State TANF and MOE Annual Reports

Administration for Children and Families

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Annual Report on State TANF and MOE Programs - 2004
Vermont

Attachment A

Annual Report On TANF Programs Under 45 CFR 265.9(b)

Each State must provide the information indicated below on its TANF program regardless of the funding source -- i.e., no matter whether the State used segregated Federal TANF funds, segregated State TANF funds, or commingled funds to pay for the benefit or service.

If the State elects to report on other benefits or activities provided through other program funding streams, please mention it after the TANF-funded benefits or activities for each item.

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

45 CFR 261.30 encompasses the 12 categories of work activities listed in Section 407(d) of the Social Security Act for purposes of determining the State's required minimum work participation rate(s). Each State defines the activities that fall under each of these 12 categories and provides them to us. This item is for that purpose. Therefore, your definitions should include the kinds of work activities that apply to each of the 12 categories. For example, what activities comprise "job skills training directly related to employment" in your State?

(1) Unsubsidized employment means a job for which less than 25 percent of its wages or earnings are subsidized by Reach Up (Vermont’s TANF program) funds. Unsubsidized employment may include self-employment.

(2) Subsidized private sector employment means a job in the private sector for which at least 25 percent of its wages or earnings are subsidized by Reach Up (Vermont’s TANF program) funds.

(3) Subsidized public sector employment means a job in the public sector in which at least 25 percent of its wages or earnings subsidized by Reach Up (Vermont’s TANF program) funds. Placements are limited in duration to no more than six months.

(4) Work experience (including work associated with the refurbishing of publicly assisted housing if sufficient private sector employment is not available) means a placement, limited to no more than six months in duration that is located at public, private, or nonprofit site with local supervision.

(5) On-the-job training means training that develops and enhances skills directly related to the participant’s attainment of, retention of, or advancement in an unsubsidized job available in the local employment market and provides an opportunity to acquire knowledge and abilities in a specific occupational area.

(6) Job search and job readiness assistance means an activity that includes seeking unsubsidized employment; job clubs participation; resume and application preparation; job interviews; work-search and work-search training; and housing search, if the participant is homeless. This activity is limited in duration to no more than six weeks during a federal fiscal year, and only four of the six weeks may be consecutive.

(7) Community service programs means structured service placements that may be located at public, private, or nonprofit sites with local supervision when unsubsidized or subsidized work is not available due to local economic conditions. The placement may also provide training and experience designed to enhance the participant’s skills and is an activity that benefits the community. The need for continuation of the placement is reviewed every three months.

(8) Vocational educational training (not to exceed 12 months with respect to any individual) means training designed to provide the participant with skills or certification in an area of study necessary for the participant to obtain a job available in a geographic area where the participant is willing to relocate within three months of completion of the vocational program. Examples of vocational education include licensed practical nurse training and auto mechanic training.

(9) Job skills training directly related to employment means training that develops and enhances skills directly related to the participant’s attainment of, retention of, or advancement in an unsubsidized job available in the local employment market and provides an opportunity to acquire knowledge and abilities in a specific occupational area. Examples include classes and programs in computer keyboarding and data entry, training to obtain a commercial driving license, and training to become a personal care attendant or licensed nurse’s aid.

(10) Education directly related to employment, in the case of a participant who has not received a high school diploma or a certificate of high school equivalency, means basic and remedial education that will provide an individual with basic literacy equivalent to at least grade 8.9, education in English proficiency when an individual is unable to understand, speak, read, or write the English language at a level necessary to obtain employment consistent with the participant's employment goal, and participation in a work experience placement with a basic education program component designed to provide a high school diploma or certification of high school equivalency.

(11) Satisfactory attendance at secondary school or in a course of study leading to a certificate of general equivalence, in the case of a recipient who has not completed secondary school or received such a certificate, means participation at the level described in the participant’s family development plan in an educational program designed to prepare a person to qualify for a high school diploma or its equivalent; and a secondary school program.

(12) The provision of child care services to an individual who is participating in a community service program means the provision of child care services, consistent with the participant’s approved self-employment plan, to an individual who is participating in a community service program.

(2) A description of the transitional services provided to families no longer receiving assistance due to employment. Indicate the kinds of help provided to working families that received, but no longer receive, "assistance" as defined in 45 CFR 260.31.

