ACF: OPRE Approaching Time Limits

Chapter 4

The Implementation of Time Limits

Chapters 2 and 3 provide a broad overview of the states’ time-limit policies and experiences. This chapter delves more deeply into how time limits are implemented, focusing on eight states where substantial numbers of families have reached limits.

At first glance, the implementation of a time limit might seem straightforward — welfare agencies simply need to count months of benefit receipt and then stop the checks when the limit is reached. Complexities arise because the welfare system, in addition to preparing recipients for self-sufficiency, also continues to serve its original purpose of protecting children from severe destitution. No governor or welfare administrator wants to see large numbers of vulnerable families lose their benefits without jobs or alternative sources of support. Thus, welfare agencies try to minimize the number of families who reach time limits unprepared for self-sufficiency, and they create exceptions (exemptions and extensions) to protect recipients who are unable to achieve it despite diligent efforts.

But how do staff motivate recipients to take action when the deadline may seem far away and when other policies such as earned income disregards may send conflicting messages? How do administrators make consistent, equitable judgments about who is unable to work and who has made a good-faith effort to find a job when these concepts are inherently fuzzy and subjective? And how do agencies strike a balance between implementing reasonable safeguards and weakening the message that welfare is temporary? Clearly, examining implementation at the “street level” is crucial to understanding time limits.

The information presented in this chapter is based on interviews with welfare administrators, supervisors, and line staff in eight states. As discussed in Chapter 1, MDRC conducted limited field research exclusively for this report in five states: Georgia, Louisiana, Massachu-setts, New York, and South Carolina. The chapter also draws on separate MDRC studies in Connecticut, Florida, and Ohio.1 In all eight states, the research focused on particular cities and selected welfare offices in those cities. The findings illustrate the diversity in the implementation of time limits, but they are not necessarily representative of implementation nationwide or even throughout the eight states. Appendix B describes the field research and includes a brief profile of time-limit policies and practices in the eight states. Table 4.1 provides a quick summary of each state’s policy.

Welfare Time Limits

Table 4.1

Brief Summary of Time-Limit Policies in the States Discussed in This Chapter
State	Time Limit
Connecticut	21-month limit, with extensions 60-month lifetime limit with few exceptions
Florida	24 months in a 60-month period for most recipients 36 months in a 72-month period for the most disadvantaged 48-month lifetime limit
Georgia	48-month lifetime limit
Louisiana	24 months in a 60-month period 60-month lifetime limit
Massachusetts	24 months in a 60-month period
New York	60-month limit, followed by Safety Net assistance
Ohio	36 months followed by 24 months of ineligibility 60-month lifetime limit
South Carolina	24 months in a 120-month period 60-month lifetime limit

As Table 4.1 makes clear, the chapter mostly pertains to state time limits of fewer than 60 months. New York has a 60-month limit, but limits in the other states range from 21 months (Connecticut) to 48 months (Georgia). This is not surprising, because, as noted in Chapter 3, a large majority of the families who have reached time limits nationwide have reached shorter state time limits. But the focus on shorter time limits in this chapter means that the practices discussed may not reflect the implementation of the federal 60-month limit.

The chapter is organized around the following topics: how the time-limit message is communicated, how exemptions are handled, working with cases approaching the time limit, the extension process, and what happens after the time limit is reached.

Key Findings

Key findings presented in this chapter include:

The implementation of time-limit policies varies considerably across the eight states, and even from welfare office to welfare office within some of the states.
In trying to send a clear message, welfare staff present simplified versions of time-limit rules, typically ignoring such complexities as periodic time limits and deemphasizing the possibility that extensions may be granted.
All eight of the states grant time-limit exemptions or extensions for recipients with medical problems that limit their employability, but the processes for identifying and verifying such problems are quite different from state to state.
Welfare staff more carefully monitor a case as it begins to approach the time limit. This serves the dual purpose of targeting services to recipients who need them and assessing whether individuals are complying with program rules.
Most of the eight states grant extensions or exemptions for recipients who comply with program rules but do not have jobs when they reach the time limit. How states determine who has played by the rules varies considerably, although many states base the decision on recipients’ current willingness to comply with the program’s work requirements rather than on their past history.

Communicating the Time-Limit Message

The architects of welfare reform imposed time limits to create a sense of urgency that would motivate recipients to change their behavior. For time limits to have this effect, recipients must know about the policies and understand the consequences of reaching the time limit. This section discusses how welfare departments inform recipients about time limits and what kind of message they send.

How Welfare Departments Inform Recipients About Time Limits

Welfare agencies inform recipients about the time-limit policy and about each recipient’s status (for example, how many months of benefits have been used and how many remain). In all eight states studied, line staff discuss time limits when a parent applies for cash benefits and at various points thereafter.

Staff consistently report that recipients tend not to focus on the time limit while it is still far away, so it is critical to repeat and reinforce the time-limit message. In-person appointments, whether focused on eligibility or employment issues, present an opportunity to drive home the message. Mandated reviews may occur more frequently as recipients get closer to the time limit. In Massachusetts, “transition reviews” are initially scheduled every 6 months but become more frequent as recipients pass the 12-month mark, if they are not working or participating in an employment activity. The reviews focus on the recipient’s status vis-à-vis the time limit and her plans for supporting her family after leaving cash assistance. Such reviews are particularly important in Massachusetts, because a large share of the recipients who are subject to the time limit (that is, families with children between ages 2 and 5) do not have a work requirement.

