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Appendix B

Profiles of the States Discussed in Chapter 4

This appendix includes brief descriptions of the implementation of time limits in eight states where a significant number of families have reached limits. The state profiles are based on field research conducted for this project as well as research previously conducted as part of other MDRC projects.

Five states Georgia, Louisiana, Massachusetts, New York, and South Carolina were visited between December 2001 and February 2002 as part of this project. For the most part, the welfare offices selected for field research were in or near the largest urban areas in the state. The research was conducted over two days with a team of researchers meeting with supervisors and line staff in one office each day. In addition, meetings or conference calls with state administrators were conducted prior to the welfare office visits. Finally, in some states, interviews were also conducted with local advocates for welfare recipients to gain their perspective on welfare reform.

Staff were asked about the state’s time-limit policies, including, for example, the duration of time limits, exemption and extension criteria, formal and informal processes for dealing with cases as they approach the time limit, and services for cases that reach a time limit. Staff were also asked what message they try to communicate to clients about time limits and how time-limit policies interact with state or county work activity requirements. Finally, staff were also asked to elaborate on the implementation and operational challenges of time limits.

It is important to note that only two welfare offices were visited in each state. For this reason, the following profiles are representative of the entire state only to the extent that the policies have been implemented uniformly. In some states, differences were observed at the county and/or local office levels. For the most part, these are noted within the profiles. However, it is impossible to know how policies might vary in other parts of the state where staff were not interviewed. The specific cities and counties that were visited are listed below.

• In Georgia, interviews were conducted at two offices in Fulton County (At-lanta). The South Central Service Center near downtown Atlanta serves the most disadvantaged caseload in the county, and the clientele includes residents of several public housing developments. The South Fulton Service Center — located in College Park, on the outskirts of Atlanta — is the least densely populated office in the county.

• In Louisiana, the research was conducted at two parish (county) offices located within the City of New Orleans. Gentilly is located slightly outside the city center and serves a predominately working-poor population. The Uptown office is located on the edge of the city’s central business district and serves a number of long-term welfare recipients and hard-to-serve clients.

• Advocates from two prominent Louisiana welfare organizations — the Agenda for Children and the Welfare Rights Organization — were also interviewed.

• In Massachusetts, visits were conducted to two offices in the Boston suburbs: Malden and Revere. The Revere office serves a population that includes a number of immigrants and refugees. In addition, representatives from Greater Boston Legal Services and the Massachusetts Law Reform Institute were interviewed.

• In New York, the research was conducted entirely in New York City. One neighborhood welfare center (Job Center) in Brooklyn was visited. In addition, discussions were held with staff at the city’s main fraud verification unit (also in Brooklyn), where all noncompliant individuals are being called in as they approach the time limit.

• The South Carolina sites included one rural office and one office in Charles-ton. Orangeburg County, located between Columbia and Charleston, is rural and has a relatively high employment rate and very little industry. Charleston County serves the city of Charleston.

In addition to the limitations posed by the small number of offices visited within each state, there is another important limitation to address: Even though time-limit policies were specified in welfare reform legislation, many of the specifics evolved over time. For example, in some counties where staff do not now routinely close cases because of the time limit, many cases were closed when families first began to reach time limits. The profiles refer, at times, to specific policy changes — for example, the impact of a new state or county director (South Carolina) or policy decisions made in anticipation of large numbers of clients reaching a time limit concurrently (New York).

Two of the profiles — Florida and Ohio — are based on research conducted as part of MDRC’s Project on Devolution and Urban Change. In Florida, five rounds of field research in Miami-Dade County welfare offices were conducted between 1997 and 2001 to understand how TANF policies, including time limits, were being implemented. Central-office administrators were interviewed, and interviews and observations were conducted in “branch” offices in three neighborhoods (all urban). In Ohio, six rounds of field research were conducted between 1997 and 2001 in Cuyahoga County. As in Miami-Dade, interviews were conducted with central-office administrators, and interviews and observations were conducted in three “branch” offices (all urban). In addition, in both counties, program documentation was collected (including, for example, policy guidelines and administrative reports), and welfare staff were surveyed about their knowledge and practices.

Finally, the Connecticut profile is based on field research conducted as part of MDRC’s evaluation of Jobs First — the state’s welfare reform program. The profile is based on interviews with managers and line staff as well as surveys of welfare recipients in the New Haven and Manchester welfare offices. Similarly, the Florida Family Transition Program (FTP) profile is based on MDRC’s random assignment evaluation of FTP, a pilot project that operated in Es-cambia County (Pensacola) from 1994 to 1999.

Connecticut

Background

Connecticut’s time limit took effect statewide in January 1996, when the state implemented the Jobs First welfare reform initiative under federal waivers. The information presented in this report comes from MDRC’s large-scale evaluation of Jobs First, which targeted the Manchester and New Haven welfare offices.

• Time-limit policy. Nonexempt recipients are limited to 21 months of benefit receipt unless they receive an extension. After the MDRC study ended, the state added additional criteria to qualify for more than three extensions and also added a new, 60-month time limit that allows few exceptions.

• TANF grant level and earned income disregard policies. The maximum TANF grant for a family of three is $543. All earned income is disregarded as long as earnings are below the federal poverty level.

• Work requirements and sanctions. Nonexempt recipients are required to participate in work activities focused on rapid employment. The welfare grant is reduced by 25 percent for three months for the first instance of non-compliance, 35 percent for three months for the second instance, and 100 percent for three months for the third instance. The penalties become stricter once a recipient receives a benefit extension after reaching the time limit: A single instance of noncompliance can result in permanent termination of benefits.

Communicating the Message

When Jobs First was implemented, there was a large increase in the number of welfare recipients who were expected to move toward self-sufficiency but no corresponding increase in the Department of Social Services (DSS) staffing. As a result, the program was designed in a way that limited the need for frequent in-person contact between recipients and staff. Thus, while the time-limit policy was communicated to recipients when they enrolled, there were relatively few opportunities to reinforce the message during the first 21 months of benefit receipt.

Surveys of recipients and staff found that workers did not actively encourage most recipients to leave welfare quickly in order to bank their months of eligibility. In fact, such a message would not have been credible, given the structure of the earnings disregard. Individuals who found employment would usually continue to receive their full welfare grant (if earnings exceeded the poverty level, they would receive no grant). Thus, in order to bank months, a recipient would need to give up $543 per month in benefits.

Staff surveys also found that workers used different strategies in discussing the extension policy. Under program rules, recipients are granted benefit extensions if they make a good-faith effort to find work but have income below the welfare payment standard when they reach the time limit. This general policy was known from the beginning, but the specifics were not developed until shortly before the first recipients reached the time limit. Before that point, some staff (typically those in the New Haven office) told recipients that people who cooperated with the rules would receive extensions if necessary — and thus stressed the importance of following program rules. Other workers were more vague, warning clients that it was not certain who would receive extensions and that all recipients should thus try hard to find jobs (this approach was more common in Manchester).

One challenging issue that has emerged recently is that each recipient now has three separate time-limit counters: a state 21-month counter, a state 60-month counter, and a federal 60-month counter. This issue arises because the federal time-limit clock runs during months when recipients are exempt from the state time limits. Also, the state 60-month limit counts benefits received since October 1996, while the 21-month counter began in January 1996. Recipients receive notices informing them about their status vis-à-vis all three time limits, even though the federal counter has no specific implications for them unless they move to another state.

Determining Who Is Exempt

In general, families in Connecticut are exempt from the time limit if all adults are exempt from mandatory participation in work activities. The proportion of the state TANF caseload who are exempt from the time limit has grown over time as the caseload has declined. About one-fourth of the caseload were exempt in 1998, compared with more than half today. The most common exemptions are for child-only cases and for recipients with a child under age 1. The next-most-common reason is for incapacitation, although the criteria for such an exemption are narrow and all long-term extensions for incapacitation must be approved by a centralized medical review team. MDRC’s evaluation found that exemptions are typically granted either when a recipient first becomes subject to Jobs First or, much more rarely, as he or she approaches the time limit.

