HHS created new pathway to share TANF recipients' Social Security numbers and immigration status with DHS

On June 23, 2026, the Office of Family Assistance within HHS's Administration for Children and Families published a Federal Register notice modifying System of Records 09-80-0375, the Temporary Assistance for Needy Families (TANF) Data system. The notice added a new routine use — Routine Use 10 — authorizing HHS to disclose TANF recipients' personal data, including Social Security numbers and detailed immigration or citizenship status, to the Department of Homeland Security and other federal or grantee agencies "engaged to assist" with program-integrity reviews. The routine use took effect July 23, 2026, and states reported the first data release would begin August 11, 2026.

TANF was created by Congress in 1996 specifically to limit federal oversight and give states control over benefits administration and the confidentiality of recipient data. The notice asserts HHS has authority to "ensure compliance with all TANF program requirements," including verifying recipients' immigration status, and newly authorizes disclosure of Social Security numbers, dates of birth, county of residence, and detailed immigration-status categories.

Updates

2026-08-03 — 24 states and D.C. sued to block TANF data-sharing rule [2][3]

A coalition of 24 states and the District of Columbia, led by New York, sued the administration in the U.S. District Court for the District of Columbia, arguing the routine use violates the Privacy Act, the Administrative Procedure Act, and the Constitution's Spending Clause, and exceeds the narrow oversight role Congress assigned HHS under the TANF statute. New York Attorney General Letitia James called the change a "blatant effort to politically target" recipients; New Jersey Attorney General Jen Davenport said it would "obliterate" existing confidentiality protections. The states' complaint states that 95% of TANF children and 85% of adult recipients are U.S. citizens.