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Appendix A: Study Site Summaries
SUFFOLK COUNTY, NEW YORK
A. Local Site Characteristics
Suffolk County occupies the eastern two-thirds of Long Island, New York. The county is home to about 1.5 million people, of whom about 88 percent are Caucasian, 8 percent African American; the remaining population represents a mix of races. Suffolk County is the leading agricultural county in New York despite substantial development and urban sprawl. The economy is fairly strong—job opportunities are abundant and unemployment is relatively low (3.7 percent).
B. TANF Program Administrative Structure and Staffing
Administrative structure. In New York, the Office of Temporary Disability Assistance (OTDA) operates the TANF program. At the county level, the Suffolk County Department of Social Services (DSS) determines TANF eligibility, and the Suffolk County Department of Labor (DOL) is responsible for providing and monitoring all employment services. DSS and DOL staff are housed within specialized units that reflect each step in the TANF service delivery process (e.g., eligibility, client services, tracking, noncompliance, and so forth). Clients progress from one unit to the next.
Staff involved with sanctions. Workers in the DOL monitoring units identify non-participants and refer them to the noncompliance unit. Workers in the noncompliance unit review referred cases and send them to the DSS compliance unit if they do not comply. Workers in the compliance unit conciliate with clients and impose or rescind sanctions. A mediator participates in all conciliations.
C. Use of Sanctions
State and local staff agree that sanctions are not beneficial to anyone—they hurt the client by limiting the amount of assistance for the family and hurt the county and state by reducing their work participation rates. The county’s philosophy with respect to sanctions is changing in accordance with a shift in the state’s philosophy. The county used to be particularly rigorous about imposing sanctions swiftly for noncompliance with program requirements. In response to the DRA, however, the county has taken a “kinder, gentler” approach, affording more leniency to clients to avoid sanctions. In particular, the county has instituted a “one strike” rule that enables staff to accept—one time only--a good-cause excuse for noncompliance without requiring any documentation from clients.
D. Work Requirements and Related Policies
Applicant work requirements. DSS refers all applicants it deems immediately employable to a co-located DOL counselor/technician for enrollment in job search while the TANF application is being processed. Failure to conduct job search may result in denial of the application. The county recently began requiring this up-front job search in an effort to ensure that clients are already in countable activities when their TANF cases are opened.
Screening and assessment. Immediately after intake, a DSS employability worker uses a nine- page assessment form to determine whether the applicant is immediately employable or in need of additional assessment. In addition, the worker conducts reviews with TANF clients every six months to assess their continued employability, identify any new limitations that may have arisen, and make referrals for more in-depth assessment as necessary. The employability worker refers all clients who are not immediately employable to a private contractor, which conducts more in-depth physical health, mental health, and substance abuse assessments. Compliance with all assessments is a condition of TANF eligibility.
Exemptions from work requirements. Approximately one-third of the families on the TANF caseload are exempt from work requirements.
Program expectations. TANF clients participate primarily in unsubsidized employment or work experience as their primary activity (typically 25 or more hours per week) and vocational education or job search (15 or fewer hours per week) as their secondary activity. However, clients may participate in work experience for no more than the number of hours equal to their TANF benefit divided by the minimum wage, which is $6.75 in New York.
E. Sanction Process
Identifying non-participation. Each month, DOL monitoring unit workers receive attendance sheets from service providers and pay stubs from employed clients. The monitoring unit workers then enter the information into a centralized database. Monitoring unit staff identify non-participants from participation reports or rely on providers to contact them directly if clients do not participate. When monitoring unit workers identify clients who are not meeting program requirements, they initiate the sanction process by transferring noncompliant cases to the DOL noncompliance unit.
Addressing non-participation. DOL counselors/labor technicians notify the DOL noncompliance unit of clients’ noncompliance. The DOL noncompliance unit prepares a letter to clients notifying them of their noncompliance and the potential effect of a sanction on their benefits and requesting them to contact the DSS compliance unit within 10 days. The DOL noncompliance unit provides the letter to the DSS compliance unit, which mails the letter to clients. The DSS compliance unit schedules a meeting with those clients who contact the office within 10 days. A compliance unit examiner and a mediator (who holds the title of caseworker) attend the meeting with clients. The meeting allows clients to present their side of the story and evidence of good cause. Issues that typically arise during conciliation meetings include lack of knowledge about program requirements (i.e., clients did not receive an appointment letter in the mail, especially if residing in a shelter), change of residence, transportation problems, child care problems, and medical appointments.
Imposing a TANF sanction. If clients fail to respond to the letter within 10 days, the DSS compliance unit follows procedures to impose a sanction electronically on the 11th day. DSS compliance unit staff also rescind or impose sanction for all clients who attend their conciliation meetings.
F. Reversing a Sanction
Appeals process. Clients must call, email, or write to the state to request a fair hearing. State staff then notify local fair hearing representatives and schedule a hearing date and time. Compliance examiners assemble a package for the fair hearing staff with a summary of the case and all relevant documentation. Local fair hearing representatives often schedule a conference with the client, the representative, and the compliance unit examiner to try to establish good cause before the hearing even though the conciliation period has expired. If the case cannot be resolved, an administrative law judge listens to the case and provides a decision in writing within an average two to three weeks after the hearing.
Cure requirements. DSS workers reverse sanctions for all sanctioned clients who have remained in sanction status for the required minimum period of time and either attended an assessment meeting with a DSS employability worker or attended a meeting with the DOL labor counselor/technician to review and amend the client employability plan.
