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November 15, 2004

Andrew Bush
Senior Advisor to the Secretary
Office of Family Assistance
Administration for Family and Children
U.S. Department of Health and Human Services
Aerospace Building, 5th Floor
370 L’Enfant Promenade, SW
Washington, DC 20447

Dear Mr. Bush,

Enclosed is Tennessee’s Annual Report on TANF and State MOE Programs. This report was completed based on the instructions found in TANF-ACF-PI-00-6 (Revised).

The enclosed copy is the original, certified by Commissioner Virginia T. Lodge. However, to ensure that the report was filed timely, we also faxed the report on November 15, 2004.

Please do not hesitate to call if you have any questions or require further information.
Thank you.

Sincerely,

Glenda Shearon
Assistant Commissioner for Adult and Family Services

Cc: Amanda Robinson, Acting Secretary’s Representative
Carlis Williams, Southeast Hub Director ACF
Robert M. Shelbourne, Acting Director, Division of Tribal TANF Management

Appendix A

Each State must provide the following information on the TANF program (for the previous fiscal year):

(1) The State's definition of each work activity;

(1) A description of the transitional services provided to families no longer receiving assistance due to employment;

• For cases closed due to income, Employment Career Services are available for up to 12 months.
• For up to twelve months after case closure, the counseling services available through Family Services Counseling are available to the adults and children of former Families First cases. These services are not available to "child only" cases.
• For up to eighteen months after case closure, the First Wheels revolving car loan program is available to adults of former Families First cases. The car loan can be for up to a maximum of 36 months. Therefore, the benefit of this program can extend for a maximum of 54 months after case closure. Not available to Child Only cases.
• While Transitional Child Care is available to all families who leave (unless they are closed due to child support sanction, were a child only case or all members moved out of state), these services are paid for through the Child Care Development Fund.

(3) A description of how a State will reduce the amount of assistance payable to a family when an individual refuses to engage in work without good cause pursuant to 45 CFR 261.14 of this chapter.

Please refer to the "State of Tennessee Temporary Assistance for Needy Families Program State Plan" page 13 (first full bullet point, beginning “Sanctions”) to describe sanctions for non-cooperation with the Families First work requirements. In addition, to the description there, it is important to note that the first work sanction results in ineligibility from Families First until compliance. Any second or subsequent sanctions from the Families First program results in ineligibility for three months AND until compliance.

Please refer also to page 3 (Goals, Results and Public Involvement Item E) for mention of our third party review of case closures due to sanctions.

(4) The average monthly number of payments for child care services made by the State through the use of disregards, by the following types of childcare providers:

The state averages 676 cases per month using a childcare disregard to purchase child care. This represents 1.2% of our average caseload, excluding child only cases. Using a survey containing 1245 current Families First participants, we identified those who should be getting a disregard by screening for the following answers:
• Reported children in child care and;
• Reported not receiving Families First assistance with child care and;
• Reported paying some of their own money for child care

69 cases were identified, representing 5.5% of the Families First active sample. 72 child care arrangements were noted. One of those was eliminated as being ineligible for child care disregards (other parent caretaker). While the sample may not be identical to the population of those receiving child care, as it relies on self-reporting, methods used in prior years also relied on some self reporting, and depended on much smaller samples.

(i) Licensed/regulated in-home child care; Not applicable in TN

(ii) Licensed/regulated family child care; 4.2%

(iii) Licensed/regulated group home child care; 0.0%

(iv) Licensed/regulated center-based child care; 71.8%

(v) Legally operating (i.e., no license category available in State or locality)
in-home child care provided by a nonrelative; 0.0%

(vi) Legally operating (i.e., no license category available in State or locality)
in-home child care provided by a relative; 21.1%

(vii) Legally operating (i.e., no license category available in State or locality)
family child care provided by a nonrelative; 0.0%

(viii) Legally operating (i.e., no license category available in State or locality)
family child care provided by a relative; 0.0%

(ix) Legally operating (i.e., no license category available in State or locality)
group child care provided by a nonrelative; N/A in Tennessee

(x) Legally operating (i.e., no license category available in State or locality)
group child care provided by a relative; and N/A in Tennessee

(xi) Legally operated (i.e., no license category available in State or locality)
center-based child care; N/A in Tennessee