As discussed in Chapter 2, welfare departments also use formal notices and letters to inform recipients how much time they have used and how much they have left. In Ohio and South Carolina, recipients are told how many months of assistance are remaining when they receive each benefit check and through many other notices from the welfare department. In other places, recipients receive status reports when they begin to approach the time limit. For instance, in Georgia, recipients get a system-generated notice at 12 months, 36 months, and every month thereafter as they approach the 48-month limit. In Louisiana, where there is 24-month limit, recipients get an official notice at the 18-month point. In New York, standard letters are sent at 54 and 58 months. Massachusetts officials noted that they rely less on letters because recipients’ exemption status can change frequently, making it difficult to ensure that letters are accurate.

Welfare offices also “advertise” time limits and other features of new policies through posters and banners hanging in waiting rooms and in staff offices. “The clock is ticking” is a common sight on welfare office walls and a catch-phrase used by many caseworkers. Images of ticking clocks and hourglasses have become familiar.

There are several challenges to reinforcing the time-limit message. For example, in Connecticut, MDRC’s evaluation found that staff informed recipients about the time limit at application and at redetermination appointments but had relatively infrequent contact with clients otherwise. In order to facilitate serving large numbers of people, the state’s welfare reform program was designed so that staff and recipients did not necessarily need to interact frequently, which gave staff fewer opportunities to reinforce the time-limit message.

Another challenge arises because, in many states, employment services are delivered through an array of subcontracted service providers or through the workforce development system. It can be difficult for a welfare agency to ensure a strong, consistent message when recipients may interact more regularly with staff from other agencies.

Messages That Staff Convey About the Time Limit

In discussing time limits, staff try to send a clear message that welfare is no longer an entitlement or a long-term option. In some cases, however, the complexity of the policy itself can obscure the message. Conversations with administrators and line staff revealed that, in trying to send clear messages, staff present simplified versions of the time-limit rules, commonly ignoring or glossing over complexities. For example, staff in Massachusetts, Louisiana, and South Carolina largely ignore the periodic nature of their state’s time limits, referring to the time limit as being 24 months. In Florida, some recipients can receive 36 months of benefits in a 72-month period, while others can receive only 24 months in a 60-month period.2 In addition, as noted below, recipients are eligible to “earn back” months on their time-limit clock. Caseworkers in Miami stick to a general message that welfare is limited; they would have to make a manual calculation to figure out how many months of benefits remain for a particular client.

Staff may oversimplify to such a great extent that recipients are not aware of the benefits that they can receive. For example, in Massachusetts, advocacy groups started a publicity campaign to inform recipients and former recipients that 60 months had elapsed since the imposition of the state’s time limit (24 months of receipt in a 60-month period) — meaning that recipients’ 24-month clocks could be reset to zero.

The interaction between state and federal time limits can also cause confusion. In Con-necticut, recipients are informed of their status in relation to three different time-limit counters — the state 21-month limit, the state 60-month limit, and the federal 60-month limit. The three counters may be different because, for example, some recipients are exempt from the state time limits during months in which their federal clock is running. Also, the state 60-month time limit counts months of receipt since October 1996 (when TANF was implemented), while the state 21-month counter began as early as January 1996, when the state’s waiver program began.3 In most of these states, however, the federal time limit was largely invisible to recipients and line staff. Officials in the state central office track months of federally funded benefits, but the shorter state limit is emphasized in interactions with recipients.4

Sometimes, simplified language can have unintended side effects. For example, in At-lanta, caseworkers said that they tell recipients, “TANF is a four-year program.” Similarly, in Florida’s Family Transition Program (FTP), some staff told recipients the date — two or three years in the future — by which time they would need to leave welfare. MDRC found that formulations like these may lead some recipients to adopt the time limit as their personal schedule for leaving welfare, rather than trying hard to leave earlier.5

Messages about benefit extensions. Although written materials usually explain all rules about time limits, staff in most of these eight states avoid discussing the possibility of extensions until recipients are very close to the time limit. Many workers believe that talking about extensions will undermine recipients’ motivation and sense of urgency. As one Massachusetts caseworker put it, “Talking about extensions would defeat the purpose of the time limit; extensions are supposed to be for emergencies.” In Florida’s FTP, extensions were discussed so infrequently that many recipients did not know they were possible.

Ultimately, however, messages about extensions will inevitably be shaped by the way that the extension policy is implemented. When a time limit is first imposed and no one has reached it, both staff and recipients are uncertain what will happen (that is, who or how many people will be allowed to continue receiving benefits after they reach the time limit). Many states — perhaps intentionally — do not finalize their procedures for families reaching the time limit until just before the first group reaches it, so staff do not know which rules will apply. During this early period, a message that deemphasizes extensions is credible. In fact, some Con-necticut staff reported that they thought it would be unfair to lead recipients to believe that they would receive extensions, because staff themselves did not know whether this would be the case.