Efforts to re-engage sanctioned clients. Suffolk County operates three initiatives to attempt to re-engage clients in program activities. First, the county contracts with the Education and Assistance Corporation (EAC) to meet with clients in a first sanction through the Sanction Intervention Project. Second, the county uses the Special Investigation Unit (SIU) within the DSS Client Benefits Unit to investigate cases of clients in a second or subsequent sanction through the Eligibility Verification Review. Third, the county recently contracted with EAC to work with clients in second or subsequent sanctions for whom SIU has identified no fraud and a willingness to comply. EAC is conducting in-depth assessments with these clients and referring them to a temporary employment agency for placement into an unsubsidized job.
Contact information:
Kimberly Staab
Suffolk County Department of Social Services
Mary Gordon Building
3085 Veterans Memorial Highway
Ronkonkoma, NY 11779
631-854-9843
Kimberly.Staab@suffolkcountyny.gov
PIMA COUNTY, ARIZONA
A. Local Site Characteristics
The population of Pima County, which includes Tucson and rural outlying communities, totals about 1 million. The county is located about 90 miles from the Mexican boarder, and about one-third of its population is Hispanic or Latino, a figure that underestimates the actual number because it does not include undocumented workers. Pima County’s unemployment rate of about 4.6 percent is comparable to the state average (4.7 percent). Most entry-level jobs are in the service sector.
B. TANF Program Administrative Structure and Staffing
Administrative structure. The TANF program in Arizona is state administered. Two divisions within the Department of Economic Security serve TANF recipients: the Family Assistance Administration (FAA) handles TANF eligibility, and the Employment Administration (EA) provides employment and training services. As part of a statewide privatization effort, contracted service providers will handle all case management responsibilities for TANF recipients by the October 1, 2007.
Staff involved with sanctions. EA case managers initiate sanctions, and FAA eligibility workers impose them.
C. Use of Sanctions
The message that state TANF administrators convey to program staff is that sanctions are a last resort. Program staff also believe that their time is better spent attempting to engage noncompliant clients than sanctioning noncompliant clients. As a result, the practice is to resolve barriers first and then consider initiation of a sanction. TANF clients are rarely sanctioned. The current sanction rate is about 3 percent. . Program staff feel that sanctions do not have their intended effect because (1) clients may cure sanctions based on a commitment to participate rather than demonstrated participation, and (2) a long sanction process means that clients do not experience immediate consequences for their failure to participate.
D. Work Requirements and Related Policies
Applicant work requirements. Clients complete a 30-minute group orientation session and, in Pima County, register with the local One-Stop center as conditions of TANF eligibility.
Screening and assessment. Case managers use a standardized assessment tool, the Case Management Screening Guide, to gather information about clients’ background, employability, family needs, and barriers to employment. Clients with disabilities that are likely to persist for more than a year are referred to University of Arizona for a comprehensive medical and psychosocial assessment. Based on assessment results, clients follow one of three routes: they are referred back to their case manager with recommendations for required hours and activities, they are referred to vocational rehabilitation, or they receive assistance in applying for Supplemental Security Income (SSI).
Exemptions from work requirements. County administrators estimate that approximately 40 percent of clients in Pima County are deferred because they have a child under one year of age, are caring for a disabled family member, are in the third trimester of pregnancy, or have a documented physical or mental health condition.
Program expectations. Clients are required to participate 40 hours per week in work or work-related activities with the understanding that they will likely fall short of their participation hours. The hope is that they complete an average 30 hours per week. Clients are assigned to the following activities: job-readiness, job search, work experience, education or training, or paid employment. They may also be temporarily assigned to state activities in lieu of or in addition to federally countable activities. Examples include caring for a child with health or behavioral problems, attending court appointments, or physical or mental health treatment.
E. Sanction Process
Identifying non-participation. Clients report participation to their case manager weekly. In addition, case managers are required to meet monthly with clients to monitor their ongoing participation and progress. High caseloads, between 150 and 200 cases per worker, make it difficult for case managers to fulfill their monitoring responsibilities.
Addressing non-participation. The process for initiating a sanction includes several notices over an extended period. When clients stop participating, the case manager sends a request-for-good- cause-information notice, which gives clients 10 days to respond. If clients fail to respond, then the case manager mails a good-cause-has-not-been-established form, which gives clients another 10 days to respond. If clients do not respond to the second mailing, then clients sends a notice-of-adverse-action form, which gives clients another 10 days to respond before imposition of a sanction. All sanction requests must be reviewed by the case manager’s supervisor, who uses a detailed checklist to ensure that all of the case manager’s actions were reasonable and correct. With just one mistake (e.g., misspelled street name, incomplete documentation, failure to address barrier), the entire sanction process starts over. Supervisors frequently overturn sanction requests. The sanction process takes between six and eight weeks, depending on when the sanction is requested.
Imposing a TANF sanction. Imposing a sanction is a mechanical process handled electronically. In Arizona, sanctions become progressively stringent with each incidence or each consecutive month. In the case of the latter, the case manager must request a new sanction each month of non-participation; the sanction does not automatically move from one level to the next. If the case manager fails to request a sanction for the second or third consecutive month of non-participation, then the full grant is restored and the sanction process begins again. Case managers are required to contact clients before each sanction request.