Eligible families who are no longer receiving financial assistance from the Reach Up Program (Vermont’s TANF program) due to employment are provided with the following transitional services:
• Transitional Medicaid benefits are continued for 36 months.
• Child care subsidies are continued on a sliding fee scale basis.
• Reach Up participants who obtain unsubsidized employment are eligible to receive job retention and enhancement services. Participants who are no longer eligible for Reach Up financial assistance continue to be eligible for these services for up to six consecutive months following grant closure due to wages from employment. The services provided may include coaching and encouragement, referrals to community resources, education and training, and the range of support services provided to Reach Up participants who are meeting their work requirement through unsubsidized employment during their employment phase.

(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.

When a Reach Up participant refuses to engage in work without good cause, the participant’s family grant is reduced by $75 per month for each of the first three months of non-compliance. If the participant continues to refuse to engage in work for more than three months, the family’s grant is reduced by $150 per month. In the event that a participant has been sanctioned 12 months and has received 60 or more cumulative months of assistance, the family’s grant is reduced by $225 per month.

All reductions in the family grant for a participant’s failure to engage in work are per participant. When two parents in a family both have work requirements and refuse to engage in work, the family’s grant is reduced for each parent’s act of noncompliance. Participants who are subject to financial sanctions must meet with their case manager at least once a month. A parent’s failure, without good cause, to keep an appointment with the case manager when the family grant is being reduced due to a refusal to engage in work may result in termination of financial assistance to the family.

(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 child care providers:

Vermont pays for child care services through direct payments to providers, not through the use of disregards. The following numbers represent the average number of payments per month during FFY 2003.

(i) Licensed/regulated in home child care
None;

(ii) Licensed/regulated family child care
431 children 303 families;

(iii) Licensed/regulated group home child care
None;

(iv) Licensed/regulated center based child care
456 children 340 families;

(v) Legally operating (i.e., no license category available in State or locality)
in home child care provided by a non-relative
52 children 26 families;

(vi) Legally operating (i.e., no license category available in State or locality)
in home child care provided by a relative
13 children 7 families;

(vii) Legally operating (i.e., no license category available in State or locality)
family child care provided by a non-relative
138 children 87 families;

(viii) Legally operating (i.e., no license category available in State or locality)
family child care provided by a relative
None;

(ix) Legally operating (i.e., no license category available in State or locality)
group child care provided by a non-relative
None;

(x) Legally operating (i.e., no license category available in State or locality)
group child care provided by a relative; and
None;

(xi) Legally operated (i.e., no license category available in State or locality)
center based child care
None.

(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.

Vermont has adopted the Family Violence Option. Program rules include the following requirements:

• At the time of a participant’s application for and redetermination of eligibility for the Reach Up Program, field staff must explain to the participant that he or she may request a deferment from the work requirement and a waiver from the requirement to cooperate with child support enforcement if the family is suffering the effects of domestic violence. Applicants and participants are also provided with general information about domestic violence and a toll-free domestic violence hot-line number.

• Upon request, field staff can provide a referral to a local domestic violence program and help an individual apply for the waiver or deferment, or both.

• Case managers working with a Reach Up Program family who is experiencing the effects of domestic violence must incorporate activities that address the family’s domestic violence situation into the family development plan.

All members of the Reach Up Program’s field staff receive training designed to help them to recognize the signs of domestic violence and work with victims of domestic violence.

During FFY 2004, 7 domestic violence deferments or exemptions were approved, and 227 waivers of the child support requirements were also approved.

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

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

(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

(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.

Nonrecurring support services related to training and employment are available to financial assistance recipients participating in the services component of Vermont’s TANF program. These support services include payments for transportation and tools, clothing, and other items required for training or employment. A family remains eligible for payment of support services up to 6 months after their financial assistance terminates due to employment. Vermont does not make diversion payments.

(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.

Vermont’s work site agreements require the work site to comply with the Department for Children and Families Economic Services Division’s (ESD) rules on the work place displacement policy. The rules state that no adult in a Reach Up Program work activity that is funded, in whole or in part, by funds provided by the federal government shall be employed or assigned when:

• any other individual at the same work site is on layoff from the same or any substantially equivalent job;

• the employer has terminated the employment or reduced the regularly scheduled hours of any regular full-time employee or otherwise caused an involuntary reduction of its work force capacity to fill the vacancy so created with a participant of the Reach Up Program; or

• the employment or placement is the result of a strike, lockout, or other bona fide labor dispute.