Working with Cases Approaching the Time Limit

Cases approaching the time limit in Connecticut are targeted for attention by caseworkers. For example, during the study period, lists of cases whose counters were at month 16 were distributed to workers, with instructions to ensure that these recipients are engaged in work activities. In the New Haven office during this study, recipients who reached month 16 and were not working were offered assistance from social work staff.

In month 20 of assistance, recipients are called in for an exit interview conducted by their DSS caseworker. Recipients who fail to show up for the interview cannot receive an extension. At the interview, the caseworker first reviews the exemption criteria to ensure that none apply. Next, the household income is considered. Recipients with income above the welfare payment standard are not eligible for an extension. Recipients with income below the payment standard receive an extension if they are deemed to have made a good-faith effort to find employment. This is generally defined by the recipient’s sanctioning history: A recipient who has one sanction or no sanction is considered to have made a good-faith effort and is granted a six-month extension.1  Recipients who are ineligible for an extension based on good-faith effort can still receive an extension if they have circumstances beyond their control that prevent them from working — although, as discussed below, this rarely happens.

In practice, MDRC’s evaluation found that nearly every recipient whose income was below the payment standard upon reaching the 21-month time limit was deemed to have made a good-faith effort and was granted an extension. In essence, the policy gives recipients the benefit of the doubt, even when there is little information available about their history of participation in employment activities. As a result, a large majority of the people whose cases were closed because the time limit were employed. Once in an extension, the penalty structure for noncompliance becomes much more severe: A single instance of noncompliance results in case closure, and the recipient cannot receive any further extensions based on good-faith effort. (However, individuals whose benefits are canceled for noncompliance during an extension are not categorized as having left welfare because of the time limit.)

A new exit interview is scheduled in month 5 of each six-month extension, and the process is repeated. There is no limit to the number of extensions a family may receive, although, in the MDRC evaluation, less than 10 percent of program group members received more than three extensions. Nevertheless, statewide, nearly 40 percent of the time-limited caseload was in an extension as of mid-2001. In October 2001, Connecticut imposed new restrictions on obtaining more than three extensions, and it also imposed a new 60-month time limit that allows few exceptions.2   The proportion of cases in extensions has declined sharply since that time.

After the Time Limit

DSS contracts with the Connecticut Council of Family Services Agencies, an umbrella agency, to operate the Safety Net program. The program is targeted to recipients who have been terminated from welfare (because they were deemed noncompliant) and whose income is below the payment standard; Safety Net is intended to prevent harm to children in these families. Cases are referred to Safety Net by DSS, and program case managers conduct intensive outreach efforts. The program can provide a limited number of vouchers to pay for rent or other necessities, but much of the focus is on helping participants find jobs. In a substantial number of cases, participants are found to be eligible for cash assistance, usually because an exemption applies. Because Safety Net services are targeted to noncompliant recipients, they are not available to compliant recipients with income below the payment standard who do not meet the criteria for a fourth or higher extension or who are terminated because of the 60-month time limit.3  

DSS also developed a temporary program to provide rental assistance to families whose benefits have been terminated and whose income is above the payment standard.

Florida

Background

MDRC is studying Florida’s welfare reform in Miami-Dade County as part of the Pro ject on Devolution and Urban Change. The data presented here were collected as part of that study. Florida’s welfare system is state-administered, so there may be less variation in imple mentation than in states with county-administered welfare programs.

• Time-limit policy. Florida has both a lifetime and a periodic limit on cash assistance. The lifetime limit is 48 months. The periodic limit is 24 months within any consecutive 60 months for most recipients and 36 months in a 72-month period for those facing more serious barriers. There is also an “earn-back” provision that enables recipients to earn one additional month of eligibility, up to a maximum of 12 additional months, for each month in which they are fully compliant with the work activities through subsidized or unsubsidized public or private sector employment. The first participants reached the time limit in October 1998.

• TANF grant level and earned income disregard policies. The maximum monthly benefit in Florida for a family of three is $303. Florida disregards $200 of earned income and 20 percent of the remainder. A family of three can earn up to $806 per month and remain eligible.

• Work requirements and sanctions. Florida’s welfare-to-work program is administered at the local level by 24 Regional Workforce Boards. Training and employment services are contracted out to providers, who play a role in determining which recipients get an extension to the time limit. Failure to comply with work requirements leads to complete termination of a family’s TANF benefits. The sanction can be imposed in the first instance until 10 days of compliance. Upon the second instance of noncompliance, Florida terminates TANF and Food Stamp benefits until 10 days of compliance. For subsequent instances of noncompliance, the maximum sanction is termination of TANF and Food Stamp benefits for three months, followed by compliance for 30 days. Benefits to children under 12 may continue through a protective payee. In Miami-Dade County, the rate of sanctioning is quite high: During an average month in FY 2000, about 4 out of 10 adults on cash assistance were either referred to or receiving a sanction.

Communicating the Message

In Miami-Dade County, the Department of Children and Families communicates messages about time limits to recipients primarily during application and redetermination meetings. Unlike in many other states, the number of months remaining on a recipient’s clock in Florida is not routinely announced with each benefits check (the state recently began issuing benefits via electronic benefit transferEBT]). Time limits are also discussed during welfare-to-work orientation meetings, which also include information about work requirements, sanctioning, and support services. When clients have six months of cash assistance eligibility remaining, they receive a letter indicating that they are approaching the time limit and informing them that they may be eligible for an extension if they are working.

During redetermination interviews, caseworkers remind clients of their time limits and attempt to find out if the client’s status has changed. Recipients are required to inform their caseworkers of any change in status, including employment, within 10 days. The county has a form that allows people who are subject to the time limit to close their case at any point, and caseworkers suggest that clients should save their months of assistance for a time when they really need it. One caseworker indicated: “I remind clients during recertification that there are transitional benefits. If clients are working and get a very low benefit, I encourage them not to take it so that time won’t count against the time limit.” During the meeting, clients are given a form that explains the time limit and that they must read and sign for their file.

Most caseworkers in Miami-Dade County reported that they feel time limits motivate individuals to find jobs. They stress the time-limits message to clients who are not working diligently to find jobs.

Determining Who Is Exempt

Florida exempts recipients who receive Supplemental Security Income (SSI or SSDI) and individuals who care for disabled family members.

Working with Cases Approaching the Time Limit

Florida grants hardship extensions for several categories of recipients: those who are unable to find employment despite complying with the state’s work program requirements, participants who have complied with program requirements but who face extraordinary barriers to employment, recipients who have significant barriers to employment and need additional time, victims of domestic violence, recipients living in high-unemployment areas, and families for whom the termination of cash benefits would likely result in a child’s being placed in emergency shelter or foster care. Individuals who have applied for SSI or SSDI but who are still waiting to learn whether their application will be accepted are automatically granted extensions.

In addition, Florida also provides extensions for recipients who are participating in substance abuse programs. Upon successfully completing treatment, they may receive up to an additional 12 months of benefits for each month they are enrolled.

After the Time Limit

Miami-Dade County does not offer any post-time-limit services. However, extensions are easily granted to recipients who comply with requirements, and there is no limit on the number of months of an extension that a recipient can receive.

A central conclusion that can be drawn from Miami-Dade County’s experience with time limits is that most recipients leave the system because they are working or noncompliant with requirements. Those who are compliant are eligible for extensions, and relatively few families have their cases closed directly because of the time limit.

Florida’s Family Transition Program

Background

The Family Transition Program (FTP) was a pilot program that operated in Escambia County (Pensacola) from 1994 to 1999. Escambia County was the first place in the United States where families reached a termination time limit. MDRC conducted a random assignment evaluation of FTP under contract to the State of Florida.