After families start reaching the time limit, the grapevine takes over, and staff must adapt their message to the reality. This happened in New Orleans. Staff initially warned that the clock was ticking, but as word spread about the extension policy, they stopped using “the clock” as a threat. Now they try to send the message that “it gets complicated after 24 months,” implying that recipients should get off assistance before then. Similarly, in Connecticut, it would not be credible to tell recipients that extensions to the 21-month time limit are rare, because most recipients undoubtedly know that extensions are quite common.

Messages about banking months of eligibility. Many believe that welfare staff should counsel recipients to leave the rolls as quickly as possible to save, or “bank,” some of their months of assistance for the future. This message can be difficult to sell, however, because many recipients feel that they have few alternatives to welfare in the short term. Expanded earnings disregards further complicate the banking message. To benefit from an expanded disregard, a recipient needs to stay on welfare after finding work. Should staff urge recipients to take advantage of disregards by combining work and welfare? Or should they urge clients to bank their remaining months of eligibility by voluntarily leaving welfare? The approaches taken by staff reflect the particular characteristics of policies in each state.

In Connecticut, the financial incentives to work are unusually generous. Recipients can earn up to the federal poverty level and receive the full grant amount ($543 for family of three). This leads Connecticut staff consistently to recommend that recipients use the disregard. A banking message would not be credible when recipients would have to give up such a large sum of money in order to leave welfare while still eligible. In Louisiana, during the first 24 months — when recipients work and are eligible for a temporary $900 disregard — their time-limit clocks stop. This policy eliminates the dilemma; staff can market the disregard because there is no downside for recipients.

In other states, staff are much more likely to urge recipients to bank months of eligibility in case they face a later emergency — essentially ignoring the disregard. In Charleston, South Carolina, case managers discuss the pros and cons of the disregard but encourage recipients to opt out of welfare whenever they have a job that allows them to support themselves, rather than taking advantage of the disregard. Similarly, Atlanta staff said they tell recipients to save their months in case of an unforeseen problem down the road. Staff appear more likely to emphasize saving months of eligibility when a recipient is working and receiving only minimal TANF benefits (especially if she also receives child support payments regularly) or when the recipient has only a few months left before the time limit. New York City recently instituted a pilot program, discussed below, that gives working recipients bonus payments for closing their welfare cases before reaching the time limit.

Messages about education and training. Policies that emphasize quick entry into the labor market (often called “work-first policies”) limit recipients’ opportunities to attend education and training programs. Nonetheless, where the option is available, staff must decide whether to encourage recipients to seek short-term training that might help them get better jobs or to try to find a job and leave welfare quickly to stop the time-limit clock. In most states, staff stress the work-first message rather than advising recipients to use their time on welfare to upgrade their skills. This is consistent with the overall philosophy of the states’ welfare reforms.

For selected groups, however, some states do advocate training or education, particularly early in the time-limit counter. Caseworkers in Cleveland said that they encourage recipients who lack a high school diploma or General Educational Development (GED) certificate to obtain more education or training before looking for a job. Staff in Massachusetts said that they urge clients who have children between ages 2 and 5 —recipients who are exempt from work requirements but subject to the time limit — to take advantage of the opportunity to further their education. Nevertheless, local advocacy groups continue to question the state’s commitment to education and training. Many Massachusetts staff said that they would support a greater emphasis on training and education, since the time limit eliminates the possibility that recipients will stagnate in such programs for long periods. Staff in Florida’s FTP placed a fairly heavy emphasis on education and training, particularly during the program’s early years; they believed that the time limit magnified the importance of finding well-paying jobs.

Exemptions from Time Limits

As discussed in Chapter 2, many states exempt recipients from time limits when they are disabled, caring for a disabled household member, caring for a young child, pregnant, victims of domestic violence, or qualify for other reasons. While some of these circumstances (for example, pregnancy and a child’s age) can be easily identified and validated, complications arise with exemptions for medical issues or other hardships, which are inherently less clear-cut. Are recipients identified as needing an exemption through in-depth assessments or clients’ own reports? What review mechanism is in place so that situations are handled consistently across different workers and offices? What is the process for obtaining such as exemption, and how do states balance the need for accurate information with the need to develop a process that is not too burdensome for recipients with serious problems?

Not all states suspend time-limit clocks through exemptions. States with no or few time-limit exemptions, like Georgia and New York, let the clock run for individuals with medical or mental health problems, though these recipients may be exempt from work requirements (these states still need to determine who qualifies for an exemption from work programs). The theory is that, without the possibility of an exemption, every recipient feels pressure to move toward self-sufficiency. These states implement safeguards through their extension policies when recipients reach the time limit.6

Identifying Recipients with Medical Problems

States that allow time-limit exemptions for medical problems that affect employability use different approaches to identify the recipients who are experiencing such problems. In most of the states that were visited, staff routinely review the exemption reasons and ask recipients if any of them apply. For example, at each transition review, Massachusetts caseworkers ask, “Are there health issues including drug or alcohol use that are preventing you from finding a job?” For the most part, however, staff rely on recipients to self-report their problems; most agencies do not proactively assess whether recipients have particular health problems that may prevent them from working.

