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How can a TANF agency reasonably modify its policies, practices, and procedures for people with disabilities?

Sometimes people with disabilities are unable to participate in or benefit from a TANF program without modifications to policies, practices, and procedures. Under Section 504 and the ADA, TANF agencies must reasonably modify policies, practices, and procedures to avoid discrimination on the basis of disability, unless the modification would fundamentally alter the nature of the service, program or activity.

One size does not fit all in regard to modifications. TANF agencies should assess the needs of each applicant or beneficiary with a disability and make reasonable modifications tailored to meet those needs.

Modifications may be needed in the: (1) TANF application process; (2) procedures related to notifying TANF applicants and beneficiaries of their rights; (3) requirements of TANF programs; (4) policies and practices concerning exemptions, extensions and sanctions; and (5) policies and practices that aid individuals in sustaining TANF program participation.


~A TANF agency requires face-to-face eligibility interviews. Due to a disability, a person is unable to physically access the TANF office for an eligibility interview. As a reasonable modification, the TANF agency could meet with the client at an accessible location, or conduct this eligibility interview over the phone.

~A TANF agency has education and training programs, and has instituted time limits for completing the programs. A client with a learning disability has difficulty completing the education and training program within the required time limit. As a reasonable modification, the TANF agency could grant an extension to the time limit if the extension would not fundamentally alter the nature of the program.

Content created by Office for Civil Rights (OCR)
Content last reviewed on September 1, 2015