In response to an earlier blog entry about the deadline for posting comments on the Interim Temporary Assistance rules, we received an e-mail from Dr. Exclusio Gragstadler, Director of the Exclusionist Institute for the Behavioral and Marital Health of Those Welfare People in Coeur D’Alene, Idaho. Dr. Gragstadler vociferously disagreed with the recommendation that HHS should promote marriage by promoting college. As he put it, “TANF is a welfare program for welfare people, and is not meant to be a college schlolarship program for college people.” He also enclosed his own comments to HHS on the rules. We reprint them here not as an endorsement of their contents, but simply to provide a conservative perspective on Temporary Assistance. The comments are unedited by us, except for the inclusion of a few hyperlinks that we thought might aid our readers.

Dearest Fellow Doctor Horn:

I know that you, like our humble President, are merely a faithful servant faithfully serving the “will of the people.” Knowing that you will faithfully consider and act on public comments on the Interim Rule, just as you faithfully did lo so many years ago when you requested comments that were faithfully reflected in the Administration’s 2002 plan for TANF Reauthorization, I have been especially dedicated in my preparation of these comments. I assure you I have given them every bit of consideration they deserve. Let me add that while my comments may be brief my good man, they are very thoughtful and carefully based on research. To the exact extent, coincidentally, as the Administration’s TANF reauthorization proposal was also carefully based on knowledge and academic evidence. My first comment is thank you. Thank for you for the particular dedication you and the Administration have shown, both in your inspired plan for reauthorization (my sincere condolences for what happened with that one, it’s sad to see so many good ideas—superwaivers, 40 hour work requirements, universal engagement—lie fallow) and in these Regulations for putting a stake in the heart of the noxious notion that “state flexibility” has any role to play in an important federal, nay, American program such as TANF. We—and I mean the royal, err, national “we”, you and I—are both Doctors and national leaders, so I am sure we all agree that we know better than all those people toiling on the front lines in the states. Isn’t that why we’re “playing in the majors” after all and they’re still stuck in the minors? And while the foremost tenet of our profession may be, first, do no harm, the second is certainly, we national Doctors know better. You and I both know that state officials—or, as we like to call them, the TANF “farm team”— were getting a bit full of themselves. It was almost as if some of them had started to believe that they knew best—that they had figured out on their own, without our expert federal guidance and direction, how to “reform welfare.” Some leftist advocates, in cohoots with their latte-sipping, Volvo-driving comrades in “left-coast” media outlets have even begun to claim that TANF “isn’t welfare any more” and that “welfare dependency” is no longer one of the most important public issues of the day. (Of course, the illegal immigrant invasion and the decline of marriage are the top two, but welfare dependency is certainly the third, whether the public, misled as they our by the powerful liberal media and Hollywood, realizes it or not.) We admire your cleverness sir! The new regulations will put these minor leaguers in their place. And by keeping state officials busy, busy, busy from now on—especially with all of the fabulous new bean-counting, err, I mean “reporting and monitoring” requirements—we can rest assured that the farm team will stay focused on the “trees” and miss the “forest.” You know what they say about idle hands …. Moreover, the looming threat of fiscal penalties should states fail to meet the new requirements in the way we want them to will definitely show them “Who’s Their Daddy.” States will soon find out how wrong the Congressional Budget Office was to project that no significant participation rate penalties will be levied on states before 2009, and that only modest penalties will be levied in subsequent years. We’ll show them won’t we! I do have one recommendation on the penalty front, however. The current rules unfortunately require states that fail to meet the participation rates to actually increase their state funding (MOE) contributions and, even worse, to not take the penalty money out of the TANF program. This means more welfare rather than less, and seems highly counterproductive. Please fix it in the rules so that the penalties come directly from reductions in benefit checks of dependent welfare recipients (in other words, everybody who recieves TANF). Since you didn’t include our proposal to mandate “full-check” sanctions in the Administration’s TANF plan, I feel this is the least you can do. Our second comment is also a “thank you”—thank you for clearly establishing, as you do in the revisions to 261.2(e) of the rules that TANF is not “assistance” but “welfare.” Welfare is welfare, period, just like the death tax is the death tax, period—and these rules will make that a matter of federal law. (Perhaps there should also be a penalty for those farm team officials who fail to include the word “welfare” in the names of their state TANF programs?) We also recommend that you use this regulatory opportunity (alas, it may be our last one, the way things are going) to change the name of Temporary Assistance to the Temporary Welfare for Needy Welfare Recipients Welfare Program or TWNWRWP for short. As a doctor steeped in research, you know that public opinion polling shows that most people support “assistance for the poor” but oppose “welfare.” Including three mentions of “welfare” in the name of the program would reinforce the notion that Temporary Assistance is not just welfare singularly but also welfare three times over, and therefore bad bad bad, indeed harmful harmful harmful, instead of something that people may be fooled into thinking is good, or even good good good. Well, I don’t want to keep you or me any longer from our vital work of promoting marriage. It’s been such a treat to see our morality reintroduced in government—it almost makes me think Grover was wrong to say that we need to shrink government down to a small enough size so that we can drown it in a bathtub. All of those whiners who insist on focusing on the negatives—like the small increase in so-called “poverty” since 2000—have missed the point entirely. And anyway, what’s a few million more poor, especially since they all have VCR’s as our good colleague Dr. Rector has shown. I bet most of them even have DVD players and subscribe to Netflix now. You know and we know what really matters is how highly you, me and our other virtuous colleagues on the right have valued the sacred institution of marriage. That reminds me, two of those colleagues, Newt and Bill, now distinguished and esteemed senior fellows at my Institute, pass on their regards and complete support for these comments. We close with the gentle reminder that TWNWRWP is actually supposed to be reauthorized once every five—not ten years—so you might want to go ahead and get started on that so we can have our friends sneak it into the next 700-page tax cut, err, “Deficit Reduction” bill, a few hours before Congress votes on it. Sincerely, Dr. Exclusio Gragstadler, Ph.D, J.D., M.D., M.S.W. Director and Distinguished and Esteemed Senior Fellow The Exclusionist Institute on the Behavioral and Marital Health of Those Welfare People PS: I’ve been meaning to ask: are you related to Doctor Phil, or is there just an uncanny resemblance?

No need to answer this in the regulations directly, but we at the Institute are interested, and since he goes by just his first name, it’s hard to tell. PPS: Which actually gives us another great idea—have you thought about just going by Dr. Wade? It might help you break into the more lucrative TV market, particularly now that we hear he and Oprah are on the outs. PPPS: The latest installment of our healthy marriage promotion grant has yet to arrive. Bill has said it will only take him a few days to triple the amount once we receive it, so could you look into it?