One might assume that recipients with medical problems would report them, but the reality is more complex. Staff report that stigma, fear, and lack of knowledge make some recipients reluctant to discuss health problems, particularly mental health issues. Similarly, many parents will not report their substance abuse problems for fear of losing their children to the child welfare system. One New Orleans worker who runs a two-week job-readiness training program commented that “a lot of barriers are not readily apparent until you deal with the person day after day.”

Welfare staff are usually not trained to recognize such problems, and they typically do not spend much time with each client. A supervisor in Massachusetts noted that “some workers are better than others at getting clients to admit problems.” As a result, certain kinds of problems may slip through undetected. Special post-time-limit outreach programs, discussed below, sometimes encounter recipients who should have been exempted but instead had their benefits terminated. Difficulties in identifying recipients with serious barriers to employment have existed as long as states have had work requirements, but the stakes are higher now that people with severe problems risk losing benefits when reaching time limits.

It is difficult to assess the magnitude of this problem, but some client advocates see it as a serious issue. In both Connecticut and Massachusetts, the state TANF agencies have been criticized for not being proactive enough in identifying recipients’ barriers to employment, even though about one-half (Connecticut) to three-quarters (Massachusetts) of the welfare caseload are exempt from the time limit.7 Critics believe that the states should conduct more thorough assessments of recipients’ limitations well before they approach the time limit.8

Line staff acknowledge that a small number of recipients may fall through the cracks but contend that they have few options when a recipient is unwilling to reveal a problem or does not follow through with the exemption process. Administrators may be reluctant to devote scarce resources to in-depth assessments that do not necessarily provide reliable information about recipients’ functional limitations; they argue that the best way to assess whether problems exist is to see how recipients perform in required work activities.

Some agencies conduct assessments to uncover barriers to employment. For instance, in Cleveland, welfare staff use an hour-long conversation to determine clients’ job-readiness and issues concerning housing, medical care, clothing, food, substance abuse, and social support. Elsewhere, recipients are referred to outside agencies for assessment. Although Georgia does not grant exemptions, many cases in Atlanta are referred to the vocational rehabilitation department for a thorough assessment of medical and mental health. New York City administers a substance abuse screening questionnaire to all welfare applicants. If the responses indicate a potential substance abuse problem, the individual is referred for additional evaluation and, if appropriate, to a treatment provider.

The Process for Getting a Medical Exemption

In an effort to prevent the abuse of exemption policies, the states that were studied require various levels of documentation to verify medical disability claims. In South Carolina, a doctor’s statement is sufficient. Elsewhere, however, a central review process is required. For instance, Massachusetts and New York contract with outside vendors to review doctors’ statements, and recipients may be required to see another doctor before their exemptions are granted. This process, designed to ensure consistency and minimize fraud, can take a long time to complete. In Connecticut, caseworkers can grant some short-term exemptions, but longer-term exemptions must be approved by a centralized medical review team. In New Orleans, one staff person (not a doctor) reviews all requests for medical exemptions in the region.

Critics point out that the same issues that prevent some recipients from working steadily also make it difficult for them to navigate complex, multistep exemption review processes. Again, mental health problems are most likely to present a problem: Many recipients with mental health problems have not been receiving medical care and do not enter the exemption review process with a physician’s statement. As a result, they may be required to see a psychologist or other specialist as part of the process. By virtue of their condition, some of these individuals have difficulty keeping appointments, and so their medical exemption may be denied for failing to follow through.

Medical exemptions usually remain valid for a specific length of time. For short-term medical issues, the doctors or the review vendor determine the duration of the exemption. Staff judge some recipients to be so disabled that they will never be employable, and they and may refer such clients to a specialized worker or agency to help them navigate the eligibility process for Supplemental Security Income (SSI).

Working with Cases Approaching the Time Limit

Though time limits are intended to motivate recipients, they also increase the pressure on states to design effective welfare-to-work programs. If more recipients find employment and leave welfare, fewer families risk being cut off at the time limit. Time limits also increase the pressure on the welfare staff who are responsible for preparing clients for the time limits. As a time limit draws near, staff make special efforts to engage recipients in welfare-to-work programs, and they carefully monitor participation. These intensive efforts serve two purposes: They target services to recipients in need, and they also provide evidence about whether recipients are willing (and able) to comply with work-related requirements.

Linkages with Welfare-to-Work Programs

Welfare staff work to link clients with employment services from the time they first come onto welfare, but staff generally renew the pressure when clients get close to the cutoff point. Some localities rely on the same employment service options for new recipients as for those nearing the time limit, while others have established special programs for recipients at risk of reaching the limit. In New York City, cases that reach the 48-month point are transferred to a special unit of staff who handle both eligibility and employment functions in order to ensure that these cases receive focused attention.9 In Florida’s FTP, recipients who were approaching the time limit and were unemployed were referred to special job developers who worked very intensively to help people find jobs. In New Haven, Connecticut, all recipients who reached the 16-month point were offered assistance from social work staff.

