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II. Sanction Policies and Program Trends: An Introduction to the Study Sites
The primary goal of this study was to provide states and localities with a broad view of sanction policies, procedures, and reengagement strategies that they could adopt to improve their TANF programs and work participation rates. Given this goal, we selected sites purposively to maximize variation along key policy and programmatic dimensions. Including sites with different sanction policies (e.g., immediate full-family, gradual full-family, and partial sanctions) allows states to compare the advantages and challenges of each approach. Preference was given to sites that had made explicit changes in sanction policy or procedures. We were particularly interested in sites that made changes specifically as part of their efforts to increase their work participation rate. To maximize the utility of the study to other states and localities, we excluded sites that seemed atypical or idiosyncratic with respect to caseload size, geographic location, or general welfare policies. We also excluded three states that were the subject of an earlier study MPR conducted on the implementation of TANF sanctions—Illinois, New Jersey, and South Carolina (Pavetti et al. 2004).1 Finally, to expose policy makers and program administrators to potentially promising practices, we included sites that implemented innovative sanction strategies, such as home-visiting reengagement programs, problem-solving or conciliation processes, sanction orientation meetings, or assistance with curing sanctions. With these criteria in mind, we selected eight sites in seven states to include in this study (see Table II.1).
| Site | Major City in or Closest to Site | Type of Sanction | County Work-Mandatory TANF Caseloada |
Implemented Sanction Policy Changes | Implemented Innovative Sanction Strategies |
|---|---|---|---|---|---|
| Texas—Tarrant County | Fort Worth | Immediate full-family | 5,800-6,000b | Yes | Yes |
| Florida—Duval County | Jacksonville | Immediate full-family | 900b | No | No |
| Utah—Salt Lake County | Salt Lake City | Gradual full-family | 1,600-1,700 | Yes | Yes |
| Arizona—Pima County | Tucson | Gradual full-family | 1,000-1,100 | Yes | No |
| Georgia—DeKalb County | Decatur/Atlanta | Gradual full-family | 700-800 | Yes | No |
| California—Los Angeles County | Los Angeles | Partial | 26,000-27,000 | Yes | Yes |
| California—Kern County | Bakersfield | Partial | 6,000-7,000 | Yes | Yes |
| New York—Suffolk County | Long Island | Partial | 1,000-1,500 | No | Yes |
| a County or regional work-mandatory TANF caseloads reported during fall 2006. b Indicates regional, rather than county, TANF caseload. |
Sanctions are implemented in complex welfare environments. A variety of state and local factors may influence the way sanctions are implemented. For instance, work requirements and exemption policies, caseload size and characteristics, or the TANF program administrative and staffing structure may influence who is subject to sanctions and how sanctions are carried out. As a result, two sites operating under the same sanction policy may actually be using sanctions to achieve different goals and outcomes. In this chapter, we introduce the study sites, grouped by the type of sanction policy they have in place, and describe the sanction policy and the context in which the policy is administered. Table II.2 provides an overview of the sanction policy in each site. We also present information on recent trends or initiatives in the site that are critical for understanding the sanction policy environment.
