Poster #46 - Administrative Rulemaking, Epistemic Injustice, and TANF Funding for Pregnancy Resource Centers

• In Event: Friday Poster Reception

Abstract

The federal rulemaking process is a critical, yet underexamined, site of knowledge production and epistemic authority in U.S. social policy. In 2023, the Administration for Children and Families (ACF) proposed a rule restricting how states allocate Temporary Assistance for Needy Families (TANF) block grant funds, including a provision designating anti-choice Pregnancy Resource Centers (PRCs) as ineligible for TANF funding. The proposed rule prompted 7,105 public comments, the majority mobilized by PRC advocates. This paper examines how public commenters discursively constructed and contested epistemic authority in debates over the appropriate use of public welfare funds, drawing on Fricker’s (2007) framework of epistemic injustice to interrogate whose knowledge counts in the governance of poverty and reproduction.

Using critical discourse analysis, we analyzed all 415 unique comments that referenced TANF funding for PRCs, submitted by concerned citizens, legislators, advocacy organizations, PRC staff and volunteers, and public benefit recipients. Comments were coded and analyzed iteratively by a five-member research team to identify themes and discursive patterns. Our analysis focused on how commenters connected PRCs to TANF’s statutory purposes, what language they used to justify or oppose public funding, and how this language reinforced or contested existing power hierarchies.

Two findings anchor this analysis. First, commenters on both sides engaged in epistemic contestation through the language of “choice.” Anti-PRC commenters, largely professional reproductive rights organizations, framed PRCs as withholding or distorting reproductive health information, constraining the knowledge available to pregnant women at the margins of society. Pro-PRC commenters argued that centers enable “true choice” by providing material support that allows women to carry a pregnancy to term, framing government restriction as itself coercive. Pro-PRC comments further exhibited a paternalistic dimension, characterizing PRC services as guiding clients toward “wise” or “good” choices. This language forecloses the epistemic authority of low-income women to define what constitutes a good decision for their own lives. Critically, when “choice” becomes the shared terrain of contestation, the debate is reframed around abstract reproductive rights and organizational funding rather than the material needs and lived experiences of low-income women themselves.

Second, commenters on both sides reproduced moral epistemologies of poverty embedded in TANF’s statutory structure. By situating PRC services within TANF’s core purposes (marriage promotion, work requirements, and prevention of out-of-wedlock pregnancy), pro-PRC advocates reinforced individualized, behavioral explanations of poverty that render structural causes of economic insecurity largely unintelligible within the policy’s logic. This reliance on public funds reflects a reciprocal dynamic in which PRCs increasingly function as substitutes for the state in providing material support to low-income families. This organizational dependence on TANF funding shifted the focus of the comment record away from the needs and experiences of TANF recipients and toward the preservation of PRC funding streams.

Our findings demonstrate that the narratives of advocates and volunteers were privileged over those of the families meant to benefit from the proposed rule, reinforcing epistemic injustice. Strengthening public participation in the rulemaking process to include the voices of benefit recipients is a necessary precondition for welfare governance that meaningfully serves low-income families.

Authors

• Madri Hall-Faul, University of Kentucky
  Presenting Author

• Emily Loveland, California State University San Bernardino
  Non-Presenting Co-Author

• Gilean Chikwati, University of Kentucky
  Non-Presenting Co-Author

• Kathryn Libal, University of Connecticut
  Non-Presenting Co-Author