Automated computer systems in all states track the months of cash assistance receipt, and staff can quickly access this information. In some places, however, staff commented that the system was not always correct, and so they manually performed a double check for clients nearing the time limit. To focus additional attention on recipients close to the time limit, some administrators generate lists of such cases and then require supervisors or line staff to report on the status of each recipient.

According to one office manager, strict reporting requirements for recipients in the months surrounding the time limit take up the majority of her time. Staff confirmed her assessment. The increased workload attributed to time limits drove the redeployment of staff in several welfare offices. Two New Orleans welfare offices recently created a specialized position to handle the work requirement and the time-limit functions without being responsible for eligibility issues. Even staff in these specialized positions expressed frustration with the complexity of the rules — specifically, with the different criteria for exempting cases from time limits as opposed to work requirements.

Sanctions

Increased monitoring may increase the likelihood that sanctions will be imposed on recipients who do not abide by participation mandates. Many states impose full-family sanctions after one or more instances of noncompliance with work requirements. Families cut off because of full-family sanctions stop accumulating months toward the time limit (unless they subsequently return to welfare). Miami has sanctioned large numbers of cases for failing to comply with work requirements, and many more people there have lost benefits as a result of sanctions than because of the time limit. In Atlanta, case managers said that they are more lenient in the early months, more willing to give recipients several chances to comply. Closer to the time limit, however, they become quicker to sanction. In some states, frequent full-family sanctions are a key reason why few families have reached time limits. While much attention has focused on families reaching time limits, sanctions are likely to occur out of the spotlight, as part of the day-to-day operations of the welfare office.10

Some states have deemphasized sanctioning. In South Carolina, when a new welfare director took over in 1998, she sought to decrease the state’s previously high sanctioning rate by implementing a system of extensive conciliation. Case managers are expected to call clients, revise their employment plan, and make home visits to engage the clients in the program. After taking those steps, case managers must meet with their supervisor and with the county director before imposing a sanction.

The Pre-Time-Limit Review

Chapter 2 notes that most states conduct a formal review of recipients’ status just prior to the time limit. One purpose of the review is to make sure that recipients understand that their cash grant will end unless they meet certain criteria or, where necessary, apply for an extension. Staff may also use the review to determine which recipients qualify for an exemption or extension. In Cleveland, recipients are required to attend an extensive and structured review six months before the time limit. A key focus of the interview is to determine whether families have a realistic plan and will have sufficient income after their cash grant ends. At the end of the meeting, recipients write in their own words how they plan to support their family when they reach the time limit. In Massachusetts, a similar purpose is served by the final transition review, which is conducted just before the time limit.

As discussed below, the pre-time-limit review meetings may also be part of the extension process. In Connecticut, recipients who fail to attend an “exit interview” have their case closed at the time limit because they have not requested an extension (the exit interview also serves as a redetermination for Food Stamps and Medicaid). In New Orleans, staff invite recipients to a review meeting two months prior to their time limit, but attendance is not mandatory. Possibly because staff do not meet with every recipient, they do not always determine whether someone reaching the time limit qualifies for an extension. Nonetheless, these recipients continue receiving benefits. Staff must enter a particular code to stop benefits at the time limit. In other states, the computer system automatically stops benefits at the time limit unless an extension code is entered.

Meeting with each recipient as the time limit approaches imposed great burdens on staff when large groups of recipients all reached the time limit concurrently. In Massachusetts, approximately 5,000 recipients reached the time limit at the same time in late 1998. Staff in one office remarked that when the first cohort of recipients reached the time limit, the entire office devoted its resources toward approving or denying extension requests. In retrospect, state officials would have preferred to phase recipients into the time limit more gradually. New York City set up a special centralized process to handle thousands of cases approaching the time limit in December 2001; recipients were required to file a brief application in order to transition to the post-time-limit Safety Net program. Press reports suggested that many recipients fell through the cracks and failed to make the transition; city officials report that about 90 percent of nonex-empt cases were converted to the Safety Net program.

Benefit Extensions

Extension decisions exert tremendous influence on the outcomes of time-limit policies. If many people get extensions, it may reduce the effectiveness of time limits in motivating others to get a job and leave the rolls. If extension rules are too stringent, vulnerable families may lose benefits and suffer as a result.

As discussed in Chapter 2, states have quite different approaches to extensions. Among the states discussed in this chapter, Connecticut, Florida, and Georgia grant a relatively large number of extensions, while Ohio closes most cases that reach the time limit. South Carolina and Massachusetts initially denied most extension requests, but both states report that they are now much more likely to grant extensions. Louisiana closes many cases because of the time limit often because the recipient fails to comply with work requirements after reaching month 24 but it appears that many of these families subsequently return to welfare.

The extension review processes are also quite different. Some states, including Con-necticut and Massachusetts, require recipients to formally request an extension. In others, each case is automatically considered to see if it qualifies. South Carolina now grants an extension to all recipients who are deemed to be compliant with the program just before reaching the time limit.