| Site | Penalty for 1st Sanction | Penalty for 2nd Sanction | Penalty for 3rd Sanction | Cure Requirements | |||
|---|---|---|---|---|---|---|---|
| Cost | Minimum Duration | Cost | Minimum Duration | Cost | Minimum Duration | ||
| Texas (Tarrant County) |
Grant termination | 1 month | Grant termination | 1 month | Grant termination | 1 month | Comply for 30 consecutive days |
| Florida (Duval County) |
Grant termination | 10 days | Grant termination | 1 month | Grant termination | 3 months | Case manager discretion |
| Utah (Salt Lake County) |
$100 reduction | 1 month | Grant termination | 1 month | Grant termination | 2 months | Comply up to 2 consecutive weeks |
| Arizona (Pima County) |
25% reduction | 1 month | 50% reduction | 1 month | Grant termination | none | Verbally commit to participate |
| Georgiaa (DeKalb County) |
25% reduction | 3 months | Grant termination | 3 months | 25% reductionb | 3 months | Renegotiate employment plan |
| California (Los Angeles/Kern County) |
Reduction by adult portion | None | Reduction by adult portion | none | Reduction by adult portion | none | Participate up to 30 days |
| New York (Suffolk County) |
Reduction by adult portion | None | Reduction by adult portion | 3 months | Reduction by adult portion | 6 months | Renegotiate employment plan c |
| a In Georgia, the first instance of noncompliance results in a formal conciliation with no effect on the TANF grant. The first sanction results in a 25 percent reduction of the TANF grant for 3 months. b After a 2nd level sanction, sanctions alternate between a 25 percent grant reduction for three months and immediate full TANF case closure for a year. c Local districts in New York have the authority to require clients to demonstrate compliance for a period of time in order to cure their sanctions. The longest period of time local districts have required is 10 days. |
A. Immediate Full-Family Sanctions
An immediate full-family sanction terminates the TANF grant for the first instance of noncompliance without good cause. Immediate full-family sanctions are a quick consequence for nonparticipation and could be a strong motivator to encourage program compliance. They may also help states achieve higher work participation rates because they remove nonparticipants from the TANF caseload and thus the denominator of the participation rate calculation. Ensuring that sanctions are implemented appropriately is particularly important in states with immediate full-family sanctions since the ramifications for clients are swift and severe.
Two of the seven states in the study, Texas and Florida, use immediate full-family sanctions. In 2003, Texas policymakers passed legislation authorizing a change in sanction policy, from a partial to an immediate full-family sanction. Just prior to these changes, one-third of the TANF caseload was in sanction status. Now, during an average month, approximately 10 percent of TANF clients are removed from the caseload due to a sanction. In both states, sanctions are imposed swiftly, typically less than two weeks after an initial warning notice is sent to clients. Immediate consequences for nonparticipation have likely helped both states achieve state work participation rates of about 50 percent.
1. Texas—Tarrant County
Sanction Policy. In Texas, program administrators encourage the use of sanctions as a tool to enforce the state’s work first approach. The state establishes all sanction policies. The penalty for a sanction is elimination of the cash grant for a minimum of one month and loss of Medicaid for the adult. During that month, clients remain on the caseload in sanction status. To cure a sanction, clients must perform 30 consecutive days of work activities; if they do not, the TANF case is closed. To return to TANF after being sanctioned off the caseload, clients must complete 30 days of work activities within 40 days of their TANF eligibility interview. All sanctions result in the same consequences. The maximum cash grant for a family of three is $217. A TANF sanction does not affect food stamp eligibility or benefit amounts.
To offset the strict requirements for curing a sanction, Tarrant County decided to use existing TANF funds to support those seeking to cure their sanctions. The county contracted with a local service provider to operate REAP (Rapid Employment Attachment Program), a program designed to reengage sanctioned clients and assist those interested in curing their sanction. REAP offers sanctioned clients intensive support and guidance in structured job search classes and individualized help to address personal and family challenges so that they might fully participate.
Program Requirements. All TANF applicants are required to complete an orientation session, and most comply with the requirement. Once eligible for TANF, clients are required to participate for 30 hours a week in federally countable activities. Extensive exemption criteria, however, eliminate about a quarter of the TANF caseload from the requirement to participate, and case managers may modify clients’ work hours and activities for those with documented good cause.
Administrative and Staffing Structure. In Texas, the state Health and Human Services Commission (HHSC) and Texas Workforce Commission (TWC), an agency that administers state workforce investment services, work in partnership to design and administer services for TANF recipients. In Tarrant County, Workforce Solutions, the local workforce investment agency, contracts for management and operations of the local Workforce Center that provides case management and employment and training services to TANF recipients. Workforce Solutions also contracts with 12 community agencies for specialized services not provided directly at the Workforce Center. Staff at a specialized HHSC sanction unit review and impose all sanctions requested by Workforce Solutions case managers.