If there is a bargaining unit at the work site, ESD or its agent shall obtain the bargaining unit’s certification that the participant’s employment or placement will not result in any violation of the bargaining unit agreement.

ESD shall maintain a grievance procedure for resolving complaints of alleged violations of the department’s displacement policy. This procedure will involve the opportunity for informal resolution conducted by the Reach Up Welfare-to-Work Director or the director's designee. If no informal resolution can be reached within 30 days, the complainant may file a request for a hearing with the state.

The state's grievance procedure shall involve a hearing before a Department of Employment and Training Appeals Referee. The state shall provide the complainant with a written decision within 90 days from the date of the filing of the complaint. A dissatisfied party may appeal a decision by the state within 20 days of receipt of the state's written decision.

This displacement policy has been formally incorporated into ESD’s rules manual through the administrative rules process set forth in Vermont statute. This process provided for formal publication of the proposed rule and an opportunity for public comment.

(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. Summarize below, the State programs and activities directed at preventing and reducing the incidence of out-of-wedlock pregnancies and establishing annual numerical goals for preventing and reducing the incidence of these pregnancies (TANF purpose 3):

Sec. 260.20 (c): Vermont’s efforts at reducing out-of-wedlock pregnancies are described in the TANF State Plan at (a)(1)(v).

b. Summarize below, the State programs and activities directed at encouraging the formation and maintenance of two-parent families (TANF purpose 4):

Sec. 260.20 (d): On July 1, 1994, Vermont initiated the Welfare Restructuring Project (WRP), a section 1115 waiver demonstration project. One of the most significant provisions of WRP was the elimination of the “100-hour rule.” As a result of this rule, families with two able-bodied parents were ineligible for benefits when the breadwinner worked 100 or more hours in a month. On July 1, 2001, when Vermont replaced WRP with Reach Up, its TANF program, the Vermont General Assembly decided to maintain the elimination of the 100-hour rule. The elimination of this rule has allowed Vermont to continue to provide financial assistance to intact families until their income exceeds the TANF program’s payment standard.

Vermont believes that the Reach Up Program’s increased focus on work and the reciprocal responsibilities of parents and government, supported by strong case management, work together to strengthen families and help them deal with the stressors that can break them apart.

In addition, the Reach Up accommodates two-parent families’ need for flexibility in fulfillment of parental and work obligations. This is accomplished by allowing the parents to choose to share work requirements and determine who will meet the hours of the family’s work requirement. By leaving these decisions up to the families, Reach Up supports the family members’ ability to structure their lives in a way that strengthens the family unit.

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

Approximately 1 individual participated in subsidized employment per month.

Attachment B

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

State: Vermont Fiscal Year: 2004

Date Submitted: December 29, 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 attached instructions.

1. Name of Benefit or Service Program

a.) Reach Up (RU)
b.) Reach Up Parental Nurturing Component (RUPN)
c.) Reach Up Minor Parents Safety Net Component (RUSN)
d.) Emergency Assistance (EA)
e.) Child Care
f.) Postsecondary Education Program (PSE)
g.) Earned Income Tax Credit (EITC)

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

a.) Reach Up: Vermont’s TANF program, Reach Up, provides transitional assistance and support services to needy families with (or expecting) children. Adults in participating families who are receiving financial assistance must participate in a services component of the program. Adult participants who can work are required to engage in work or work activities. Using a case management model, the department provides eligible families with support services and opportunities designed to address the families’ needs that are related to gaining and maintaining unsubsidized employment and moving the family toward self-sufficiency.

b.) RUPN: This is a separate state component of Reach Up. This component is open to a single parent, a caretaker, or a parent in a two-parent family with one able-to-work-part-time or unable-to-work parent. This program provides a time-limited deferment from the Reach Up work requirement. This component is designed to foster parental nurturing of children under age two in their own homes and is limited to no more than 24 months over the primary caretaker’s lifetime. Other than the qualifying criteria for this program, this component operates under the Reach Up eligibility and participation rules.

c.) RUSN: This is a separate state component of Reach Up designed to preserve eligibility for financial assistance for minor parents who are not in compliance with federal supervised living and school attendance requirements. These minor parents who are not complying with the federal supervised living and school attendance requirements receive financial sanctions in the form of a reduced grant instead of being terminated from assistance. The minor parent must meet regularly with the case manager who continues to work with the parent to bring them into compliance with the program requirements. Other than the qualifying criteria for this program, this component operates under the same rules for participation and eligibility as Reach Up.