F. Reversing a Sanction
Appeals process. Sanction appeals are not common, with typically only a couple each year. Clients are informed by letter of their right to appeal. Once clients request an appeal, the state office requests the case file and arranges a telephone conference call with an administrative law judge at the state office, a local fair hearing officer, the client, and sometimes the case manager. Where possible, the fair hearing officer tries to resolve the case with the client before the call. Otherwise, the judge hears the case and makes a decision.
Cure requirements. Clients may cure a sanction or stop the sanction process based on a commitment to participate. Clients are not required to participate for any length of time. If clients commit to participate and then do not, the sanction process begins again.1
Efforts to re-engage sanctioned clients. Clients are sent a notice before the imposition of second- and third-level sanctions. Case managers are required to contact the client by telephone before imposing a full-family sanction. Case managers expressed mixed feelings about re-engagement efforts. On the one hand, they wanted clients to comply; on the other hand, clients’ expressed interest in participation starts the sanction process anew.
Contact information:
Denise Blackman
Arizona Department of Economic Security
P.O. Box 21106
Phoenix, AZ 85036-1106
(602) 542-6325
Dblackman@azdes.gov
Peggy Feenan
Deputy Program Administrator
400 W. Congress, Suite 420
Tucson, AZ 85701
(520) 628-6810, ext. 250
Pfennan@azdes.gov
DUVAL COUNTY, FLORIDA
A. Local Site Characteristics
Duval County, described as the “gateway to the South,” is a sprawling community located in the northeast corner of Florida. Jacksonville, the largest city in the county, has a population of just under 750,000. Duval County’s population is roughly one-third white but also includes has a sizeable African American population. The county unemployment rate is low, about 3 percent. Major employers in the area are the military, manufacturers, and call centers for the financial industry.
B. TANF Program Administrative Structure and Staffing
Administrative structure. The Florida Department of Children and Families (DCF) handles eligibility for TANF, food stamps, Medicaid, and other programs. Local workforce development agencies provide employment and training services for TANF recipients. In Duval County, the workforce provider is First Coast Workforce Development, Inc. (WorkSource). WorkSource operates three One-Stop centers in the county, one of which, the Market Street branch, serves primarily welfare recipients.
Staff involved with sanctions. WorkSource case managers, assigned caseloads of 50 to 60 cases per worker, handle the full range of case management responsibilities except eligibility. They initiate the sanction process and request the imposition of sanctions. A designated DCF eligibility worker, located in a centralized call center, processes all sanction requests.
C. Use of Sanctions
TANF administrators described sanctions as a way to hold clients responsible for what they are required to do. In practice, sanctions are used regularly to encourage compliance. In Duval County, just over 10 percent of cases were closed in September 2006 due to a sanction.
D. Work Requirements and Related Policies
Applicant work requirements. As a condition of eligibility, clients must complete an orientation session and work registration as well as eight workshops (60 to 90 minutes each) and a basic aptitude test. Workshop topics include resume writing, mental health, communication skills, and domestic abuse, among others. Clients complete these activities in about two or three weeks.
Screening and assessment. Clients first undergo an assessment of their education and reading level. In addition, they fill out a checklist in their orientation packet that assesses their job readiness and how they view work. During their first meeting with their case manager, they review the checklist and talk about their employment goals, education and work history, personal and family challenges, and immediate service needs. The case manager uses this informal conversation to develop each client’s Individual Responsibility Plan.
Exemptions from work requirements. Exemption criteria follow a standard set of federal guidelines that exclude clients from counting toward the work requirements. Clients are required to have a licensed physician document all exemptions for physical and mental health conditions.
Program expectations. TANF clients are required to complete an average 30 hours of work or work-related activities per week for a total 120 hours per month. They are encouraged to work 40 hours per week in order to use the extra hours to compensate for weeks in which they fall short of 30 hours. Monthly tracking of hours affords the flexibility needed to make adjustments for variation in hours worked per week. Required activities follow federal requirements. Most clients are assigned to job search, community service, or work.
E. Sanction Process
Identifying non-participation. Unless employed, clients submit time sheets to their case manager weekly. Working clients submit employer pay stubs after each bimonthly pay period. In addition to weekly check-ins, case managers meet with TANF clients assigned to them at least monthly to identify clients’ service needs and put supports in place to avoid participation disruptions.
Addressing non-participation. When clients are noncompliant, the case manager calls them by telephone. If the case manager is unable to make contact by telephone, then the manager sends a pre-penalty letter indicating that the client has 10 days to contact the case manager to demonstrate good cause for non-participation before a sanction is imposed. If a client does not contact the case manager, then the manager sends another letter indicating that a sanction will be imposed. If the client responds to the initial warning and is noncompliant again within a 30-day period, the client has 3 rather than 10 days to establish good cause for non-participation. No pre-penalty letter is sent for the second occurrence within 30 days.
Imposing a TANF sanction. To impose a sanction, the case manager sends an electronic alert to a designated DCF eligibility worker. The eligibility worker has 10 days to make changes to the electronic file. When the sanction is imposed, the eligibility worker sends a letter notifying the client of imposition of the sanction.
F. Reversing a Sanction
Appeals process. A DCF fair hearing officer handles all sanction appeals. When the client requests an appeal, WorkSource staff try to resolve the appeal before it goes to a formal fair hearing. If the case is unresolved, then the fair hearing officer meets with the client, case manager, and DCF supervisor to discuss the case. Sanction appeals are not common.
Cure requirements. Clients need to come into compliance before their sanction is cured. The case manager determines the minimum period of time that clients are required to participate before their sanction is cured. Curing a sanction appears to be a relatively easy process.
