 2015, Kansas passed a bill that tried to cap TANF withdrawals to one $25 withdrawal per day. The Federal Government replied to Kansas stating this was not allowed and ultimately Kansas never implemented the law.
Then in April 2016, the U.S. Department of Health and Human Services Administration for Children and Families (ACF) published some clarifying and additional guidance on access provisions for states administering the TANF program. This guidance comes from Section 4004 of Public Law 112-96. ACF reiterates that “Public Law 112-96 also requires states to include in their state TANF plans an explanation of how the state will ensure that recipients of TANF assistance have adequate access to their cash assistance…”
The ACF reviewed each state’s TANF plan and has outlined three principle areas of adequate access for state TANF programs:
- “States should maximize the flexibility for recipients to access cash withdrawals.”
- “States should seek to minimize or eliminate withdrawal fees and ATM surcharges for TANF recipients, and must provide recipients an opportunity to access assistance with no fees or charges.”
- “Maximize the geographic distribution of ATMs and/or provide other case access points.”
Further information from the ACF can be found here: https://www.acf.hhs.gov/ofa/resource/tanf-acf-pi-2016-02
For these reasons we ask you to not pass HB 315 out of this committee. We thank you for your time and consideration.
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