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In 2023, the Administration for Children and Families (ACF) proposed a rule to address misspending of Temporary Assistance for Needy Families (TANF) block grants. This included a proposal that Pregnancy Resource Centers (PRCs) could not receive funding. A group of mobilized constituents responded to this rule via the public comment process, yielding more than 7,000 comments.
Public comments permit democratic engagement for those aware of the rulemaking process. Using a framework of epistemic injustice, exploring how power and politics shape the development and dissemination of knowledge, helps contextualize this process. Two types of epistemic injustice are hermeneutical and testimonial. Hermeneutical injustice occurs when a person is unable to express knowledge. As public commenting is not a well-known process, participation is limited. Testimonial injustice occurs when a person has access to knowledge production, but distribution of that knowledge is undermined because of prejudice or stereotypes. This occurs when certain public comments are undermined or ignored. The purpose of this paper is to understand how knowledge is constructed and leveraged to advance arguments to the use of public funds for religious, anti-abortion organizations like PRCs.
Methods: A critical discourse analysis (CDA) was used to examine public comments. A dataset of all comments responding to the TANF rule was downloaded. Researchers removed duplicates, yielding 724 unique comments. Comments relating to PRCs were flagged (n=415). Five researchers analyzed these comments using the Sort and Sift, Think and Shift approach, exploring how the language reflected power dynamics. Through rigorous memoing, team meetings, and visual diagramming of themes, researchers dove in and stepped back from the data to develop common themes.
Results: Most comments came from concerned citizens (n=286), PRC staff and administrators (n=44), PRC volunteers and advocates (n=40), and advocacy organizations (n=26). Comments from TANF recipients (n=5) were largely absent from the discourse, indicating that hermeneutical injustice may have stifled their voices. Rather than focusing on the PRC provision, TANF recipients implored ACF to strengthen structural responses to economic insecurity by including more supportive services in TANF or reducing the barriers to program access. This contrasted with the dominant narrative from concerned citizens and PRC volunteers, advocates, and administrators who justified PRC funding by describing the organization as shaping low-income individuals otherwise dependent on social systems into self-sufficient family units. In 2024, the TANF rule was withdrawn, highlighting the testimonial injustice experienced by TANF recipients whose narratives were not considered in this policy choice.
Conclusions and Implications: There is a potential avenue for democratic engagement via the federal rulemaking process. However, the few narratives from TANF recipients highlight how epistemic injustice can stifle authentic engagement when the process is not transparent to the public. A mobilized advocacy effort can shape the dominant narrative of public comments received. In 2026, H.R. 6945, the Supporting Pregnant and Parenting Women and Families Act was introduced, statutorily protecting TANF funding for PRCs. This highlights how a mobilized constituency can use this process to affect change, and the role epistemic injustice plays in shaping these narratives.