Efforts to re-engage sanctioned clients. None.
Contact information:
Eileen Schilling
Department of Children and Families
1317 Winewood Boulevard, Building 1
Tallahassee, FL 32399
(850) 414-5643
Eileen_Schilling@dcf.state.fl.us
Vicki Abrams
Department of Children and Families
5920 Arlington Expressway
Jacksonville, FL 32211
(904) 723-5448
Vicki_Abrams@dcf.state.fl.us
Bryan Stone
WorkSource
2141 Loch Rane Boulevard, Suite 107
Orange Park, FL 32073
(904) 213-3800, ext. 2004
Bstone@worksourcefl.com
DEKALB COUNTY, GEORGIA
A. Local Site Characteristics
DeKalb County borders Atlanta and has a population of 678,000 persons, of whom 56 percent are black and 39 percent are white. The county unemployment rate is just under 10 percent; most entry-level jobs offer low pay and no benefits.
B. TANF Program Administrative Structure and Staffing
Administrative structure. The state Department of Human Resources, Division for Family and Children Services (DFCS) administers Georgia’s TANF program. In DeKalb County, DFCS case managers, carrying caseloads of about 60 clients, manage ongoing eligibility and provide overall case management. They refer clients to one of nine contracted service providers for employment and training services.
Staff involved with sanctions. Case managers initiate the sanction process as well as impose sanctions. DFCS designated three community resource specialists to act as liaisons to share information between agencies and re-engage non-participants. They meet weekly with contracted service providers and meet with clients as needed.
C. Use of Sanctions
Sanctions are reportedly used to hold clients accountable to program requirements and to present consequences in order to encourage clients to “do what they need to do.” While case managers often use the threat of sanctions, they rarely ever impose them. Less than 5 percent of the TANF caseload is sanctioned each month.
D. Work Requirements and Related Policies
Applicant work requirements. Work eligible TANF applicants who are determined to be job ready are required to participate in four weeks of job search for 40 hours per week as a condition of TANF eligibility. Slightly fewer than half of applicants complete the requirements.
Screening and assessment. Intake workers use a standardized assessment form to determine clients’ job readiness. They also screen for mental health, substance abuse, domestic violence, and child protective services issues and refer clients seemingly in need of such services to the appropriate counselor at DFCS for in-depth assessment.
Exemptions from work requirements. About a quarter of TANF clients are exempt from work requirements. Work requirements may temporarily be waived for some clients due to documented short-term conditions.
Program expectations. Once eligible for TANF, clients develop a TANF family service plan. For most clients, activities and hours included in the plan follow federal work requirements. Clients are referred to contracted service providers that serve them and monitor their participation. Providers typically require 40 hours per week of participation; however, Georgia will impose sanctions only when clients fall below 30 hours.
E. Sanction Process
Identifying non-participation. Clients report their participation to contracted service providers that, in turn, report to community resource specialists (liaisons) who relay information to DFCS case managers. All reporting between the client and the provider and between the provider and the liaisons occurs daily. Liaisons notify case managers immediately when a client stops participating.
Addressing non-participation. At the first instance of non-participation, case managers invite clients to a conciliation meeting with the case manager in an effort to return the client to compliance. During the meeting, clients may provide documented reasons for non-participation. For non-participation after a conciliation meeting, the case manager sends clients a warning letter indicating that, unless they establish good cause, a sanction will be imposed within 10 days.
Imposing a TANF sanction. If noncompliant clients do not respond to a sanction warning within 10 days, the supervisor of the case manager assigned to the client reviews and approves the sanction request. The case manager imposes the sanction.
F. Reversing a Sanction
Appeals process. For clients appealing a sanction, DFCS and the client present their arguments before an administrative law judge. Hearings last an hour on average. Sanction appeals are rare at one or two a year.
Cure requirements. To begin receiving full benefits again after a sanction, clients must complete the activity that they abandoned, thus triggering the sanction, and wait out the minimum sanction period, which is based on the number of prior instance of noncompliance.
Efforts to re-engage sanctioned clients. Case managers contact clients approaching the end of their minimum sanction period to renegotiate their full participation and compliance with the program.
Contact information:
Donna E. Gunter
Department of Human Resources
Division of Family and Childrens Services
2 Peachtree Street, NW, Suite 18-486
Atlanta, Georgia 30303
404-657-3737
Degunter@dhr.state.ga.us
Betty Ricks
Department of Human Resources
Division of Family and Children Services (DFCS)
178 Sams Street
Decatur, GA 30030
(404) 370-5357
bericks@dhr.state.ga.us
TARRANT COUNTY, TEXAS
A. Local Site Characteristics
Most residents in Tarrant County, which includes Fort Worth, are Caucasian, although the county is also home to a large Hispanic or Latino and African American population. With a population just under 600,000, Fort Worth is among the largest cities in Tarrant County. Unemployment in the area is close to the state rate, which is about 4.6 percent. Most jobs are in the healthcare, aerospace, hospitality, and logistics/trucking industries.
B. TANF Program Administrative Structure and Staffing
Administrative structure. The Texas Health and Human Services Commission (HHSC) oversees TANF eligibility while the Texas Workforce Commission (TWC) oversees TANF employment and training services. TWC distributes money to 28 local Workforce Development Boards that contract with local providers. Workforce Solutions for Tarrant County, the local Workforce Investment Agency, contracts for management and operations of the local Workforce Center that provides employment and training services to TANF recipients. The Workforce Solutions Board in addition contracts with 12 community agencies for specialized services. One of the community-based providers, the Women’s Center operates REAP (Rapid Employment Attachment Program) to help individuals cure their sanctions.
