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The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) shifted cash welfare to a block grant, granting states broad flexibility in administering Temporary Assistance for Needy Families (TANF). Since then, the program’s structure has led to a steep decline in families reached by TANF cash assistance with little action by Congress to address its inadequacies. Some presidents have tried using executive power to shape PROWORA’s implementation. The Obama administration eased work requirements, though these efforts were stalled through legislative and judicial intervention. The Biden administration also proposed a rule restricting how states spend TANF funds, out of concern that block grants are not reaching low-income individuals and families.
The federal rulemaking process allows agencies to implement laws through regulations under the Administrative Procedure Act. Proposed rules are published in the Federal Register, with public comment periods for 30–60 days. While intended to encourage democratic input, participation is often dominated by businesses and interest groups with the resources to influence rulemaking. This paper analyzes the discourse of one such group – Pregnancy Resource Centers (PRCs, or Crisis Pregnancy Centers) which mobilized a mass comment campaign against the Biden administration proposed TANF rule, which disqualified PRCs from TANF funding.
Methods
This study uses critical discourse analysis to examine how commenters used language to express power, ideology, and assumptions about poverty, family, and the role of TANF funding for PRCs. All public comments referencing TANF funding for PRCs were analyzed (n = 416). Five authors conducted memo-based analysis of all comments through a structured five-question guide focused on discursive framing and power. Each comment was read by at least two authors during categorization and memoing. Next, we analyzed the memo set, identifying key themes. We refined themes through collaborative team analysis and used ChatGPT to confirm central patterns and improve analytic rigor.
Results
Clear differences exist between unrestricted TANF cash assistance through states and conditional PRC material assistance provided to pregnant women. Yet, PRC supporters framed PRCs as aligned with TANF’s goals, portraying them as essential providers of material aid, parenting support, and moral guidance. They viewed the proposed rule as unfairly “targeting PRCs” and overextending executive power. Supporters used moral, religious, and family-centered language to justify funding, reflecting power dynamics favoring privatized, faith-based welfare. TANF recipients were depicted as deserving but needing guidance, reinforcing paternalistic assumptions about poverty tied to traditional family roles. Commenters emphasized that without PRCs, many women would lack resources and “choice.” The overwhelming response from PRC supporters demonstrates the dependence of these organizations on TANF funding.
Conclusions/Implications
The results illustrate the interconnectedness of public welfare funding and the anti-abortion movement while emphasizing a need to capture all perspectives in feminist and human rights research. Many comments revealed material vulnerability among PRC supporters, suggesting that beyond ideology, economic precarity and lack of access to government support could drive advocacy for faith-based solutions within local policy contexts. Researchers should avoid binary progressive-conservative framings and instead engage the nuance of lived experience in contexts of inequality and constraint.