• Time-limit policy. FTP’s time limits were 24 months in any 60-month period for most recipients and 36 months in any 72-month period for those facing the most serious barriers to employment.

• TANF grant level and earned income disregard policies. The maximum TANF grant for a family of three was $303 when FTP operated. The first $200 plus half of any remaining earnings were disregarded.

• Work requirements and sanctions. FTP’s employment component emphasized both job search activities and education/training activities. There were no full-family sanctions in place for much of the time that FTP operated.

Communicating the Message

As a relatively small pilot program that was implemented before time limits were broadly familiar, FTP was generously funded and heavily staffed. Each participant was assigned to a case manager, who handled both eligibility and social services functions, and an employment services worker. Each case manager worked with only 30 to 35 families.

With small caseloads, workers were able to have frequent contact with participants. The time-limit message was transmitted during these in-person contacts and through written materials. Surveys of workers and participants found that staff did not necessarily urge recipients to leave welfare in order to bank their months. Particularly during the early years of FTP operations, workers were more likely to encourage participants to take advantage of education and training opportunities to prepare themselves for relatively high-paying jobs that could keep them off welfare permanently. Over time, FTP became more employment-focused, and the banking message assumed more prominence.

Determining Who Is Exempt

Beginning in May 1994, individuals who applied for AFDC in Escambia County were randomly assigned to FTP or to a control group that remained subject to AFDC rules; on-board recipients were randomly assigned in the same manner when they came to the welfare office for a semiannual redetermination appointment. Recipients who met the criteria for an exemption from FTP at that point — including those with a child under age 1 and those who reported that they had a medical condition that precluded them from working — were not enrolled into the program (or the evaluation). There are no data on what fraction of the welfare caseload was excluded in this way.

Recipients could also be exempted after their time-limit clock started — for example, if a new medical condition developed or a preexisting condition was detected for the first time. There are no precise data on how many recipients were exempted in this manner, but data from the evaluation show that about one-third of those who accumulated 24 or 36 months of benefit receipt (depending on their time limit) were not considered to have reached the time limit; the most common reason was that they had been granted a medical exemption that stopped their time-limit clock. Staff reported that serious medical conditions sometimes came to the surface as recipients approached the time limit and were targeted for intensive services.

Although extensions of the time limit were possible in FTP under certain circumstances (see below), staff rarely discussed extensions with participants.

Working with Cases Approaching the Time Limit

Recipients who came within six months of reaching their time limit and who were not employed were referred to specialized staff known as “transitional job developers,” who worked intensively to help these individuals find jobs. The transitional job developers sometimes met with recipients several times a week, and they offered employers generous subsidies to hire their clients.

During this same period, staff met to assess whether recipients had complied with FTP’s employment requirements and other rules over their time in the program. According to the program policy (which was in part imposed by the federal waiver process), recipients who complied with the rules but were unable to find jobs by the time they reached the time limit were to be offered subsidized minimum-wage jobs that would allow them to earn as much as a standard welfare grant. Temporary benefit extensions were also possible for recipients who were deemed compliant. A Review Panel, composed of volunteers from the community, helped to determine which participants were deemed compliant and which should be granted extensions.

Cases deemed noncompliant — and thus ineligible for extensions or post-time-limit subsidized jobs — were reviewed by a child welfare worker. The children’s portion of the grant was to be retained if it was determined that full termination would place the children at risk of foster care placement. Finally, the district welfare administrator had to sign off on all benefit terminations.

Only about 17 percent of the FTP participants who were studied in the evaluation (237 people) actually reached the time limit within four years after enrollment. The vast majority of the others left welfare before reaching the time limit.

Despite the multiple safeguards and layers of review, nearly all of those who reached the time limit had their benefits fully canceled. Very few extensions were granted; only a handful of cases retained the child’s portion of the grant; and no one was given a post-time-limit subsidized job. (As noted earlier, however, a significant number of recipients were excluded from FTP or were exempted before reaching the time limit, usually because of medical problems.)

The FTP evaluation found that almost half the recipients who reached the time limit were already employed and earning at least as much as a standard welfare grant; these individuals were considered self-sufficient and not in need of either an extension or a subsidized job.

The rest of the recipients who reached the time limit were not employed, but the vast majority of them were deemed noncompliant and thus ineligible for an extension or a subsidized job. Compliance was never precisely defined under FTP rules, and it appears that the distinction between failure to follow program rules and failure to make progress toward self-sufficiency was somewhat blurred in practice. For example, nearly all recipients who were not employed six months prior to reaching the time limit were deemed noncompliant.

The child’s portion of the grant was rarely retained, because the criteria used in the child welfare review were narrow: The worker needed to conclude that foster care placement was likely to occur as a direct result of benefit termination. The staff who conducted the reviews reported that they believed that children in some of the families they examined might eventually be removed from their parents but said that the cause for removal would not be benefit termination.

After the Time Limit

Very few recipients in FTP were granted extensions, so there was no formal set of services for that group. There was also no formal follow-up program for families whose benefits were terminated at the time limit. Many of them continued to receive Medicaid and Food Stamps and thus remained in touch with FTP staff, at least to some extent.

Georgia

Background

Georgia’s time limit was implemented in January 1997. MDRC visited two welfare offices in Fulton County (Atlanta) as part of this project.

• Time-limit policy. Georgia has a 48-month lifetime limit for receipt of TANF. The first families reached the limit in January 2001.

• TANF grant level and earned income disregard policies. The maximum monthly benefit for a family of three is $280. Georgia disregards the first $120 of a recipient’s earned income plus one-third of the remainder during the first four months of employment; the first $120 during months 5 to 12; and the first $90 thereafter.

• Work requirements and sanctions. All recipients who are deemed ready to work must participate in work activities. The only exemption from the work requirement is for single custodial parents who have a child under 12 months of age in the home.

Communicating the Message

In Fulton County, applicants for TANF assistance are first notified of the state’s 48-month time limit during their initial orientation. Caseworkers subsequently remind recipients of the time limit on a regular basis. The state sends letters about the time limit to recipients when they reach month 12, month 36, and every month thereafter. These letters tell recipients the number of months of benefits that they have used up and the number remaining.

The general message that the Fulton County Department of Families And Children’s Services (DFACS) tries to communicate to recipients is: “TANF is a 48-month program. It is not an entitlement any longer. Try your best to find employment and get off quickly. Save your months of eligibility because you many need them later.” In particular, employed recipients who are receiving small grants are encouraged to close their case. Staff say that they don’t talk much about extensions even when recipients are nearing the time limit. One case manager said that when she meets with recipients just before the time limit, she tells them, “If you don’t participate, your benefits will be cut.”

Determining Who Is Exempt

Although Georgia does not exempt recipients from the time limit, Fulton County does refer many recipients to the vocational rehabilitation department for an in-depth assessment to uncover medical, mental health, substance abuse, and other serious issues. Despite this assessment, staff say that cases with serious problems sometimes slip through the cracks and that they might find out about it only after a case is closed and the person reapplies. At that point, staff say to the person: “Tell us what is going on. If I don’t know, I cannot guarantee you will get an extension.”

In addition, the only exemption from work requirements is a once-in-a-lifetime exemption for single custodial parents with a child younger than 12 months of age. Consequently, all recipients have a work plan. The plan for recipients with a medical disability, for example, might be to continue with their medical treatment. Fulton County works closely with local agencies that provide assessments, short-term training, vocational rehabilitation services, substance abuse treatment, and counseling for domestic violence victims.