Staff involved with sanctions. Workforce Solutions case managers are responsible for all case management activities except eligibility. Small caseloads, between 40 and 60 clients per worker, allow case managers to track clients’ participation and progress. Workforce Center case managers identify non-participants and initiate the sanction process. HHSC eligibility workers impose all sanctions. REAP staff work individually with sanctioned clients to cure their sanctions.
C. Use of Sanctions
State welfare administrators set the stage for the use of sanctions by talking about the state’s “work first” approach. “Your pay stops coming if you stop coming to work,” one administrator said to describe how sanctions are used. Local administrators talked about sanctions as a policy to enforce participation. During an average month, between 4 and 7 percent of work-mandatory clients are sanctioned.
D. Work Requirements and Related Policies
Applicant work requirements. TANF applicants must attend a workforce orientation to be eligible to receive TANF.
Screening and assessment. Case managers assess clients during an in-person interview, which generally takes the form of a conversation about barriers to employment, work interests, and service needs. In addition, as part of their orientation, clients complete the TABE test to determine their reading and math level. Contracted service providers, such as Easter Seals, may conduct specialized assessments for clients with physical or mental health conditions.
Exemptions from work requirements. State administrators estimate that about a third of TANF clients are subject to work requirements. Exemption criteria follow federal guidelines. Child-only cases are excluded from work requirements.
Program expectations. Clients are expected to work 30 hours per week in federally defined work activities. They typically participate first in job search or job-readiness activities and are then referred to the Career Steps program for community service or to a specialized treatment provider.
E. Sanction Process
Identifying non-participation. Clients report their participation each week to contracted service providers and to their case manager. Case managers also schedule monthly meetings with each client on their caseload.
Each week, contracted service providers enter clients’ participation hours and activities into the Safety Net tracking system. Some case managers are responsible for transferring the information in the Safety Net Tracking system into the state management information system.
Addressing non-participation. When clients stop participating, they are sent a sanction warning letter telling them that they have 10 business days to contact their case manager to discuss the reasons for non-participation. The letter also describes what clients need to do to come into compliance. If clients do not respond to the sanction warning, then the case manager sends a second letter stating that a sanction will be imposed and instructing clients to contact the REAP program as a first step for curing their sanction.
Imposing a TANF sanction. To impose a sanction, the case manager sends a sanction request to the HHSC eligibility worker. The eligibility worker reviews the case to determine if the client qualifies for an exemption or if there is any new information about the case. If there are no changes, the eligibility worker imposes the sanction electronically and mails clients a letter informing them that their TANF case will be close and that they will lose the adult portion of their Medicaid.
F. Reversing a Sanction
Appeals process. Sanction warnings include information about clients’ right to appeal. An HHSC appeals officer requests clients’ case file and schedules an appeals hearing within two weeks from the request date. The hearing takes place over the telephone and includes the client and case manager. Decisions are usually rendered within a week of the hearing and about 20 days after the appeal is filed. Sanction appeals are fairly common; the appeals officer said that he often has 25 sanction appeals on his caseload at any given point. Slightly fewer than 10 percent of sanctions are reversed due to documented good cause, clients’ ability to prove that they did not receive the appointment letter, or incomplete documentation of non-participation or other reasons.
Cure requirements. Tarrant County created REAP to help clients cure their sanction. Clients must participate consistently for 30 days to cure their sanction or the TANF case is closed. If the individual’s TANF case is closed due to sanction, the individual must reapply for TANF and participate in work activities for 30 days within 40 days of their eligibility interview before the TANF case is approved and cash benefits issued.
Efforts to re-engage sanctioned clients. REAP staff contact sanctioned clients immediately after they are sanctioned and invite them to attend an orientation. While at REAP, clients participate in job search and job-readiness activities, including daily structured workshops, and receive individualized support to build their self-esteem and confidence.
Contact information:
Irma Allen
Texas Health and Human Services
1501 Circle Drive
Fort Worth, TX 76119
Irma.Allen@hhsc.state.tx.us
(817) 321-8922
Debby Kratky
Workforce Solutions
1320 S. University Drive, Suite 600
Fort Worth, TX 76107
Debby.Kratky@twc.state.tx.us
(817) 528-0402
LOS ANGELES COUNTY, CALIFORNIA
A. Local Site Characteristics
Los Angeles County is a large metropolitan area with a population of just under 10 million. It is a racially and ethnically diverse metropolis with significant concentrations of African Americans, Hispanics or Latinos, and Asian Americans, among others. Most entry-level jobs are service sector jobs in the tourism industry. The local unemployment rate is about 4.5 percent, slightly lower than the state average.
B. TANF Program Administrative Structure and Staffing
Administrative structure. While California is a county-administered state, the California Department of Social Services (CDSS) develops most CALWORKs (TANF) policies. In Los Angeles County, the Department of Public Social Services--through the Bureau of Workforce Services--administers CALWORKs. The Los Angeles County Office of Education (LACOE) operates the county’s job search program, and several community colleges provide training and education opportunities. Contracted service providers offer mental health and substance abuse treatment services and domestic violence counseling.
Staff involved with sanctions. Within the county, 24 CALWORKs offices handle eligibility functions, and seven GAIN (Greater Avenues to Independence) offices provide case management and work or work-related functions. GAIN case managers request sanctions; CALWORKs eligibility workers impose them.
