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Critics Hit Proposed Welfare Rules. SOCIAL ASSISTANCE

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LITTLE has been said publicly about welfare reform in the nearly seven months since former President Reagan signed into law the beginnings of a fundamental redirection in America's welfare policy. But beneath the surface much has been going on. Welfare reform is now just beginning to be publicly discussed again, with hearings this week on the way in which the new law is being put into effect.

Over the past seven months officials of the Department of Health and Human Services, which oversees implementation of the new law, have been drawing up regulations the states must meet in order to receive federal funds. The HHS has published the regulations it proposes, and interested organizations may now comment on them. HHS will consider all views before making them final.

This week Sen. Daniel Patrick Moynihan (D) of New York, principal architect of the new law, held a hearing at which representatives of organizations that work with the poor assessed the proposed regulations. What most said publicly was that several flaws exist; the most serious charge was that several elements of the regulations are so stringent that they would limit state flexibility, and in some cases prove counterproductive.

Some, however, who are sharply critical in public, also say in private that the regulations are, on balance, quite good.

Until October the keystone program of the American welfare system had emphasized helping poor children by providing money to them and their mothers.

The thrust of the new law is to redirect the welfare system to emphasize making able-bodied adults financially self-sufficient. The law ``embodies a new consensus that the well-being of children depends not only on meeting their material needs, but also on the parent's ability to become self-sufficient,'' says Constance Horner, undersecretary of the Department of Health and Human Services.

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