Working with Cases Approaching the Time Limit

Caseworkers call recipients in at month 44. The purpose of this meeting is to make an initial assessment of whether recipients will qualify for extensions. Caseworkers also use this opportunity to find out whether there are medical, mental health, substance abuse, or other barriers that prevent recipients from finding work. Recipients who are not in an activity and have not been found to have barriers to employment are referred to a work experience program with a strong case management component. The program (called Good Works) includes work experience and subsidized employment. These recipients are paid wages, and caseworkers say that they encourage them to voluntarily close their case and save their remaining months of eligibility. Mandatory drug tests are also part of this program, and anyone testing positive is referred to substance abuse treatment.

Strict reporting and monitoring requirements have accompanied the implementation of time limits. Each month, each welfare office receives a list of recipients who have reached month 44 and beyond. Staff monitor compliance with the work plan, and they call recipients in for a staffing every 90 days. After 44 months, staff say that they are “less lenient”; if a recipient missed an appointment, the case is immediately closed. Caseworkers also say that they spend lots of time making sure that people on the list are complying with their work plan. Staff claim that most cases are closed because they fail to comply with the work requirement, not because they reach the time limit.

Intensive monitoring and reporting procedures increased case managers’ workload. As a result, the directors of both offices visited for this study had recently established specialized employment services units. One office gave responsibility for handling all aspects of cases reaching 44 months to one staff member. In another office, the responsibilities were divided differently, with some staff assuming responsibility for tracking participation in programs offered by outside providers.

Final decisions on whether or not to grant an extension are made in month 47. If recipients do not attend the meeting, caseworkers attempt to reach them through home visits and certified letters. When caseworkers cannot locate recipients, the cases are closed. Staff said that many do not comply at this point, and their cases are closed.

Georgia grants extensions past the 48-month time limit for the following seven categories: (1) cases of domestic violence, (2) active cases in Child Protective Services, (3) cases participating in a substance abuse program, (4) persons unable to work because of personal disability who are not certified for SSI, (5) caretakers of disabled household members, (6) persons who have not yet completed their work plan, and (7) persons living in areas with few employment opportunities. Claims of domestic violence, disability, or substance abuse are followed up by referral to outside specialists for assessments, verification, and development of treatment plans. Supervisors and a senior county official review all extension decisions. State officials have begun reviewing cases that have reached 60 months.

After the Time Limit

Many of the recipients in Georgia who receive benefits beyond the 48-month time limit are classified as having an “incomplete work plan.” Their benefits are extended because they are in a training or work plan approved by the county and need additional time to complete their program. Case managers report that “not many are cut off because of time limits.” Staff also say that this liberal extension policy sends a “mixed message” to recipients, lessening the likelihood that they will take the time-limit message seriously.

Extensions are made for a period of 90 days at a time. There is no limit on the number of extensions that can be granted, but, at the end of each 90-day period, the case worker determines whether the client will continue to be eligible for an extension. Staff say that the few who have already accumulated nearly 60 months of TANF are disabled to the extent that “some will never get off.”

Louisiana

Background

Louisiana’s time limit took effect in January 1997, and the first families reached it in January 1999. MDRC visited two welfare offices in New Orleans as part of this project.

• Time-limit policy. Nonexempt individuals are limited to 24 months of assistance in any 60-month period, and there is a 60-month lifetime limit on cash assistance.

• TANF grant level and earned income disregard policies. The state TANF program is called Family Independence Transitional Assistance Program (FITAP). The maximum monthly grant for a family of three is $190.

• Work requirements and sanctions. Adult recipients with no children under age 1 are required to work 20 hours per week. Louisiana imposes full-family sanctions after the second instance of noncompliance with work activity requirements.

Communicating the Message

Recipients in Louisiana are first informed about the time limit — including exemption criteria — during a mandatory orientation at application. Case managers and eligibility workers informally reinforce the time-limit message to clients. Staff report that they do not discuss the periodic nature of the time limit and that this is not tracked by the computer system. Because the state offers extensions to clients who comply with the Family Independence Work (FIND Work) program’s participation requirements, the time-limit message is closely related to the message of mandatory participation in the FIND Work program.

The first formal time-limit notification is a system-generated letter sent to clients in month 18 of assistance that explains their time-limit status (including a list of the months in which they received assistance) and gives a detailed explanation of exemption criteria.4   According to case managers in one office, clients are aware that the state has a liberal extension policy and that they are likely to continue to receive benefits even after they reach the time limit. In another office, staff maintain that they do close a number of cases each month for the time limit but that many clients have discovered that it is relatively easy to come back on welfare.

Determining Who Is Exempt

Time-limit exemptions can be granted to clients who are disabled or incapacitated, to women in the third trimester of pregnancy, and to working recipients during the first six months of employment when they are eligible for the enhanced income disregard. Case managers can independently exempt pregnant and working clients. A designated staff person — the county Program Specialist — handles medical exemptions. The Program Specialist reviews a standard form that is filled out by the client’s case manager and physician and then both authorizes the exemption and determines its duration. Since there is no formal process for proactively assessing clients’ health, medical exemptions are largely client-initiated and thus subject to clients’ awareness of both the exemption criteria and their own health, not to mention their degree of comfort in discussing such matters with their case manager.

There are some situations in which clients are exempt from participation in work activities but are still subject to time limits. For example, a recipient with a child under age 1 is exempt from participating in FIND Work activities although her time-limit clock is ticking. Similarly, clients with disabilities are exempt from time limits but not necessarily from work activities; thus, a client who is depressed may be mandatory for work activities even though she is exempt from the time limit.

Louisiana recently decided to apply the same exemption and extension criteria to the 60-month time limit as are currently in place for the 24-month limit.

Working with Cases Approaching the Time Limit

Clients in Louisiana are explicitly told about the state’s extension policy in a letter they receive during month 18 of assistance. Clients can continue to receive assistance beyond 24 months for a number of reasons. Most do so because they are participating in FIND Work activities. Extensions of up to 12 months are granted to clients in order to complete an approved education or training program. Less commonly, extensions are granted to “unemployable” individuals. Unemployability can be defined by an individual’s characteristics if the case manager and supervisor determine that personal barriers make it unlikely or unreasonable that the client will find a job. Clients may also be deemed unemployable when the unemployment rate in the county is over 10 percent or the Parish Manager determines that there are no suitable jobs in the community. Finally, clients can also continue to receive benefits if they demonstrate that they are actively seeking employment. As discussed below, this extension is applied quite differently at the office level.

Case managers are responsible for granting extensions, and they can do so independently except in the case of an extension due to “unemployability,” which requires the supervisor’s approval. Extensions do not need to be coded in advance of month 24. In fact, clients will continue to receive benefits without an extension code; the default system outcome is an extension. According to one supervisor, because case managers cannot always promptly process cases that reach the time limit, a number of clients continue to receive benefits after month 24 without an extension. Since case managers and clients alike anticipate that clients will be granted extensions, case managers focus on how not whether clients will continue to receive assistance. As one supervisor noted, Louisiana has a conservative time-limit policy that has been implemented liberally.

For a number of reasons, case mangers aim to get clients engaged and compliant with the FIND Work program before they reach the time limit. Case managers don’t have to worry about closing engaged clients’ cases, either for the time limit or for a sanction. Furthermore, clients who are compliant do not have to meet separate FITAP requirements for extensions or exemptions — for example, by demonstrating that they are actively seeking employment. Engaged clients also count toward the county’s participation rate, which some counties consistently struggle to meet. On the other hand, unengaged clients with more than 24 months require intensive case monitoring. Case managers must track month-to-month whether they continue to qualify for a FITAP extension.

Clients can be eligible for continued FITAP benefits if they demonstrate that they are actively seeking employment by handing in monthly job contacts. However, doing so does not “count” as a FIND Work activity, and a client who has signed an employment plan and been assigned to a component can have her case closed for noncompliance even if she hands in a list of job contacts. However, clients can reapply for assistance almost immediately. As will be shown, the two counties visited in Louisiana had implemented very different methods of managing clients’ FITAP eligibility with regard to their participation in the FIND Work program.