C. Use of Sanctions
Los Angeles County has focused significant effort on understanding the characteristics and circumstances that lead to sanctions. It has implemented procedural changes that encourage program staff to do everything possible to promote compliance before a client is sanctioned for noncompliance. The county tries to use sanctions as a last resort. At any given point, about one-fifth of the TANF caseload is in sanction status.
D. Work Requirements and Related Policies
Applicant work requirements. None.
Screening and assessment. As part of their initial orientation, clients undergo screening for domestic violence, substance abuse, and mental health issues as well as for potential learning disabilities. Those screening positive are referred to a specialized treatment provider for in-depth assessment. After the initial orientation and screenings, clients are referred to three weeks of job search, after which unemployed clients are referred to an outside contractor for comprehensive assessment.
Exemptions from work requirements. Between one-fourth and one-third of all CALWORKs clients are exempt from work requirements. Many of those exempt in Los Angeles County have a child under one year of age.
Program expectations. Clients are required to participate in 32 hours of work activities per week. Twenty of those hours must be in a federally defined work activity, although case managers have considerable flexibility in determining the types of activities appropriate for the remaining 12 hours. Clients are typically assigned to job search/job-readiness activities, education or training, work experience, or specialized supportive services.
E. Sanction Process
Identifying non-participation. Case managers rely on reports from providers to monitor clients’ participation and to identify noncompliant clients. Providers submit monthly reports for those assigned to job search and quarterly reports for those in all other activities (e.g., school or vocational training, community service, or supportive services).
Addressing non-participation. Once identified, non-participants are sent a noncompliance cause determination appointment letter inviting them to meet with their case manager to discuss the reasons for noncompliance. A sanction clock starts with the mailing of the appointment letter. If the clock is not reset or stopped, a sanction is automatically imposed 21 days later. Case managers may contact clients by telephone or letter to re-engage them during the 21-day period. Clients who attend their noncompliance cause determination appointment develop a compliance plan to stop the sanction process. The compliance plan specifies the activities that the client failed to complete, thereby triggering the sanction process.
To re-engage clients at risk for sanction, Los Angeles County developed an extensive home- visiting program. Home visitors send a letter to schedule a home visit immediately upon learning of the participants’ noncompliance. The home visitors call the participant the day before their cause determination appointment and meet with them the day after if they do not keep the appointment. During the home visit, the worker talks with clients about barriers to participation and work. The home visitor then follows up with clients 15 days later to ensure that they are participating. According to an administrative report in late 2005, the home-visiting program pilot led to the resolution of more than 70 percent of noncompliance periods or sanctions.
Imposing a TANF sanction. If clients fail to attend their cause determination appointment or contact their case manager, a sanction is automatically imposed at the end of the 21-day period. Recipients who are going to be sanctioned receive a notice-of-action letter notifying them that they are about to be sanctioned and have the right to appeal the decision.
Exemptions from work requirements. Between one-fourth and one-third of all CALWORKs clients are exempt from work requirements. Many of those exempt in Los Angeles County have a child under one year of age.
Program expectations. Clients are required to participate in 32 hours of work activities per week. Twenty of those hours must be in a federally defined work activity, although case managers have considerable flexibility in determining the types of activities appropriate for the remaining 12 hours. Clients are typically assigned to job search/job-readiness activities, education or training, work experience, or specialized supportive services.
E. Sanction Process
Identifying non-participation. Case managers rely on reports from providers to monitor clients’ participation and to identify noncompliant clients. Providers submit monthly reports for those assigned to job search and quarterly reports for those in all other activities (e.g., school or vocational training, community service, or supportive services).
Addressing non-participation. Once identified, non-participants are sent a noncompliance cause determination appointment letter inviting them to meet with their case manager to discuss the reasons for noncompliance. A sanction clock starts with the mailing of the appointment letter. If the clock is not reset or stopped, a sanction is automatically imposed 21 days later. Case managers may contact clients by telephone or letter to re-engage them during the 21-day period. Clients who attend their noncompliance cause determination appointment develop a compliance plan to stop the sanction process. The compliance plan specifies the activities that the client failed to complete, thereby triggering the sanction process.
To re-engage clients at risk for sanction, Los Angeles County developed an extensive home- visiting program. Home visitors send a letter to schedule a home visit immediately upon learning of the participants’ noncompliance. The home visitors call the participant the day before their cause determination appointment and meet with them the day after if they do not keep the appointment. During the home visit, the worker talks with clients about barriers to participation and work. The home visitor then follows up with clients 15 days later to ensure that they are participating. According to an administrative report in late 2005, the home-visiting program pilot led to the resolution of more than 70 percent of noncompliance periods or sanctions.
Imposing a TANF sanction. If clients fail to attend their cause determination appointment or contact their case manager, a sanction is automatically imposed at the end of the 21-day period. Recipients who are going to be sanctioned receive a notice-of-action letter notifying them that they are about to be sanctioned and have the right to appeal the decision.
F. Reversing a Sanction
Appeals process. Few clients appeal sanction decisions. Some appeals officers handle fewer than five appeals a year. A county fair hearing specialist reviews each case to see if welfare agency staff handled it appropriately. The appeals officer attempts to resolve the situation before the case progresses to formal review. If the case is not resolved, the administrative law judge listens to the case. The fair hearing specialist, the client, and any client representatives participate in the hearing. The judge renders a decision within 90 days of the date that the client filed the appeal.