d.) EA: The Emergency Assistance Program provides financial assistance to meet short-term or nonrecurring needs experienced by families in emergency situations.

e.) Child Care: Vermont provides subsidies that cover part or all of child care expenses for children under the age of 13 to help families achieve or maintain economic self-sufficiency.

f.) PSE: The Postsecondary Education Program is a separate state program designed to provide living expense stipends and support services to enable parents in eligible families to pursue undergraduate postsecondary degrees in fields directly related to employment.

g.) EITC: The Earned Income Tax Credit provides working families with minor children tax credits that are refunded to the families in excess of any refunded overpayment of tax liability. The income eligibility is the same as for the federal EITC. This is an MOE program, limited to the amount of spending that meets with the "new spending" provision under section 409(a)(7)(B)(II)(aa) of the Act.

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

a.) RU: To provide financial assistance to needy families and help families move toward self-sufficiency. 45 C.F.R. § 260.20(a)-(b).

b.) RUPN: To provide financial assistance to needy families and help families move toward self-sufficiency. 45 C.F.R. § 260.20(a)-(b).

c.) RUSN: To provide financial assistance to needy families and help families move toward self-sufficiency. 45 C.F.R. § 260.20(a)-(b).

d.) EA: To provide financial assistance to meet short-term or nonrecurring needs experienced by families in emergency situations. 45 C.F.R. § 260.2 (a).

e.) Child Care: To help families pay for child care they need to achieve or maintain economic self-sufficiency. 45 C.F.R. § 260.20 (b).

f.) PSE: To provide case management and financial support to low-income families so parents have the ability to pursue postsecondary degrees in fields that lead to employment and economic self-sufficiency. 45 C.F.R. § 260.20(a)-(b).

g.) EITC: To provide low-income working families access to more of their earned income. 45 C.F.R. § 260.20(a)-(b).

4. Program Type. (Check one)

a) RU:

_X_ This Program is operated under the TANF program.
____ This Program is a separate State program.

b.) RUPN:

____ This Program is operated under the TANF program.

___X_ This Program is a separate State program

c.) RUSN:

____ This Program is operated under the TANF program.

__X_ This Program is a separate State program.

d.) EA:

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

e.) Child Care:

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

f.) PSE:

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

g.) EITC

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

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

RUPN: This is a separate state component of Reach Up. This program provides a deferment from the Reach Up work requirement. Families in this program whose youngest child is older than 6 months must participate in family development activities. These activities may include Reach Up work activities. Other than the qualifying criteria for this program and the modification of the work requirement, this component operates under the same rules for participation and eligibility as Reach Up.

RUSN: This is a separate state component of Reach Up designed to preserve eligibility for financial assistance for minor parents who are not in compliance with federal supervised living and school attendance requirements. Other than the qualifying criteria for this program, this component operates under the same rules for participation and eligibility as Reach Up.

PSE: This program is a separate state program and does not provide TANF assistance to its participants. While the program does not have work activities, able-bodied spouses of participants must engage in full-time employment. Participants in the program must be full-time matriculating students in a two- or four-year postsecondary undergraduate degree program and must remain in good academic standing.

EITC: This program does not have work activities, but only working families with earned income are eligible for this tax credit.

6. Total State Expenditures for the Program for the Fiscal Year: $ 76,957,932

a.) RU — $44,679,451
b.) RUPN — $927,998
c.) RUSN — $4,972
d.) EA —— $3,655,721
e.) Child Care — $9,199,551
f.) PSE — $2,594,695
g.) EITC — $15,895,544

All amounts include administrative and other supportive services.

7. Total State MOE Expenditures under the Program for the Fiscal Year:
$ 33,290,995

a.) RU — $15,425,020
b.) RUPN — $927,998
c.) RUSN — $4,972
d.) EA — $1,824,882
e.) Child Care — $5,052,022**
f.) PSE — $2,594,695
g.) EITC — $7,461,406

All amounts include administrative and other supportive services.

** The $5,052,022 amount of MOE expenditures in child care includes $2,666,327 that was used to meet the State’s CCDF Matching Fund requirement.

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

a.) RU: 4,831