In one county, once clients reach the time limit, they are explicitly told that they can continue to receive assistance if they can prove that they are actively seeking employment. Clients are sent an office-specific letter in month 22 explaining that, in order to continue to receive assistance, they must submit a list of 20 job contacts every month. They are sent a sample contact list, and the back of the letter has a simple diagram that illustrates when in a given month they must submit a form in order to be eligible for benefits in the subsequent month. Although case managers hope to eventually engage these clients in FIND Work activities, many otherwise-unengaged clients continue to receive assistance in this way. In practice, FITAP eligibility is prioritized over FIND Work participation. According to case managers and supervisors, this policy has taken a lot of the “bite” out of the time limit.

By contrast, at a different county office, staff report that they give priority to assigning clients to work activities when they are near or past the time limit. Engaged clients must continue to participate in order to receive benefits after the time limit. Staff do not tell clients that they can submit job contacts and remain on assistance. Furthermore, they regularly sanction clients. However, clients can reapply almost immediately, and, according to case managers, many do so. During the reapplication period, clients must demonstrate compliance in order to be recertified. However, they do not have to comply with their former employment plan. A list of 20 job contacts demonstrates compliance for applicants, including reapplicants. Staff report that many clients cycle on and off welfare in this manner, effectively avoiding sustained participation.

Louisiana recently redistributed the tasks assigned to case managers. Until recently (January 2001), case managers were required to monitor clients’ participation in FIND Work as well as clients’ eligibility for Food Stamps, Medicaid, FITAP, and support services. Although caseloads were small (approximately 40), case managers reported that eligibility functions monopolized their time and hampered their ability to engage clients in work activities. Staff at both offices were optimistic that — under the new system, in which case managers focus primarily on clients’ compliance with FIND Work and on their time-limit status (functions can be distributed somewhat differently, at county option) — they would have more success engaging clients in work activities.

After the Time Limit

Louisiana currently applies the same extension criteria to the federal 60-month time limit as to the state time limit. Therefore, clients can continue to receive benefits indefinitely, as long as their status remains unchanged. Since few individuals have accumulated 60 months of assistance, the state is not concerned that the number of exempt clients will exceed the federal limit.

There is no strict policy regarding follow-up with clients whose cases are terminated — as a result of either the time limit or a sanction. As noted, clients can re-apply for benefits at any time. Food Stamp benefits continue automatically (for both time-limit and employed leavers), but clients have to apply for transitional Medicaid and child care. Clients who leave for employment are also eligible for $120 per month in transitional cash assistance (to cover transportation and other costs related to employment).

Massachusetts

Background

Massachusetts’s time limit took effect in December 1996, and the first families reached it in December 1998. MDRC visited two welfare offices in the Boston area as part of this project.

• Time-limit policy. Nonexempt recipients are limited to 24 months of benefit receipt in a 60-month period.

• TANF grant level and earned income disregard policies. The maximum TANF grant for a nonexempt family of three is $618. Massachusetts disregards $30 and 50 percent of the remainder of a nonexempt recipients’ earned income. To remain eligible for assistance, recipients must have monthly earnings below $1,045.

• Work requirements and sanctions. Recipients with no preschool children are required to work 20 hours per week. The first instance of noncompliance results in the loss of the adult portion of the grant. If noncompliance continues for 30 days, the entire grant is terminated. The maximum sanction is the termination of the full-family grant until compliance.

Communicating the Message

Massachusetts uses a series of in-person Transition Reviews — along with written materials — to communicate information about the time limit to recipients. Transition Reviews occur at the 6- and 12-month points and then are more frequent during the second 12 months of benefit receipt (the specific schedule depends on whether the recipient is working, participating in work activities, or not involved in any employment activity). State officials report that written notices are deemphasized, in part because many recipients move back and forth between exempt and nonexempt status.

Frequent in-person contacts are particularly important because about two-thirds of the recipients who are subject to the time limit are exempt from work requirements (see below). Most caseworkers reported that they urge such recipients to participate in education or training activities; in fact, over time, these recipients have increasingly been required to enroll in education or training activities.

Staff reported that the “periodic” nature of the time limit — that recipients are actually limited to 24 months of benefit receipt in a 60-month period — is generally not emphasized in discussions with recipients. Also, staff say that they seldom discuss the possibility that extensions may be granted to recipients who reach the time limit; as one worker put it, “that would defeat the purpose of the time limit” because “extensions are just for emergencies.”

Determining Who Is Exempt

More than 70 percent of the TANF caseload in Massachusetts is currently exempt from the time limit (the exemption rate was closer to 50 percent when the time limit was first imposed, in 1996).5   The main categories of exempt recipients are those with medical problems, parents caring for a child under age 2, and child-only cases. As noted earlier, Massachusetts is unusual because the criteria for exemptions from the time limit are quite different from the criteria for exemptions from work requirements. Thus, at the end of 2001, nearly one-fifth of the state caseload — most of them families with a child between 2 and 5 — were exempt from work requirements but subject to the time limit.

Some of the exemption criteria are straightforward to assess — for example, exemptions for a child under age 2 or for child-only cases. Others, including exemptions for medical problems, can be more challenging. Like many other states, Massachusetts uses a centralized process to review requests for medical exemptions. A contracted medical assessment provider reviews statements from a recipient’s physicians and, in some cases, examines the recipient directly to determine whether an exemption is warranted. State officials believe that their earlier process, which relied on statements from recipients’ personal physicians, was subject to abuse and inconsistency.

Caseworkers are responsible for informing recipients about the exemption criteria and for asking, during Transition Reviews, whether there are “health issues including drug and alcohol use that are preventing you from finding a job.” But clients must be proactive in seeking medical exemptions; there is no routine, in-depth assessment of recipients’ physical and mental health status. Staff believe that they identify most recipients who should be exempt, but they also report that some recipients are either unaware of their health problems or unwilling to disclose them. This is particularly likely with mental health problems; stigma and cultural issues may prevent recipients from discussing these issues even if they are aware that a problem exists. Staff also note that the same issues that may make it difficult for a recipient to move toward employment may also make it difficult for her to navigate the exemption review process.

Working with Cases Approaching the Time Limit

Massachusetts’s policy identifies a range of factors that should be “considered” in deciding whether a recipient should be granted an extension upon reaching the time limit. These include “the degree to which a nonexempt grantee has cooperated, and is cooperating with, the Department in work-related activities.”

Recipients are scheduled for a Final Transition Appointment in month 23 of benefit receipt. During the appointment, the caseworker completes a Final Transition Plan, which reviews the recipient’s efforts to find work, and asks about her plans to support her family after the termination of benefits, whether there are health problems that are interfering with her ability to find a job, and whether she wants to request an extension. Recipients who wish to request an extension must complete a form that outlines the reason for the request.

The caseworker must then complete a “24-Month Extension History Form” that reviews the recipient’s work status, history of participation in employment activities, barriers to participation, and other relevant information. The form also includes a space for the caseworker’s recommendation about whether an extension should be granted. The form is given to the office director, who may discuss the case with the caseworker before reaching a decision. That decision is then reviewed at the central office. Extensions can be granted for up to six months but are usually granted for only two months at a time. There is no limit to the number of extensions a family may receive, and extensions may be granted after a recipient has left assistance.

The implementation of the extension policy has evolved over time. Because the time limit was imposed at the same time for all nonexempt cases, more than 5,000 families reached the time limit simultaneously at the end of 1998. State officials reported that it took several months to review all the extension requests; a large majority of the initial requests were denied. At that point, Massachusetts (like Connecticut) routinely denied extensions to recipients who were working and earning more than the maximum TANF grant for their family size. After a legal challenge, the courts ruled that this policy was contrary to state law, and it had to be dropped.6  

Initially, extension decisions were subject to several layers of review, first at the regional level and then at the central-office level. The review was needed to ensure that the potentially subjective extension criteria were interpreted uniformly across offices.