Recipients Who Are Working When They Reach the Time Limit

Some states have found that a large proportion of the recipients who reach their time limits are employed and benefiting from expanded earnings disregards. States differ in their approaches to these recipients. Connecticut’s generous disregard allows recipients to earn up to the federal poverty level without any corresponding decrease in cash grants. When recipients reach the time limit, if their income is equal to or greater than the cash grant amount, they are ineligible for an extension. Massachusetts initially used this approach, contending that the expanded disregard should not apply after the 24-month point. However, a court ruled that the disregard must be applied after the time limit, so that recipients cannot be denied an extension based on their earnings. Now, recipients working full time are automatically granted an extension. Those working part time, however, must also participate in a job search program to demonstrate that they are seeking full-time employment, and they are much less likely to receive an extension.

New York City is testing an innovative approach for employed recipients. The welfare agency has created a bonus program targeted to individuals who are working at least 20 hours per week (and have been for four months) and receiving cash assistance. Recipients who voluntarily close their TANF case receive a monthly cash payment of $200 for one year. Recipients benefit both because the bonus is likely to exceed their TANF grant and because they save their remaining months of eligibility. From the state and city perspective, the bonus is considered “nonassistance” and does not count against the federal time limit. Although open to any recipient who meets the criteria, the bonus program is actively “sold” to employed recipients approaching the 60-month time limit.

Florida rewards recipients who find employment by allowing them to “earn back” one month of benefits for each month of unsubsidized employment (up to 12 months). Over time, this has been expanded to include public sector or subsidized employment. In practice, however, this policy has been difficult to administer, mainly because the state’s welfare computer system is not set up to account for the credit, so that recipients’ clocks must be manually adjusted.

Recipients Who Comply with Program Requirements

In some ways, the extension decision is more important when a recipient is not employed upon reaching the time limit. As discussed in previous chapters, many states make an allowance for recipients who make a good-faith effort to comply with program mandates or to seek and retain employment but are unsuccessful.

States define “good faith” or “compliance” in various ways. Connecticut considers a recipient’s past conduct and has a clear definition of compliance. Those who have fewer than two employment services-related sanctions and who have not quit a job without good cause in the prior six months are deemed compliant. Connecticut also allows clients who have been sanctioned twice to restore their eligibility for an extension by complying with a special Individual Performance Contract. In practice, almost all recipients who reach the time limit without a job are deemed to have made a good-faith effort and are granted at least one 6-month extension. Essentially, they are given the benefit of the doubt, even if their participation was not closely monitored during the prior months. Florida’s FTP also assessed compliance based on past performance, but there was no explicit definition of compliance; in that case, almost everyone who reached the time limit without a job was deemed noncompliant and had his or her benefits terminated.

Other states, such as Georgia and Louisiana, emphasize current or future willingness to comply as a condition for granting extensions. In these states, recipients willing to participate in an employment services program are granted extensions. One Atlanta office manager commented that staff put a lot of effort into not closing cases. Recipients are given an opportunity to comply and enroll.

The Massachusetts extension policy calls for caseworkers to consider the recipient’s work history and participation record and whether the recipient has cooperated with the department’s rules and regulations. Policymakers hoped that this approach would keep recipients motivated, because no one was assured of getting an extension. When a recipient requests an extension, the caseworker prepares an extensive review of the recipient’s case history. But staff report that, in practice, what matters most in the extension decision is the recipient’s willingness to attend a structured job search program at the end of the time limit. One manager remarked that, to get an extension, “all that matters is what they are doing now.” Staff express surprise that many recipients do not request extensions. Some speculate that such recipients may not want to attend the structured job search program because they do not believe it will help them; staff also believe that clients who do not request extensions usually have unreported income or family supports.

New York has a 60-month time limit on cash benefits, but compliant individuals can continue receiving benefits beyond this point through the state’s Safety Net assistance program; Safety Net benefits are paid only partly in cash. In order to transition to the Safety Net, recipients must complete an application for the program prior to month 59 of benefits.

New York does not have full-family sanctions, so sanctioned cases still receive partial grants. New York City’s process for transferring these noncompliant cases to the Safety Net program attempts to force them to comply: All sanctioned recipients citywide are scheduled for an appointment at the central headquarters of the fraud division in Brooklyn (the appointment can be rescheduled if the recipient is unable to attend at the scheduled time). Recipients who show up for the appointment encounter a lengthy, multistep process that begins with an interview with a fraud investigator that focuses on how the recipient is supporting herself on reduced benefits. The next step is an interview with a substance abuse counselor to determine whether substance abuse is a hidden reason for noncompliance; if so, the recipient is referred for treatment. Lastly, if the recipient agrees to comply with work requirements, she is seen by a caseworker to receive her work assignment and file a Safety Net application.

A substantial number of recipients do not attend the appointment at all, which makes them ineligible for the Safety Net. Initially, recipients were offered subsidized jobs at the end of this process, and those who refused the jobs were not allowed to move to the Safety Net program. The city eventually exhausted all the subsidized jobs, so now recipients must cooperate with a job placement vendor in order to make the transition.

