Division of Family and Economic Security, Bureau of Working Families

Wisconsin Works (W-2) Manual

2.10.9 Federal 60-Month Lifetime Limit

Federal law allows states to establish their own lifetime limit for federal TANFTANFTemporary Assistance for Needy Families cash assistance of up to 60 months. Wisconsin has established a 48-month lifetime limit for federal TANF cash assistance; however, the lifetime limit varies by state.

Regardless of which state federal TANF assistance is received, it is counted as part of the 60-month federal lifetime limit and Wisconsin’s 48-month lifetime limit.

Wisconsin calculates state and federal time limits differently. Not all months that count towards the 48-month state lifetime limit will also count toward the 60-month federal lifetime limit, and vice versa. For example, certain CMCCMCCustodial Parent of an Infant placement months may only count toward the federal lifetime limit. (See 2.10.8)

Only months of assistance that are paid for with Federal TANF funds (in whole or in part) count toward the federal lifetime limit. (See 9.4.3)

A month counts towards the 60-month federal lifetime limit if the individual:

  1. Receives an actual payment of $1 or more through participation in a CSJCSJCommunity Service Job or W-2 TW-2 TW-2 Transition placement. (See 2.10.2.1)
    • Months where the full payment was sanctioned to $0 prior to W-2 pulldown do not count towards the federal lifetime limit.

Note: If the placement on the last working day of the month is a TEMPTEMPTrial Employment Match Program placement (TMPTMPCustodial Parent Trial Employment Match Program or TNPTNPNoncustodial Parent Trial Employment Match Program), and there was a payment of $1 or more for a CSJ or W-2 T placement in the same calendar month, the month will also count toward the individual’s 60-month federal lifetime limit due to receipt of federally funded TANF cash assistance.

  • Months where a delayed payment is received count towards the month for which there was participation.
  1. Receives a CMC payment and a W-2 T or CSJ placement immediately preceded the CMC placement. (See 2.10.8 for more information on time limits for CMC placements)
  2. Receives transportation assistance while in an unpaid, case management only placement and certain conditions are met. (See 9.4.3)
  3. Received TANF cash assistance in any other state. (See 2.10.2.3.1)
  4. Is a parent in the W-2 GroupAn adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) and is married to the placed parent who receives an actual CSJ or W-2 T payment of $1 or more.
    • Months do not count toward the 60-month federal lifetime limit if the individual is a Non-marital Co-parentWith respect to an individual and a dependent child, a parent who is not married to the child’s other parent and is either an adjudicated parent or a parent who has signed and filed with the state registrar under s.69.15(3)(b)3, Stats., a statement acknowledging paternity and is not the parent in a W-2 placement during a month.

The individual is exempt from having months count towards the federal lifetime limit if the individual:

  1. Is a qualified non-citizen or the placed parent in the W-2 Group is a qualified non-citizen. (See 2.4.2)

W-2 payments made to qualified non-citizens are paid through state funds, not federal TANF funds; therefore, those months do not count towards the federal lifetime limit.

  1. Lives or has lived on a federally recognized American Indian reservation, an Alaskan Native village, or an Indian country occupied by an Indian tribe during a month where at least 50% of the adults were not employed. (See 2.10.2.2)
  2. Received a $50 supplemental payment through participation in a CMF+ placement. Supplemental payments made to CMF+ participants are paid through state funds, not federal TANF funds; therefore, those months do not count towards the federal lifetime limit.

EXAMPLE 1: Judy and Joan are married and have adopted a child. Judy is participating in a CSJ placement. For every month that Judy receives a payment for her CSJ participation, Joan also uses a month that counts toward both the federal 60-month limit and state 48-month lifetime limits.

EXAMPLE 2: Melissa and Keith live together as Non-marital Co-parents and have two children. Melissa is in a W-2 T placement. For each month that Melissa receives a payment for her W-2 T participation, Keith will also uses a month that only counts toward the state 48-month lifetime limit. Because Keith is not married to Melissa, his months do not count towards his federal 60-month lifetime limit.

EXAMPLE 3: Ahmed and Julienne are married and have one child. Ahmed is a qualified non-citizen and is participating in a CSJ placement. Julienne is a U.S. citizen. For each month Ahmed participates in a CSJ placement, Julienne also uses a month which only counts toward the state 48-month lifetime limit. Because Ahmed is a qualified non-citizen and his CSJ payment is paid through state funds and not federal TANF funds, these months do not count towards Ahmed or Julienne’s federal time limits. If Julienne became the placed parent, those months would count towards her federal time limit, but they would not count towards Ahmed’s time limit because he is a qualified non-citizen.

EXAMPLE 4: Hilda applies for W-2 on May 22. Her FEP places her in a W-2 T placement starting May 25. Hilda will receive a delayed payment in June for her May participation. In the Time Limit Tracking module, Hilda will use a W-2 T month for May and the month used will count toward both the state 48-month lifetime limit and federal 60-month lifetime limits based on her participation from May 25 to May 31.

2.10.9.1 Changing the Federal Indicator

The number of months for which an individual receives a TANFTANFTemporary Assistance for Needy Families payment must equal the number of federal months used. If a discrepancy exists between payments received and federal lifetime months, the FEP, or the FEPFEPFinancial and Employment Planner’s supervisor, must adjust the individual’s 60-month federal time limit by changing the Federal Indicator for the month of participation in the WWPWWPWisconsin Work Programs Time Limit Tracking application from “Yes” to “No” in the following situations:

  1. An individual in a W-2 employment position voluntarily returns in full a payment that was sanctioned due to nonparticipation.
  2. An individual repays in full an overpayment for W-2 payments they should not have received due to:
    1. Intentional Program Violation (IPV);
    2. Sanctioned participation that was not entered in a timely manner by the W-2 agency; or
    3. Fraud.
  3. A system error in the Time Limit Tracking application caused an individual who meets the exemptions listed above to incorrectly use a month of their 60-month federal lifetime limit.

By updating the Federal Indicator, the month will still count towards an individual’s state and placement limit, if applicable, but will not count towards the federal 60-month lifetime limit.

For information on subtracting entire months of eligibility, see 2.10.5.