This public comment provides supporting evidence regarding the first and second proposed rules: to establish a ceiling on the term “needy” and to clarify when an expenditure is “reasonably calculated to accomplish a TANF purpose.” Drawing on Hahn’s expertise in TANF policy and practice, the comment argues that these proposed rules appropriately balance state flexibility with ensuring TANF funds directly support children in need. To maximize support for children in need, it also will be important not only to rein in TANF spending that doesn’t accomplish a TANF purpose, but to encourage or incentivize states to spend their TANF block grants, so “misused” funds do not become merely “unspent” funds.