Supervisors and staff in most of the states acknowledge that there is subjectivity involved in the extension decision process and that different workers may interpret the same information differently. This is particularly true when terms like “compliance” and “good-faith effort” are not specifically defined in policy. Because the consequences of denying an extension are so serious, some states have developed review processes to try to ensure that the decisions are appropriate and consistent. In New Orleans, case managers can extend benefits for some reasons on their own, but issues such as “job factors are unfavorable” require supervisory approval. In Massachusetts, line staff make recommendations regarding extensions, which are subject to review by office directors, who actually authorize extensions. Initially, office directors’ decisions were then reviewed by administrators in the regional and central offices. This extensive review process was established to ensure uniformity. Over time, administrators came to feel more confident that cases were being handled consistently, and they eventually eliminated the regional and central office reviews. Florida’s FTP, which never defined “compliance,” used an unusual Review Panel of volunteers from the community to review decisions about benefit termination, although, in practice, the panel generally followed the recommendations of staff.11

In contrast, in Connecticut, where “good-faith effort” is more clearly defined, caseworkers can generally make the extension decision without extensive review.

Other Extensions

In addition to granting extensions based on personal factors, some states have policies that allow extensions based on general conditions such as the availability of jobs or child care slots. To date, these criteria have not been widely used, even though the site visits were conducted during an economic downturn. New Orleans staff did say that occasionally recipients have received extensions because “factors relating to job availability are unfavorable as determined by the case manager’s evaluation of the individual.” For example, a person facing an insurmountable language barrier might gain an extension on this basis.

After the Time Limit

States that grant many extensions have developed special procedures and policies for recipients in extensions. Several states have also developed special outreach programs for recipients whose benefits are terminated because of time limits.

What Happens During an Extension

Individuals usually receive extensions on the condition that they comply with employment-related requirements. Extensions are usually granted for a finite period — usually a few months — but typically may be renewed. Staff in many offices say that they do not conciliate with recipients in an extension; if clients fail to cooperate, they are cut off. In these instances, it may be difficult to determine whether cases are closed because of noncompliance with the work requirement or because of the time limit. For example, in Connecticut, a recipient whose case is closed for noncompliance during an extension is not considered to have been closed due to the time limit. However, if someone is denied an extension for the same reason, it is considered a time-limit closure. One manager in New Orleans noted that the data system includes separate case closure codes for noncompliance and time limits, but said that either code is appropriate for many clients.

In some cases, welfare offices enjoy considerable latitude in enforcing extension conditions. For example, one office in New Orleans sends letters highlighting one way to maintain benefits. Recipients must make 20 job contacts each month. The letter provides a month-by-month schedule for completing the contacts. In contrast, staff in another office do not “advertise” the independent job search route to an extension, preferring to assign recipients to an employment-related work activity.

Recipients can sometimes get more than one extension. In South Carolina, two counties have very different approaches to multiple extensions. In one county, recipients were generally restricted to one 3-month extension; in another, recipients typically received a 6- or 12-month extension upon reaching the time limit, and they often received additional extensions after that. Where generous extension policies are in effect, staff often felt that they lost credibility with recipients because, as noted by one case manager in New Orleans, when welfare reform began, they had said to them, “You need to do thisget a job] or you’ll be out of luck,” but “nowclients] see there are no teeth in that threat.”

What Happens When Cases Are Closed

Return to welfare. It is sometimes possible for individuals to return to welfare after their cases are closed at a time limit. Sometimes, if they seek reinstatement quickly and are willing to comply, staff simply reinstate their benefits. If more time elapses, they must return through the intake unit, complete a new application, and show that they qualify for an extension. In New Orleans, handing in evidence of 20 job contacts during the application period allows benefits to be reinstated. Several staff commented that there are recipients who cycle through the system, complying long enough to get a few months of benefits before they are caught out of compliance again.

In Atlanta, a few individuals who had used up their 48 months of benefits and had been working returned to assistance because they lost their jobs. One administrator thought that these individuals could receive benefits under the “incomplete workplan” extension criterion if they entered an employment program. State officials thought otherwise and are not allowing these individuals to return to the rolls.

Connecticut’s policy explicitly states that recipients can apply for extensions at any time — upon reaching the time limit or after being cut off. Thus, a recipient who is denied an extension because her income is above the welfare payment standard and who then experiences an involuntary drop in income several months later can apply for an extension at that point. However, MDRC’s evaluation found that few of the recipients who were denied extensions ever returned to the rolls; a survey found that relatively few of them were aware that they could receive benefits again in the future.

Eligibility for other benefits. Although staff say that families who are cut off of cash assistance because of time limits usually continue to receive Food Stamps and Medicaid, practices differ from state to state. In Massachusetts, Medicaid continues and Food Stamps continue for at least one month, and then recipients must be recertified. Often, if former recipients become employed, they can apply for transitional services. In Cleveland, staff try to make sure that families continue to get Food Stamps and Medicaid by explicitly telling recipients about the availability of those benefits during the pre-time-limit review meeting. In Connecticut, recipients who were reporting earnings at the time of case closure are automatically moved to the transitional Medicaid category.