Both caseworkers and managers reported that the extension review process has now become quite routinized. One manager summarized the policy by saying that an extension is granted if the recipient is “either working full time or looking for full-time work.” In practice, for a recipient who is not employed, this translates into participating in a Structured Job Search activity. Recipients who are working part time are permitted to enroll in a more flexible job search activity that requires fewer hours of participation. Despite the historical summary completed by caseworkers, the extension decision usually hinges on the recipient’s current willingness to participate in the job search activities. Both local and central-office staffs believe that a much greater proportion of extension requests are approved now than in the past.

Staff consistently reported that many recipients do not request extensions. They speculated that some do not want to participate in job search activities; they may feel that the activities will not help them, or they are working part time and do not want to add work hours.

After the Time Limit

DTA has contracted with the Massachusetts Department of Public Health to operate a program called Follow-up Outreach and Referral (F.O.R.) Families, which targets families whose cases have been closed because of the time limit. Cases are referred to the program by welfare offices and F.O.R. Families. Staff then attempt to contact the recipient.

New York

New York’s time limit took effect in December 1996. MDRC visited two offices in New York City as part of this project. New York State’s 58 local social services districts have a large degree of autonomy in how they run their TANF programs, particularly with regard to certain aspects of the time limit, such as how decisions regarding extensions and exemptions are made. It is important to note that this profile, while based in part on state law, reflects the procedures and operation of New York City’s Human Resources Administration (HRA). It is likely — in fact probable — that other districts in the state run aspects of their TANF programs very differently.

Background

• Time-limit policy. Nonexempt individuals are limited to 60 months of cash assistance. After 60 months, families who are eligible for assistance can receive benefits from the state and locally funded safety net program, which is only partly in cash.

• TANF grant level and earned income disregard policies. The maximum TANF grant for a family of three is $577. New York disregards the first $90 of earned income plus 49 percent of the remainder.

• Work requirements and sanctions. In New York City, nonexempt recipients with no children under 3 months old are required to participate in work activities for 35 hours per week. New York does not have full-family sanctions; noncompliance results in a pro rata reduction until compliance.

Communicating the Message

In New York State, there is a 60-month limit on federally funded Family Assistance. However, individuals who exhaust all available months of Family Assistance can continue to receive benefits through the state’s Safety Net Assistance program. Because of this, New York’s time-limit message is twofold, and its parts are somewhat contradictory: Federally funded assistance is time-limited, but there is no lifetime limit on the receipt of state-funded assistance. To a recipient, this essentially means that there is no time limit on assistance; however, welfare staff did not advertise this. In fact, welfare offices initially posted signs with slogans like “The clock is ticking” and “Welfare is time-limited,” and welfare staff made general references to the fact that welfare is temporary.

While clients hear about the time limit in a general sense, there is little specific discussion of a client’s status or what will happen after a client reaches the time limit. In fact, until late 2000, workers could not access a client’s “count” through the computer system. For the initial cohort of 36,000 recipients who reached the time limit in December 2001, the lack of discussion about the availability of Safety Net Assistance likely corroborated the message that welfare is time-limited. In other words, the lack of a message likely provided a stronger message than the reality of the time limit. A letter sent to clients in month 58 of assistance (an earlier letter was also sent at 54 months) illustrates the ambiguity of the time-limit message: While clients are told that they can continue to receive benefits, they are also reminded to “keep track” of their time-limit count, since “the time limit is a lifetime limit.” The letter also explains that there is no time limit on Safety Net Assistance.

Determining Who Is Exempt

New York State does not offer exemptions that stop a client’s clock before the time limit. However, certain categories of individuals are exempt from work activities, and these individuals most often meet criteria for exemptions that begin in month 60. For example, clients with physical or mental impairments that are expected to last longer than six months and individuals who are required to care full time for a child or other family member are exempt from work activities, and they can be exempted from time limits after they have reached the 60-month limit. There are other conditions under which a client is exempt from work activities but not exempt from time limits. Parents with children under age 1 (although there is a lifetime limit of 12 months, and a limit of 3 months for any one child) and pregnant women in the last month of pregnancy fall into this category.

Exemptions are directly advertised to clients nearing the time limit. The 58-month letter lists the exemption criteria and encourages clients to notify their caseworker if they think that they meet any of the criteria. Case managers informally assess all clients before they reach their time limit to see whether they are eligible for an exemption. Clients who report medical problems are referred to HRA’s health care subcontractor, where clients are examined by physicians and designated as exempt or nonexempt according to the severity of their impairment.

Since well below 20 percent of New York City’s caseload is currently exempt, the city is using the time limit/Safety Net reassessment process to identify clients who may, in fact, meet exemption criteria. Exempting eligible clients has a financial benefit; exempt clients can continue to receive federally funded Family Assistance, whereas benefits provided through the Safety Net Assistance program are funded entirely by the state and city.

Working with Cases Approaching the Time Limit

As in many other localities, formal time-limit processes in New York City begin when clients approach the time limit. For many clients, this process begins in month 48, when they are transferred to one of a designated team of caseworkers responsible for formally and informally evaluating and reassessing each client’s case. This team consists of integrated workers who have been trained to handle clients timing-off Family Assistance. Formal written notices are sent in months 54 and 58. An “informational” letter sent during month 54 notifies clients of their time-limit status and reminds them of the 60-month limit on cash assistance. The 58-month letter notifies clients of the Safety Net Assistance program.

To encourage employment and reinforce the work-first message, the city offered some individuals who were nearing the time limit and already participating in work activities (but had not yet found employment) temporary, transitional, subsidized jobs in the city’s Parks Department and even in HRA. Workers stressed to clients that these positions were “real” jobs; clients received regular biweekly paychecks from employers, not welfare checks. Wages varied depending on the position as we all as — to a certain degree — the client’s background and skills. Clients working in subsidized jobs were required to participate in a job search component as well. Job offers were mandatory, and clients incurred a sanction if they refused a job offer or did not show up for their orientation or scheduled work hours.

In addition to the 58-month letter, around month 58 clients are sent an application for Safety Net Assistance and an appointment letter for a time-limit reassessment interview. To continue receiving assistance, clients must file an application for Safety Net Assistance prior to month 59 of Family Assistance. They are eligible for Safety Net Assistance as long as they meet Family Assistance eligibility criteria and they are compliant with participation requirements. While the absolute value of benefits is the same in both programs, some Safety Net benefits are noncash. For example, rent is paid through vouchers, and the city is implementing a voucher program for utilities and an EBT system that will make the program primarily noncash.7  

In December 2001, approximately 36,000 cases reached the 60-month time limit in New York City. About 6,000 cases were exempt from the time limit and continued to receive cash assistance under the 20 percent exemption provision. Another 14,000 cases mostly employed recipients were automatically converted to the Safety Net Assistance program. The remaining 16,000 cases were asked to come in to file a Safety Net application.

The city established centralized procedures to handle the large initial cohort reaching the time limit. While the transition from Family Assistance to Safety Net Assistance was relatively seamless for compliant individuals, the city implemented a special process for clients who are in sanction status when they reach the time limit. These clients cannot file an application for Safety Net Assistance at their welfare office. Rather, they receive an appointment letter giving a date and time when they must appear at the main office of the city’s fraud verification unit. (Although the letter specifies a date and time, in fact clients have a 30-day window in which they can appear.) When they arrive, there is a lengthy process that includes three meetings with three different staff before they can file an application. Typically, this process takes the better part of a day, and clients who arrive late generally have to return for a follow-up appointment. For those reaching the time limit in late 2001, the end result was a subsidized job offer. Now, however, clients who chose to file an application for Safety Net Assistance at the end of the process are assigned to a work activity.

