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Annual Report on State TANF and MOE Programs
- 2005
Vermont
December 22, 2005
Sidonie Squire, Director
Office of Family Assistance
Administration for Children and Families
U.S. Department of Health and Human Services
Aerospace Center Building - 5th Floor
370 L 'Enfant Promenade, S.W. Washington, D.C. 20447
Re: Annual Reports on TANF Programs and State Maintenance of Effort Programs
Dear Ms. Squire:
With this letter and on behalf of the State of Vermont, I am submitting two
documents required under TANF rules for annual reporting. One responds to the
requirements detailed in 45 C.F.R. §265.9(b). The other is Form ACF-204,
Vermont's annual report on state maintenance-of-effort programs.
If you have questions about the substantive responses in either document, please
contact
Paula Gottwik, Attorney-Policy Analyst, at 802-241-2887 or paulag@l2ath.state.vt.us.
Sincerely,
Betsy Forrest, Deputy Commissioner
Economic Services Division
Vermont Department for Children and Families
cc: Hugh Galligan, Regional Administrator
Administration for Children and Families
U.S. Department of Health and Human Services
Room 2000 - John F. Kennedy Federal Building
Government Center
Boston, MA. 02203
Attachment A
Annual Report On TANF Programs Under 45 CFR 265.9(b)
General Instructions:
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 raters). 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 approve a 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. Because the subsidies are funded from the Child
Care and Development Fund to which the state has transferred TANF funds, no
numbers are reported in this section.
(i) Licensed/regulated in-home child care
None;
(ii) Licensed/regulated family child care
None;
(iii) Licensed/regulated group home child care
None;
(iv) Licensed/regulated center-based child care
None;
(v) Legally operating (i.e., no license category available in State or locality)
in-home child care provided by a non-relative
None;
(vi) Legally operating (i.e., no license category available in State or locality)
in-home child care provided by a relative
None;
(vii) Legally operating (i.e., no license category available in State or locality)
family child care provided by a non-relative
None;
(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
None; and
(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, 20 domestic violence deferments or exemptions were approved,
and 121 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 Vermont Department
of Labor 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)(l)(A)(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 Program 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 2 individuals participated in subsidized employment per month.
Attachment B
Annual Report on State Maintenance-of-Effort Programs:
Form ACF-204
State: Vermont Fiscal
Year: 2005
Date Submitted: December 22. 2005
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: ____X____ This Program is operated under the TANF program.
___________ 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.
Total State Expenditures for the Program for the Fiscal Year: $ 76,933,837
a.) RU $37,591,736
b.) RUPN $1,038,523
c.) RUSN $15,147
d.) EA $4,883,479
e.) Child Care $13,749,300
f.) PSE $2,193,511
g.) EITC $16,462,141
All amounts include administrative and other supportive services.
7. Total State MOE Expenditures under the Program for the Fiscal Year: $ 32,988,565
a.) RU $11,741,577
b.) RUPN $1,038,523
c.) RUSN $15,147
d.) EA $2,646,694
e.) Child
Care
$7,325,109**
f.) PSE $2,193,511
g.) EITC $8,028,004
All amounts include administrative and other supportive services.
** The $7,325,1'09 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:
This last figure represents (check one):
a.) RU: 4,589
This last figure represents (check one):
__X_ The average monthly total for the fiscal year.
____ The total served over the fiscal year.
b.) RUPN: 127
This last figure represents (check one):
__X_ The average monthly total for the fiscal year.
____ The total served over the fiscal year.
c.) RUSN: 3
This last figure represents (check one):
__X_ The average monthly total for the fiscal year.
____ The total served over the fiscal year.
d.) EA: 168
This last figure represents (check one):
__X_ The average monthly total for the fiscal year.
____ The total served over the fiscal year.
e.) Child Care: 3,917
This last figure represents (check one):
__X_ The average monthly total for the fiscal year.
____ The total served over the fiscal year.
f.) PSE: 269
This last figure represents (check one):
__X_ The average monthly total for the fiscal year.
____ The total served over the fiscal year 0
g) EITC: 26,019
This last figure represents (check one):
____ The average monthly total for the fiscal year
__X_ The total served over the fiscal year 0
9. Financial Eligibility Criteria for Receiving MOE-funded Program Benefits
or Services:
a.) RU: In general, families participating in the Reach Up Program, including
separate state components, must meet the following eligibility criteria:
• Vermont residency;
• presence of a dependent child or pregnant woman;
• cooperation with child support enforcement and welfare-to-work requirements
as well as other procedural requirements such as providing verification and
appearing for eligibility interviews;
• countable resources at or below $1000; and
• countable income below payment standards calculated by (1) adding countable
housing expenses up the maximum allowance for the county of residence to the
basic needs allowance for the family size, (2) multiplying the sum by the ratable
reduction percentage, and (3) rounding the result down. The allowances in effect
during FFY 2003 were:
Housing maximum allowance
$400 outside Chittenden County
$450 inside Chittenden County
Basic Needs Allowance by Household Size
$ 475 — 1 person
$680 — 2 persons
$ 891 — 3 persons
$1064 — 4 persons
$1247 — 5 persons
$1372 — 6 persons
$1589 — 7 persons
$1769 — 8 persons
$ 170 — each add'l person
Ratable reduction percentage 49.6 %
b.) RUPN: Same as for RU. See subsection (a) above.
c.) RUSN: Same as for RU. See subsection (a) above.
d.) EA: In general, families receiving EA must meet the following criteria:
• emergency need;
• Vermont residency;
• presence of a dependent child or pregnant woman;
• cooperation with employment requirements as well as other procedural
requirements such as providing verification and appearing for eligibility interviews;
• no resources available to meet the emergency need; and
• countable income below RU payment levels (see RU, above).
e.) Child Care: Child care subsidies are available to families participating
in the RU program.
f.) PSE: Applicants shall demonstrate financial eligibility for the PSE program
by meeting the following applicable income test.
• Two-parent families: In families of four or fewer members, the family's
gross income minus the participating parent's earnings shall not exceed 150
percent of the federal poverty level for a family of four. In families of five
or more members: the family's gross income minus the participating parent's
earnings shall not exceed 150 percent of the federal poverty level for a family
of five.
• Single parent families: In families of three or fewer members, the family's
gross income shall not exceed 150 percent of the federal poverty level for a
family of three. In families of four or more members, the family's gross income
shall not exceed 150 percent of the federal poverty level for a family of four.
g.) EITC: Eligible families must have a minor child and meet the financial eligibility
criteria for the federal EITC.
10. Prior Program Authorization: Was this program authorized and allowable under
prior law? (check one)
a.) RU: Yes _X__ No ____
b.) RUPN Yes __X_ No____
c.) RUSN Yes __X__ No____
d.)EA: Yes __X__ No ____
e.) Child Care: Yes __X_ No____
f.) PSE: Yes ___X_ No _____
g.) EITC: Yes __X_ No ____
11. Total Program EITC. Expenditures in FY 1995: $8,434,138
(NOTE: provide only if response on 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: Betsy Forrest
TITLE: Deputy Commissioner
Approved OMB No. 0970-0248 Form ACF-204, expires 05/31/2006.