(5) If the State has adopted the Family Violence Option and wants Federal recognition of its good cause domestic violence waivers under 45 CFR 260.50-58, then provide (a) a description of the strategies and procedures in place to ensure that victims of domestic violence receive appropriate alternative services and (B) an aggregate figure for the total number of good cause domestic waivers granted;

Please refer to Optional Certification, pages 15-16 in the "State of Tennessee Temporary Assistance for Needy Families State Plan" for a description of four strategies and procedures that are in place to ensure that victims of domestic violence receive appropriate alternative services. The aggregate figure for number served through our Family Services Counseling program for domestic violence in FY04 is an average of 926 monthly. The aggregate figure for the number of good cause domestic violence exemptions in FY04 is an average of 25 monthly. This figure is lower than those actually being granted Tennessee's Family Violence Option waivers due to the design of our program that maintains strict confidentiality boundaries between the domestic violence counselor and the DHS eligibility counselor. Because of this confidentiality, the eligibility counselor is not always aware of the employment or personal barrier that is the cause for program requirements being waived.

(6) A description of any non-recurrent, short-term benefits (as defined in 45 CFR 260.31(b)(1)) provided, including:

Auxiliary payments are issued to assistance groups that are ineligible for assistance due to sanctions, time limits, or any negative closure but have been Identified as in danger of losing their shelter, utilities, custody of the child, or due to lack of food. These short-term benefits will be issued on a non-recurrent basis for a month at a time.

(i) The eligibility criteria associated with such benefits, including any restrictions on the amount, duration, or frequency of payments;

No restriction on duration. Payments can be made no more than once per month. Amounts are limited to the amount of the cash grant during the last month the family received cash benefits.

(ii) Any policies that limit such payments to families that are eligible for TANF assistance or that have the effect of delaying or suspending a family's eligibility for assistance; and

Payments are restricted to former recipients who have lost benefits due to sanctions or time limits. Recipients of auxiliary payments are encouraged to come into compliance and to reapply for benefits. No policy has the effect of delaying or suspending a family’s eligibility for assistance.

(iii) Any procedures or activities developed under the TANF program to ensure that individuals diverted from assistance receive information about, referrals to, or access to other program benefits (such as Medicaid and food stamps) that might help them make the transition from welfare to work;

Tennessee has no diversion programs or policies.

(7) A description of the grievance procedures the State has established and is maintaining to resolve displacement complaints, pursuant to section 407(f)(3) of the Social Security Act. This description must include the name of the State agency with the lead responsibility for administering this provision and explanations of how the State has notified the public about these procedures and how an individual can register a complaint;

Please refer to pages 8-9 of "The State of Tennessee Temporary Assistance for Needy Families State Plan" where our displacement procedures are described in detail, including the state agency with the lead responsibility for administering this provision.

(8) A summary of State programs and activities directed at the third and fourth statutory purposes of TANF (as specified at 45 CFR 260.20(c) and (d) of this chapter).

(a) Prevent and reduce the incidence of out-of-wedlock pregnancies and establish annual numerical goals for preventing and reducing the incidence of these pregnancies.

• Each Families First family receives a family planning brochure from the DHS case manager.

(b) Encourage the formation and maintenance of two-parent families.

• Child Support Pass-through - Families receiving cash assistance can receive child support simultaneously with their cash assistance up to their unmet need. The unmet need is calculated by determining the difference between the standard of need and the families cash assistance plus income. Child support pass-throughs are disregarded in determining eligibility and cash grant payment amounts.
• Marriage During Receipt of Assistance – Families First has expanded eligibility for two parent families who marry while on assistance. These individuals do not have the same deprivation of parental support eligibility standards that other two parent families have.
• The spouse who marries a Families First recipient will not be liable for the federal or state share of court ordered child support arrearages which are owed to a child or children in the assistance group so long as the spouse resides in the home.

(9) An estimate of the total number of individuals who have participated in subsidized employment under §261.30(b) or (c) of this chapter.

Tennessee does not offer subsidized employment in TANF.

Attachment B

Annual Report on State Maintenance-of-Effort Programs: ACF-204

State Tennessee_ Fiscal Year _2004_
Date Submitted November 15, 2004_

Provide the following information for EACH PROGRAM (according to the nature of the benefit or service provided) for which the State claims MOE expenditures. Complete and submit this report in accordance with the standardized instructions.