During this process, a client first meets with a fraud investigator, who tries to determine how the recipient is getting by on a reduced benefit and verifies her eligibility using printouts from various databases of employment, bank balances, and assets, including vehicle ownership records from the Department of Motor Vehicles (DMV). Next, the client is sent to a substance abuse specialist for a 30-minute assessment and, if appropriate, is referred for treatment. Last, recipients who agree to comply with work requirements meet with a welfare caseworker to file a Safety Net application and receive a work assignment.

Through the end of 2001, clients were offered subsidized jobs working for city agencies. Because the eligibility verification review process is technically an application process for Safety Net Assistance and all applicants who refuse a bona fide job offer are ineligible for assistance, the Safety Net applications of those who refused job offers were not accepted. These clients’ cases were not transferred to Safety Net Assistance after their Family Assistance cases were closed at the end of month 60.

Clients who are assigned to a work experience component or subsidized job appear on a work list 10 days after they are scheduled to begin participating. If a client is compliant, then the sanction is cured and the client is both transferred to the Safety Net program and reassigned to a caseworker at a normal welfare office. If a client is not participating, then the case is closed, and the client is ineligible for Safety Net Assistance. Overall, of the 16,000 cases called in to file a Safety Net application (including both compliant and sanctioned recipients), about 3,000 had their cases closed.

Several welfare offices are piloting a diversion program targeted at employed recipients. These clients are sent a letter asking them to come in for a voluntary appointment to discuss the bonus program. At the meeting, individuals are asked to voluntarily close out their case in exchange for a check of $200 per month for one year. If the client agrees, she is given her first $200 check on the spot.

After the Time Limit

Clients receiving Safety Net Assistance must continue to participate in work activities but can continue to receive assistance as long as they are eligible. Clients who later become physically or mentally impaired may go back on Family Assistance if it is determined that they meet exemption criteria. Clients whose cases close because of employment are eligible for up to two years of transitional child care and Medicaid.

Ohio

Background

Ohio’s time limit took effect in October 1997, when the state implemented its Ohio Works First (OWF) program. MDRC has studied Ohio’s welfare reform in Cuyahoga County (Cleveland) as part of the Project on Devolution and Urban Change. The data reported here were collected for that study.

• Time-limit policy. Ohio has a 36-month lifetime limit on cash assistance with no exemptions. There are two categories of extensions: (1) hardship and (2) good cause. Hardship extensions can be granted anytime after the 36-month limit. A good-cause extension can be granted only after a 24-month waiting period without cash assistance. Once a recipient is approved for a good-cause extension, she may receive cash assistance for up to an additional 24 months, for a total lifetime limit of 60 months.

• TANF grant level and earned income disregard policies. Ohio’s maximum monthly benefit for a family of three is $373. Ohio disregards the first $250 of earned income and 50 percent of the remainder.

• Work requirements and sanctions. Failure to comply with Ohio’s work requirements without good cause leads to the loss of the recipient’s cash assistance for one month or until compliance, whichever is longer. The second instance of noncompliance results in a sanction for three payment months or until compliance, whichever is longer. Subsequent instances of noncompli-ance result in the loss of OWF cash assistance for six payment months or until compliance, whichever is longer.

Communicating the Message

Cuyahoga County has attempted to make sure that all recipients are aware of the 36-month time limit and that no families are caught by surprise. With each month’s welfare check, the county sends written reminders of the number of months of cash assistance remaining. Messages about the time limit are also delivered to recipients at regular eligibility and redetermina-tion meetings. In Cuyahoga County, welfare offices (called Neighborhood Family Service Centers) have large banners that remind clients of the time limit.

As the time limit on their cases nears, all recipients are required to come in for a pre-time-limit interview. About six months before the client is due to hit the time limit, the caseworker (Cuyahoga County calls them Self-Sufficiency Coaches) conducts an interview with the recipient, using the Pre-Time-Limit Evaluation Interview form as a guide, to determine how the family will be able to survive economically once cash assistance is terminated. The county wants to be satisfied that the client has a realistic plan to replace welfare with other income from work, child support, or family members. The Self-Sufficiency Coach is responsible for going over the Talking Points on Time Limits with recipients, which include the following messages: “Time limits are real, you need to have a plan to support your family when your cash benefits end”; “Everyone can work, given the right supports”; “Employment is the only long-term guarantee that you can provide for your family”; “It pays to work, do the math”; and “Time Limits affect ONLY cash benefits.”

Determining Who Is Exempt

Ohio has no exemptions to the time limit.

Working with Cases Approaching the Time Limit

Ohio offers two kinds of extensions to the time limit: (1) hardship and (2) good cause. Families who are cooperating and have reached the 36-month time limit may be eligible for a hardship extension for various reasons, including being victims of domestic violence, having made a good-faith effort, being disabled or caring for a disabled family member, living in a high-unemployment area, needing more time to complete education or training, having an active Child Protective Services case, being homeless, being pregnant, having a substance abuse problem, or having a transportation barrier.

In Cuyahoga County, recipients are called into a pre-time-limit interview, and frontline workers determine whether or not they qualify for one of the county’s post-time-limit options (see the next section). The pre-time-limit interview is mandatory, and clients who fail to show up are referred to a child safety review program. The county has a high compliance rate for the interviews.

Ohio has recommended that each county have a child safety review process in place to ensure that children will not be in jeopardy if their family looses cash assistance due to the time limit. All counties should have a system in place to keep track of families who are facing the loss of cash assistance due to sanctions or time limits. The goals of the process are to inform families about continued support services and to ensure that children who are at risk of neglect or abuse receive protective services.

In Cuyahoga County, the child safety review process is called Safety Net and has been implemented by contracting with nonprofit agencies to conduct home visit to families who have recently lost assistance. The Safety Net contractor makes a thorough assessment of the family’s circumstances and sources of income and also tries to connect the family to appropriate resources. The contractor lets families know that it is not a state or county agency, to ease any resistance that clients may feel about having a government social worker visit their home. The contactor issues a report to the case manager regarding the status of the children in the home. If appropriate, a referral is made to the county’s child protection agency.

Families can continue to receive child care assistance, Food Stamps, Medicaid, and employment resources after cash assistance has been terminated. Staff in Cuyahoga County report that nearly all clients whose cases have been closed due to time limits continue to receive at least Food Stamps and Medicaid after cash assistances has ended. Clients remain with the same frontline worker immediately after the time limit has been imposed.

After the Time Limit

Ohio allows good-cause extensions after a 24-month waiting period following the 36-month time limit. Families who qualify can be eligible for up to an additional 24 months of cash assistance. The first families to qualify for the good-cause extension will be eligible in October 2002.

To assist clients after the time limit has been reached, Cuyahoga County has implemented two programs: Short-Term Transitional Assistance (STTA) and the Transitional Jobs Program. STTA provides up to six months of cash assistance to families who have documented medical problems or are in crisis situations. The county has a rigorous screening process and has approved relatively few applications.

The Transitional Jobs Program is for people who hit the time limit and do not have any other source of income. It is essentially a pay-for-performance job search activity designed to connect recipients with jobs with private employers. Once a client is hired, the county offers the employer a 100 percent wage subsidy for first 30 days and a 75 percent subsidy for the next 60 days. A total of 433 adults participated in the Transitional Jobs Program during the first year it was in operation. It was recently suspended because of substantial cuts in county welfare funding.

South Carolina

South Carolina implemented its time limit in October 1996 under federal waivers. MDRC visited two welfare offices as part of this project.

Background

• Time-limit policy. A family may receive Family Independence (FI) benefits for no more than 24 months out of 120 months. There is a 60-month lifetime limit on FI benefits.

• TANF grant level and earned income disregard policies. The maximum grant for a family of three is $204 a month. The state disregards 50 percent of earned income for the first four months of employment and $100 thereafter.

• Work requirements and sanctions. Individuals with children over age 1 are required to participate in FI activities except in the case of pregnancy or other incapacity. The first instance of noncompliance results in a 30-day conciliation period. If the client is still noncompliant at the end of the conciliation period, then a full-family sanction is imposed.