As discussed in Chapter 6, several studies have found that individuals who leave welfare because of time limits are more likely than other leavers to continue receiving Food Stamps and Medicaid after exit — regardless of whether they are working. It may be that the extensive pre-time-limit processes end up informing most of these clients about their continuing eligibility for these benefits. Other leavers are more likely to exit welfare without any contact with the welfare office, which may result in closure of all of their public assistance case.

Special post-time-limit outreach programs. Especially in states providing low cash grants, staff tend to assume that most noncompliant recipients had other sources of income all along and to think that people are faring about as well after time limits as they were while on welfare. Nonetheless, out of concern for families’ well-being, some welfare agencies attempt to contact the families. These small-scale programs offer either referrals to community agencies or help finding a job, and they make sure that the families are getting other benefits to which they may be entitled. Examples of such efforts to provide support to families after the time limit include the following:

South Carolina case managers conduct a home visit within 90 days of case closure, and they refer individuals to community agencies for help with domestic violence or with such basic needs as paying utilities.
Massachusetts contracts with the Department of Public Health to conduct outreach to closed cases. Part of this outreach involves “marketing” Food Stamps. The Department of Public Health reportedly has a good reputation in the community and is perceived as an advocate for clients.
Cuyahoga County, Ohio, offers families who reach the time limit (without employment) two options. One is a pay-for-performance job search program, and the other is short-term transitional assistance (STTA), generally limited to three months, for those with medical disabilities, those who are pregnant, or those in the process of applying for SSI. (The STTA provision could be characterized as a benefit extension, but local staff do not refer to it in that way.)12
Connecticut contracts with nonprofit organizations to operate a Safety Net program targeted to recipients who are denied extensions (or are terminated from welfare during an extension) because they had not complied with their participation requirement; these individuals left welfare with income below the welfare payment standard. A key focus of the program is on helping recipients find jobs, although the program can also offer vouchers to pay for necessities.

In both Connecticut and Massachusetts, the post-time-limit outreach programs sometimes identify former recipients who qualify for exemptions; these individuals may end up back on welfare. Critics argue that this demonstrates that recipients with serious problems are slipping through the cracks and having their benefits canceled inappropriately. Although the critics express support for the outreach programs that uncover these problems, they maintain that welfare agencies should try harder to find such problems before, rather than after, benefits have been canceled.

1Specifically, the chapter includes information from the following MDRC studies: The Project on Devolution and Urban Change (Cuyahoga County, OhioCleveland], and Miami, Florida); the Jobs First Evaluation (Manchester and New Haven, Connecticut); and an evaluation of Florida’s Family Transition Program (FTP), a pilot program that operated in Escambia County (Pensacola) from 1994 to 1999.(back)

2Recipients who qualify for 36 months out of 72 include custodial parents under age 24 who have not completed high school or who have no work experience and recipients who received assistance for at least 36 of the last 60 months.(back)

3Both of the state counters have direct relevance to recipients (the state 60-month limit allows fewer exceptions than the 21-month limit). The state decided that recipients should be informed about their status with regard to the federal counter because this information could affect their eligibility for assistance if they move to another state.(back)

4In both Massachusetts and South Carolina, months in which a recipient is exempt from the state time limit are also not counted toward the federal time limit. A pre-1996 waiver program still applies in South Carolina, and Massachusetts uses state funds to pay for benefits in months when a recipient is exempt.(back)

5For example, in the FTP evaluation, MDRC conducted a small-scale survey just after people were randomly assigned to either the program or the control group and asked them how long they expected to stay on welfare. Program group members were quite likely to give a response that matched their time limit, while control group members often predicted they would get off welfare sooner.(back)

6Exemptions and extensions can have very different implications for a recipient whose status changes. Consider someone who is disabled for 23 months, healthy for 1 month, and then reaches a 24-month time limit. If exemptions for incapacitation were available, she would have 23 months remaining on her clock. If not, she would be at the time limit and, presumably, ineligible for an extension based on incapacitation — although she would likely not have obtained services to help prepare her for self-sufficiency.(back)

7These figures include child-only cases. Among cases with an adult, about a third are exempt in Connecticut, and over half are exempt in Massachusetts.(back)

8In a related case, the U.S. Department of Health and Human Services Office for Civil Rights found in 2001 that the Massachusetts TANF agency does not adequately screen welfare recipients for learning disabilities or provide appropriate services for such recipients.(back)

9Although recipients are generally not terminated from welfare at New York’s time limit, they are shifted to a program that is entirely state- and city-funded; thus, there is a strong fiscal incentive to help recipients exit from welfare before reaching the 60-month point.(back)

10See Pavetti and Bloom, 2001.(back)

11A recent report on the Wisconsin Works (W-2) program documents that when extensions are granted on a case-by-case basis, as they are in Wisconsin, this can take considerable amount of time by staff. Extension requests receive considerable review at many levels. This in-depth review process has been possible because few people have applied for extensions (Gooden and Doolittle, 2001).(back)

12Even though large numbers of recipients in Cleveland lost benefits as a result of time limits, few took advantage of these programs In the first six months after recipients began reaching the time limit, approximately 3,000 families had their cases closed because of the time limit; only 256 participated in the transitional job search program, and 135 were approved for short-term transitional assistance.(back)

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