1. Name of Benefit or Service Program:

Families First

2. Description of the Major Program Benefits, Services, and Activities:

The Families First Program is funded with both co-mingled TANF funds and Separate State Program MOE funds. The only difference between the programs is the funding source. The summary for the SSP-MOE Families First Program will follow. This program provides:
• Case management
• Eligibility Services
• Education
• Job Skills Training
• Employment Career Services (including Career Assessment)
• Counseling for Domestic Violence, Substance Abuse, Mental Health, Child Behavioral Issues and Learning Disabilities
• Transportation
• Support services (e.g. car repairs, uniforms, tools, optical and dental not covered by Medicaid)
• Administrative costs associated with offering the above services
• Related information systems costs associated with the above services
• Evaluation of program process and outcomes
• Work Prep (life skills, basic work place skills)

3. Purpose(s) of Benefit or Service Program:

To move families from welfare to self-sufficiency in the shortest time possible by encouraging work and providing the education, training and support service needed for the family to gain and retain employment.

Please see page 6 "Goals for work and self-sufficiency" in the "State of Tennessee Temporary Assistance for Needy Families State Plan".


4. Program Type. (Check one)

__X__ This Program is operated under the TANF program.
______ This Program is a separate State program.

5. Description of Work Activities (Complete only if this program is a separate State program):

6. Total State Expenditures for the Program for the Fiscal Year:
______$52,661,855.80 _____

7. Total State Expenditures Claimed as MOE under the Program for the Fiscal Year:
______$52,661,855.80 _____

8. Total Number of Families Served under the Program with MOE Funds:
____72069_________
This last figure represents (check one):
____X____ The average monthly total for the fiscal year.
________ The total served over the fiscal year.

9. Financial eligibility Criteria for Receiving MOE-funded Program Benefits or Services:

Please refer to the "State of Tennessee Temporary Assistance for Needy Families" State Plan" page 13 (first full bullet point, beginning “Sanctions”).

10. Prior Program Authorization: Was this program authorized and allowable under prior law (i.e., as defined at §260.30)? (check one)
Yes __X__    No_____

11. Total Program Expenditures in FY 1995. _________________________
(NOTE: provide only if the response on to question 10 is No.)

This certifies that all families for which the State claims MOE expenditures for the fiscal year meet the State's criteria for "eligible families."

SIGNATURE: ___________________________________
NAME: ___Virginia T. Lodge______________________
TITLE: ___Commissioner__________________________
Approved OMB No. 0970-0199 Form ACF-204, expires 6/30/2002.

3. Purpose(s) of Benefit or Service Program:

To move families from welfare to self-sufficiency in the shortest time possible by encouraging work and providing the education, training and support services needed for the family to gain and retain employment.

Please see page 6 "Goals for work and self-sufficiency" in the "State of Tennessee Temporary Assistance for Needy Families State Plan".

4. Program Type. (Check one)

______ This Program is operated under the TANF program.
__X___ This Program is a separate State program.

5. Description of Work Activities in the SSP-MOE program (I.e., Complete only if this program is a separate State program):

6. Total State Expenditures for the Program for the Fiscal Year:
$4,652,644.84

7. Total State Expenditures Claimed as MOE under the Program for the Fiscal Year:
$4,652,644.84

8. Total Number of Families Served under the Program with MOE Funds: 1394

This last figure represents (check one):
____X___ The average monthly total for the fiscal year.
________ The total served over the fiscal year.

9. Eligibility Criteria for Receiving MOE-funded Benefits or Services under the Program:

Please refer to the "State of Tennessee Temporary Assistance for Needy Families" State Plan" page 13 (first full bullet point, beginning “Sanctions”). In addition, an amendment has been added to include the families of ineligible drug felons. Associated service cost and grants for ineligible drug felon families are served under state funds.

10. Prior Program Authorization: Was this program authorized and allowable under prior law (i.e., as defined at §260.30)? (check one)
Yes _X_    No ___

(population was allowed to be served through our section 1115 waiver)

11. Total Program Expenditures in FY 1995. _________________________
(NOTE: provide only if the response on to question 10 is No.)

This certifies that all families for which the State claims MOE expenditures for the fiscal year meet the State's criteria for "eligible families."