Communicating the Message

South Carolina is very proactive about notifying clients about their time limit status. Clients are told about the time limit at application and then are reminded of the time limit and their status during every encounter with staff. All notices from the welfare department, including monthly benefit checks, remind clients of how many months they have remaining. In addition, formal “staffings” — meetings with clients and all staff working on the case, including the county director, the TANF program director, the supervisor, and the case manager — are held during months 12 and 22. If a client has a job developer or a CPS worker, these workers also attend. In months 6 and 18, there are additional staff-only meetings. (In some cases, clients are also invited to attend.) In all these meetings, the focus is on the client’s progress toward the goals stated in the employability plan.

In recent years, changes in the leadership of the TANF program at the state level have affected aspects of the FI program, including time limits. Most notably, the state relaxed policies about both time-limit extensions and sanctions. (Some of the specifics of these policy changes are discussed below.) It is also important to note that there were some substantial differences in how policies were changed at the county level. Staff at one office reported that the net effect of the policy changes was to rescind the time limit. Some case managers voiced frustration that they had lost credibility with clients once clients realized that their frequent admonitions about the time limit were unwarranted. At another office, staff maintained that although policy changes had resulted in a more liberal sanctioning policy, they did not feel that clients’ perceptions of the time limit had changed.

South Carolina has one of the nation’s lowest welfare grants. Staff report that, because of low grants, clients are much more concerned about keeping their Food Stamps and support services — in particular, child care — than about staying on cash assistance. For this reason, a large part of the time-limit message emphasizes how clients can maximize their transitional benefits and “make the most of” their time on public assistance.

Determining Who Is Exempt

South Carolina’s exemption policy is clear-cut. Disabled clients and clients who are needed in the home to take care of a disabled family member are exempt, as are teenage parents. According to case managers, exemptions are not advertised; rather, if a client brings up a medical problem, the case manager gives her a state-generated form for her doctor to complete. The form has a clear list of questions that specify the nature of the client’s disability and potential for work and the length of time for which an exemption should be granted. Case managers code exemptions for the length of time specified by the doctor. Clients are granted temporary exemptions from the time they report a medical problem to the time they return the completed form.

While the process is relatively cut-and-dry for case managers, it is possible that the largely client-initiated process prevents some clients from getting exemptions. Clients might be uncomfortable discussing medical problems with their case manager, or they may be unaware of the severity of their condition. Furthermore, variation in the way doctors interpret and fill out the form as well as the relationship between clients and doctors allow room for inconsistency and potential abuse of the system.

According to state policy, exemptions can also be granted if transportation or child care is not available. However, none of the staff interviewed had ever exempted a client for these reasons. In general, only clients in remote, rural areas are exempted because support services are lacking.

Working with Cases Approaching the Time Limit

Case managers in South Carolina work closely with clients to help them achieve their employment goals. Clients sign an employment plan within 45 days of having their case certified, and case managers monitor clients’ attendance and progress in FI components. Since the new state director took office, case managers have been strongly discouraged from sanctioning clients. At one time, cases were routinely closed for noncompliance. Now, when clients miss classes or otherwise fail to comply with the program, case managers initiate an in-depth conciliation process. Case managers are expected to make telephone contact with the client, revise the client’s employment plan, conduct a home visit, and “grabclients] by the hand” to make sure that they participate. After taking these steps, a case manager must first meet with the supervisor and the county director before imposing a sanction. Case managers noted that, because of the red tape involved, they rarely sanction clients for nonparticipation.

Staff reported that they strongly discourage clients from accumulating 24 months of assistance. Rather, they encourage clients to leave assistance and forgo the earned income disregard once they are able to support themselves. Case managers tell clients that in the future banked months will be far more valuable than the paltry benefits that they will receive after their earnings are counted. Several staff maintained that a good case manager does not let a client use up all four enhanced disregard months. (In South Carolina, months in which a client receives the enhanced earned income disregard do count against the time limit.) Particularly when dealing with single mothers with young children, case managers encourage clients to leave assistance for two years (to exhaust their transitional child care benefits) and then to come back on welfare and repeat the process once they are again eligible for two more years of transitional child care.

Clients who do accumulate 22 months of assistance are required to attend a 22-month staffing to discuss their case. In one office, this meeting is the first time that clients hear about extensions. Staff in another office reported that “the word is out” about extensions and that a client knows well in advance of this meeting that the case will not be closed. Perhaps because of this, staff reported that client attendance is high for these meetings. At the 22-month staffing, extension options are discussed, and the purpose and duration of the extension are decided. Clients must sign a new employment plan at this meeting, specifying what they will accomplish during the extension period.

Until mid-2001, the client’s entire history of compliance was taken into account during this staffing. Generally, only clients who had shown a history of compliance were granted extensions. Now, all clients who are compliant at the time of the 22-month staffing are granted extensions. Compliance with the Family Independence program is the primary factor in deciding whether an extension will be granted. Ultimately, the county director has final say regarding the approval and duration of the extension, although case managers and their supervisors can make recommendations.

It is important to note that counties have relaxed their extension policies in very different ways. One county currently offers all clients 3-month extensions during the 22-month staffing. Case managers said that they had never had occasion to ask for longer extensions or to ask for an additional extension after the initial extension expired.

By contrast, staff at another office reported that most clients were offered a 6- or 12-month extension at the 22-month staffing. The general rule, according to case managers and supervisors, is that clients who have not achieved their employment goal will be granted extensions. Clients are most often granted an initial 6-month extension to complete a training program that they are currently enrolled in and are likely to complete in that time. If at the end of this time period they are still compliant, then they are eligible for an additional 12-month extension for full cooperation. The county director has the authority to grant additional extensions, and clients whose extensions are so approved meet with the county director monthly.

After the Time Limit

Case managers in South Carolina are required to conduct a home visit within 90 days of a case closure, to check on the family’s well-being. Case managers refer clients to community agencies for such matters as domestic violence and for assistance with utility bills or household items. If clients become employed, they can apply for transitional benefits. Food Stamps continue as long as the client is income-eligible.

Staff reported that, for the most part, clients are faring about as well after leaving welfare as they were while they were receiving cash assistance. No case manager had ever dealt with a client who really feared that she would not be able to get by after her case was closed. Perhaps because of the low grant in South Carolina, clients — at least according to staff — are not greatly affected by termination of their benefits.

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1Recipients who have not yet reached the 21-month point and who incur multiple sanctions — thus making them ineligible for an extension based on good-faith effort — are offered an Individual Performance Contract (IPC). The IPC program, operated by community agencies, offers recipients an opportunity to restore their eligibility for a good-faith-effort extension.(back)

2There is now an exit interview in month 58 for 60-month closures. Recipients are informed about a variety of non-welfare services, and they receive priority for certain services. Home visits are attempted for recipients who do not attend the interview.(back)

3As of this writing, the state legislature was considering extending Safety Net eligibility to individuals terminated because of the 60-month time limit.(back)

4Louisiana applies the term “exemption” for situations in which the time-limit clock stops and situations in which clients are allowed to continue to receive assistance beyond the time limit. In general, this report refers to the latter situation as an “extension.” (back)

5Families who are exempt from the time limit have their benefits paid with state funds and thus do not accrue months toward the federal 60-month time limit. For the most part, the federal time limit is invisible to recipients.(back)

6The challenge maintained that the state had to apply earnings disregards throughout a family’s time on assistance. The state argued, unsuccessfully, that extensions were a separate program with different rules from the general TANF program’s.(back)

7There are some minor differences in eligibility rules. Under Safety Net, all children and adults living in the household must be included in the case. Thus, a small number of individuals eligible for Family Assistance are not eligible for Safety Net Assistance because of the earnings of other household members.(back)

 

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