Updated

TITLE: "Right Choice.

LENGTH: 60 seconds.

AIRING: Mitt Romney's campaign did not disclose where the ad is running.

KEY IMAGES: Opens with President Bill Clinton signing legislation that overhauled the nation's welfare program by requiring recipients to meet certain work requirements to continue getting cash assistance. It then cuts to an image of President Barack Obama. A narrator says, "Obama quietly announced a plan to gut welfare reform by dropping work requirements."

Next, it shows images of people at work and says that "under Obama's plan, you wouldn't have to work and wouldn't have to train for a job. They just send you your welfare check."

The ad then moves to a picture of Mitt Romney visiting work sites and tells viewers, "Mitt Romney will restore the work requirement because it works."

ANALYSIS: The ad released by Romney's campaign paints Obama as attempting to gut the work requirements that have played such a critical factor trimming the welfare rolls. It echoes conservatives' worst fears that a July 12 letter from the Obama administration to the states amounts to an end-run around the program's work requirements.

But that letter does not unilaterally repeal or waive the law. Instead, it gives states the chance to make changes to their welfare programs and still be counted as meeting work participation requirements. It's a leap to assume that governors and legislators will seek to return to "plain old welfare" and that the Obama administration will give them the go-ahead.

And, in 2005, Romney joined several other GOP governors in promoting "increased waiver authority."

Under the Temporary Assistance for Needy Families program, states must engage at least half of their TANF families in work for a minimum number of hours each month. States can lose federal funding if they don't. The states have some discretion to determine who must work and what activities count as work.

The Obama administration said in the letter that it would consider granting waivers from work participation requirements for an array of projects, but that it would not approve any waiver likely to reduce access to employment.

Some in the GOP are making the case that tinkering with the law's work requirements through the waiver process amounts to an unraveling of welfare reform. Obama officials say that's not their intent at all. And the administration said it would only approve those waivers that would move more people from welfare to work.

The ad also ignores that governors from both parties have called for more flexibility in determining what constitutes allowable work activities under the law. For example, in August 2011, the state of Utah called for waivers that expanded the definition of countable work activities.

"It is the narrow definitions of what counts and the burdensome documentation and verification processes that are not helpful," the Utah letter said.

Romney was among eight GOP governors who weighed into the TANF reauthorization debate with a letter in 2005 that said "increased waiver authority" and other features of a Senate bill were "important aspects of moving recipients from welfare to work." He was governor of Massachusetts at the time.