SIGNATURE: ___________________________________
NAME: ___Virginia T. Lodge______________________
TITLE: ___Commissioner__________________________
Approved OMB No. 0970-0199 Form ACF-204, expires 6/30/2002

Provide the following information for EACH PROGRAM for which the State claims MOE expenditures.

1. Name of Benefit or Service Program:

Child Support Pass-through

2. Description of the Major Program Benefits, Services, and Activities:

Families for whom child support is collected in a month in which they receive assistance can receive child support pass-throughs up to the amount of their unmet need.

3. Purpose(s) of Benefit or Service Program:

To provide additional financial resources for families on assistance to assist in their transition to self-sufficiency.

4. Program Type. (Check one)

______ This Program is operated under the TANF program.
__X __ This Program is a separate State program.

5. Description of Work Activities in the SSP-MOE program (I.e., Complete only if this program is a separate State program):
N/A

6. Total State Expenditures for the Program for the Fiscal Year:
_____$12,040,253.92 ____________

7. Total State Expenditures Claimed as MOE under the Program for the Fiscal Year:
_____$12,040,253.92____________

8. Total Number of Families Served under the Program with MOE Funds:
__24898________
This last figure represents (check one):
____ X ____ The average monthly total for the fiscal year.
___________ The total served over the fiscal year.

9. Eligibility Criteria for Receiving MOE-funded Benefits or Services under the Program:

Families receiving cash assistance in a month may receive a child support pass-through if:
• Child support was collected for one of the eligible children for the month of assistance
• The family had an unmet need (the difference between the standard of need and the sum of the cash grant and the net income of the family)

10. Prior Program Authorization: Was this program authorized and allowable under prior law (i.e., as defined at §260.30)? (check one)
Yes _X_    No ___

11. Total Program Expenditures in FY 1995. _________________________
(NOTE: provide only if the response on to question 10 is No.)

This certifies that all families for which the State claims MOE expenditures for the fiscal year meet the State's criteria for "eligible families."

SIGNATURE: ___________________________________
NAME: ___Virginia T. Lodge______________________
TITLE: ___Commissioner__________________________
Approved OMB No. 0970-0199 Form ACF-204, expires 6/30/2002.

Provide the following information for EACH PROGRAM for which the State claims MOE expenditures.

1. Name of Benefit or Service Program:

Child Care Development Fund

2. Description of the Major Program Benefits, Services, and Activities:

Provision of child care subsidies to low-income families receiving Families First or Transitional Child Care.

3. Purpose(s) of Benefit or Service Program:

To provide funds to access federal child care dollars to maximize Tennessee's ability to provide child care to low-income families.

4. Program Type. (Check one)

______ This Program is operated under the TANF program.
__X __ This Program is a separate State program.

5. Description of Work Activities in the SSP-MOE program (I.e., Complete only if this program is a separate State program):

Child care is provided to families who are in work components as a part of their Personal Responsibility Plan and/or are employed.

6. Total State Expenditures for the Program for the Fiscal Year:
_____$18,975,782.00 ________

7. Total State Expenditures Claimed as MOE under the Program for the Fiscal Year:
______$18,975,782.00_____

8. Total Number of Families Served under the Program with MOE Funds: _____39,966___________
This last figure represents (check one):
________ The average monthly total for the fiscal year.
____X___ The total served over the fiscal year.

9. Eligibility Criteria for Receiving MOE-funded Benefits or Services under the Program:

Families must either be in a Families First work activity or must be transitioning off of assistance and be employed, and/or be in activities for at least 20 hours per week. In addition, the family must be income eligible for either Families First or Transitional Child Care. Transitional Child Care income eligibility is based on 60% of the State’s Median Income.

10. Prior Program Authorization: Was this program authorized and allowable under prior law (i.e., as defined at §260.30)? (check one)
Yes _X_    No ___

11. Total Program Expenditures in FY 1995. _________________________
(NOTE: provide only if the response on to question 10 is No.)

This certifies that all families for which the State claims MOE expenditures for the fiscal year meet the State's criteria for "eligible families."

SIGNATURE: ___________________________________
NAME: ___Virginia T. Lodge______________________
TITLE: ___Commissioner__________________________
Approved OMB No. 0970-0199 Form ACF-204, expires 6/30/2002.

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