Cure requirements. To cure a sanction, clients must complete the activity that led to the sanction. For example, if the client missed orientation, then the client must complete the orientation session. If the activity is longer than 30 days, such as a 60-day work experience assignment, then the client is only required to participate for 30 days before their sanction is cured.
Efforts to re-engage sanctioned clients. The GAIN computer system generates a letter each month addressed to sanctioned TANF clients, inviting them to cure their sanction. In addition, the home-visiting program makes a formal effort to re-engage TANF clients in their first sanction. During home visits, home visitors identify and resolve undisclosed barriers to employment and encourage clients to come into compliance.
Contact information:
Brenda J. Williams, HSA I
DPSS/BSO/REQAD/Management & Research Services
12820 Crossroads Parkway South,
West Annex City of Industry, CA 91746
Phone: (562) 908-5866 Fax: (562) 692-9339
brendajwilliams@dpss.lacounty.org
KERN COUNTY, CALIFORNIA
A. Local Site Characteristics
Kern County is the third largest of California’s 58 counties, with a total population just under 800,000. Bakersfield is the largest city within the county. In November 2006, the county unemployment rate was 7.3 percent as compared with a state rate of 4.6 percent.
B. TANF Program Administrative Structure and Staffing
Administrative structure. The Kern County Department of Human Services (DHS) provides all eligibility and case management services for TANF recipients. Case management social workers, carrying caseloads of between 60 and 70 clients, directly monitor client participation. Employment and training resources are provided by a collaborative of local partners, including DHS, the Employers’ Training Resource, Employment Development Department, and Kern County Department of Mental Health. These agencies also monitor client participation.
Staff involved with sanctions. Social workers initiate sanctions, and eligibility workers impose sanctions.
C. Use of Sanctions
Sanctions are used to engage clients but not to penalize children for parents’ noncompliance. California imposes partial sanctions, where the adult is removed from the grant, in order to maintain a safety net for children. About a quarter of Kern County’s TANF caseload is in sanction status at any given point in time.
D. Work Requirements and Related Policies
Applicant work requirements. None.
Screening and assessment. DHS social workers assess all new clients in their homes. Assessments focus on early engagement, identification of personal and family challenges, and direct observation of client behaviors. If clients are not employed within three weeks of the initial assessment, a private provider conducts a comprehensive, in-depth assessment. Clients may also be referred to a mental health or substance abuse treatment provider for specialized assessments.
Exemptions from work requirements. Approximately a quarter of Kern County’s TANF caseload is exempt from work requirements. Unlike the other study states, California exempts clients with physical disabilities from all activities. Other states may modify the required hours and activities for these clients based on a recommendation from a licensed physician.
Program expectations. Clients develop a welfare-to-work plan after the in-depth assessment and are assigned to at least 32 hours per week of work activities, 20 hours of which are in core activities that follow federal guidelines. Remaining hours may include job-readiness activities, school-based activities, education, mental health and substance abuse treatment, and domestic violence services. Required activities and hours may be modified with documented good cause from a licensed professional.
E. Sanction Process
Identifying non-participation. Each month, clients communicate with their DHS social worker to discuss their progress toward employment and to submit their monthly participation hours and activities. In addition, contracted service providers submit monthly client attendance and participation reports to the social workers. Clients report participation to contracted service providers weekly.
Addressing non-participation. When clients are noncompliant, case managers first contact the eligibility worker to determine if there is additional information about the case. They then send clients a notice of adverse action (NOA) informing them that continued noncompliance will result in a sanction; the notice also invites clients to a cause determination appointment. Clients have 20 days to respond to the NOA. If they do not respond and fail to keep the appointment, the social worker sends a sanction request to the eligibility worker. Clients who do respond are required to complete the activity whose abandonment led to the NOA. If they do not complete the activity, the case manager may send a sanction request and a second NOA within 10 days before the imposition of a sanction.
Imposing a TANF sanction. Once the sanction process is initiated, one to two months elapse before the imposition of the sanction. The eligibility worker must receive the sanction request from the social worker at least 10 days before the end of the month for sanctions to be imposed by the first of the following month. In some situations, such as a change in income or family composition, eligibility workers are required to send a second NOA at least 10 days before imposition of a sanction.
F. Reversing a Sanction
Appeals process. Clients are informed in the NOA that they have a right to appeal. Kern County’s appeals specialist reviews and attempts to resolve cases before the state administrative hearing takes place. If the case is unresolved, DHS and clients present their cases to an administrative law judge. The judge has 60 days to render a decision. Sanctions may be overturned if clients successfully establish good cause. Between 3 and 12 sanctions are appealed each month.
Cure requirements. To cure a sanction, clients must attend a 1.5-hour sanction orientation, develop a cure plan that includes the activity whose abandonment led to the sanction. However, the cure requirement cannot last longer than 30 days. In addition, cure plan requirements may be modified in accordance with clients’ personal and family circumstances. Clients may call the sanction hotline to find out how to cure their sanction and to request times and dates for sanction orientation sessions.
Efforts to re-engage sanctioned clients. A sanction re-engagement team (SRT) made up of two staff (assigned to the team on a full-time basis) and one DHS supervisor (assigned to the team on a part-time basis) work to re-engage sanctioned TANF recipients. The team contacts clients by telephone and/or letter to inform them of what they must do to cure their sanction. The team may also establish good cause or help qualifying clients apply for an exemption from the work requirements. The SRT contacts between 100 and 200 clients each month, about a quarter of whom attend sanction orientation sessions. Efforts appear to be most successful with clients sanctioned within the preceding six months.
Contact information:
Diane Rosso
Kern County Department of Human Services
16 East Belle Terrace Avenue
Bakersfield, CA 93307
(661) 635-2759
RossoD@co.kern.ca.us
Susan Price
Kern County Department of Human Services
5121 Stockdale Hwy
Bakersfield, CA 93309
(661) 336-6725
PriceS@co.kern.ca.us
SALT LAKE COUNTY, UTAH
A. Local Site Characteristics
About 1 million people reside in the sprawling Salt Lake County area. Most Utah residents are Caucasian (84 percent), with a mix of Hispanics or Latinos (11 percent), Asians (2 percent), Native Americans (1.3 percent), and African Americans (under 1 percent). Utah’s unemployment rate is 2.5 percent, about half the national average. Most jobs are low-wage positions in the service sector. Half of Utah’s TANF caseload lives in the state’s central region, which is made up almost exclusively of Salt Lake County.
B. TANF Program Administrative Structure and Staffing
Administrative structure. The Utah Department of Workforce Services (DWS), a combined welfare and workforce development system, operates 35 employment centers statewide, including seven centers in the central region (Salt Lake County).
Staff involved with sanctions. Employment counselors in Salt Lake County serve a combined caseload of clients receiving TANF, Workforce Investment Act services, food stamps, general assistance, and refugee services. Employment counselors, carrying caseloads of between 30 and 40 clients, monitor client participation and initiate sanctions. Eligibility workers at a centralized call center impose sanctions.
C. Use of Sanctions
DWS administrators and staff refer to the sanction process as “the problem-solving process,” which reflects the philosophy underlying the use of sanctions. The goal of the process is to help clients participate at the maximum level possible and to encourage non-participants to participate and get “back on track.” DWS administrators also work to help clients make an “informed choice” not to participate before their case is closed for noncompliance.
An unintentional consequence of efforts to increase TANF work participation rates has been an increase in the use of TANF sanctions to motivate compliance. Program administrators fear that the number of sanctions imposed each month will exceed the number of those leaving welfare for work. Program administrators are exploring alternative ways to encourage compliance.
D. Work Requirements and Related Policies
Applicant work requirements. Clients are required to complete a one-hour computerized orientation as a condition of TANF eligibility. Clients complete the orientation as part of the intake interview.
Screening and assessment. After eligibility determination, clients complete an in-depth, standardized strengths-based assessment with their employment counselor. As part of the and domestic violence issues, respectively. For those with mental health or substance abuse issues, an in-house licensed clinical therapist (LCT) conducts in-depth psychosocial assessments that generate a clinical diagnosis.
Exemptions from work requirements. Utah is the only study state that uses a universal engagement model that requires all clients to participate to their maximum ability.
Program expectations. Employment plans, based on the strengths-based assessments, include mostly federally defined work or work-related activities. However, required hours and activities may be modified in accordance with a documented limitation.
E. Sanction Process
Identifying non-participation. In October 2006, Utah implemented a new process for monitoring and verifying clients’ work participation hours. The process follows federal requirements for participation hours under the DRA and holds employment counselors and clients accountable. Clients report to employment and training service providers weekly and to their employment counselor at least bimonthly. Providers also report clients’ participation hours bimonthly.
Addressing non-participation. Imposition of a sanction involves a two-phase process. Employment counselors mail a participation review appointment letter to non-participants inviting them to a meeting to be held within 7 to 10 days of the letter’s mailing date; counselors frequently telephone as well to inform clients of the meeting. The purpose of the meeting is to talk about reasons for non-compliance (phase I). LCTs are invited to participate in the participation reviews. If clients fail to respond, then their worker sends another letter inviting them to a non-participation problem-solving case conference (phase II). The letter includes the date and time of the conference. The conference includes the employment counselor, supervisor, LCT (if involved), community providers, mental health clinicians, and the client and anyone invited by the client. The purpose of the conference is to determine any reasonable cause for non-participation and to develop a re-engagement plan. If clients do not attend the conference, then they are sent a third notice informing them that a sanction will be imposed.
Imposing a TANF sanction. Employment counselors request and initiate sanctions, and eligibility workers impose sanctions electronically. Employment center managers must review and approve all second- and third-occurrence sanctions.
F. Reversing a Sanction
Appeals process. Clients are notified by letter that they may appeal sanction decisions. State appeals officers handle the appeals. They review the DWS case file and hold a telephone conference call with the client and DWS staff. The appeals officer listens to the case and renders a decision. TANF sanctions are rarely appealed.
Cure requirements. Clients are required to participate for up to two consecutive weeks to cure their sanction. Hours and activities required to cure a sanction may be modified with documented good cause from a licensed professional.
Efforts to re-engage sanctioned clients. Employment counselors send an appointment
letter to clients in their grant reduction month for first-occurrence sanctions. Otherwise,
they make no efforts to re-engage sanctioned clients.
Contact information:
Sarah Brenna
Utah Department of Workforce Services
140 East 300 South
Salt Lake City, UT 84111
(801) 526-9205
sbrenna@utah.gov
Karla Aguirre
Utah Department of Workforce Services, Central Region
1385 South State Street
Salt Lake City, UT 84115
(801) 468-0198
kaguirre@utah.gov
1 In April 2007, the state passed legislation that requires cash assistance recipients to demonstrate compliance, rather than just the intent to comply, before a sanction can be lifted. (back)
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