Recent Trends and Initiatives. Between October 2003 and September 2006, the TANF caseload in Texas declined by nearly half, from 118,927 to 61,333 cases. TANF administrators speculate that shifting from a partial to a full-family sanction has contributed to this decline. In addition, Texas was in the process of shifting TANF eligibility functions from individual workers in welfare offices throughout the state to centralized call centers, but this transition was put on hold indefinitely in March 2007. Call center staff were to be responsible for obtaining, verifying, and calculating income and resources to determine client financial eligibility, for interviewing clients to gather information to determine non-financial eligibility, for processing changes to client case status or benefits, and for addressing client problems or complaints. Problems with the transition, however, left fewer in-house workers to handle initial TANF eligibility determinations, which extended the time for processing TANF applications. As a result, fewer TANF applicants have been entering the TANF caseload.
2. Florida—Duval County
Sanction Policy. State and local TANF administrators in Florida see immediate full-family sanctions as an effective tool for holding TANF clients accountable and encouraging compliance. In Florida, repeat sanctions result in progressively stricter penalties. First level sanctions, which account for 60-70 percent of all sanctions imposed, lead to loss of cash assistance for at least 10 days. Second level sanctions result in the loss of cash assistance for at least a month. Third level and all subsequent sanctions result in loss of cash assistance for at least three months. Sanctions may extend beyond the minimum period if the client does not come back into compliance. To cure a sanction, clients are required to come into compliance as defined by the local workforce investment agency. In Duval County, case managers have discretion to define what individual clients need to do to cure their sanctions. Typically, case managers require that clients participate in activities for a few weeks. Local agencies also have the discretion to determine what constitutes grounds for good cause for noncompliance. The cost of a sanction—the full family benefit—is $303 for a family of three. However, families that do not have children under six years old and are not otherwise exempt from food stamp work participation requirements (about one-quarter of TANF clients) also lose their food stamp benefits. TANF sanctions do not affect eligibility for Medicaid.
Florida policy also includes a safety net for sanctioned families. Families in second level and subsequent sanctions may reapply for TANF at any time with a designated protective payee other than the parent, who manages the cash grant, so that the children continue to receive cash assistance. Months for which assistance is paid through a protective payee continue to count against the family’s welfare time limit.
Program Requirements. TANF applicants in Duval County are required to complete an initial orientation and eight job search/job readiness workshops of 60 to 90 minutes each prior to approval for TANF. Once approved for TANF, clients are assigned to activities and hours that meet the federal work participation requirements; most are assigned to job search or community service activities. Opportunities to obtain post-high school/GED education are limited. Exemptions from work requirements are relatively broad and must be verified and reassessed every 90 days.
Administrative and Staffing Structure. Florida’s Department of Children and Families determines initial and ongoing eligibility for TANF recipients through centralized processing centers. In Duval County, First Coast Workforce Development, Inc. (WorkSource), the local workforce investment provider, handles case management for TANF clients and provides job search and job readiness activities to help them find work. The Market Street Branch One-Stop center is designated to serve only TANF clients. Other job seekers use One-Stop centers in different locations. WorkSource case managers at the Market Street Branch work closely with clients and initiate sanctions when clients fail to meet program requirements. A designated eligibility worker at the centralized processing center imposes all sanctions in Duval County.
Recent Trends and Initiatives. Over the past few years, Florida has shifted from the caseworker model of service delivery to a model in which staff perform specialized tasks, including staff at new centralized call centers. State administrators anticipate very few changes to sanction or related policies in response to the DRA. Just prior to the DRA, the state’s work participation rate was slightly more than 50 percent, but under the new rate calculation based on changes required by the Interim Final Rules, the state’s rate is substantially lower.
B. Gradual Full-Family Sanctions
Gradual full-family sanctions are intended to alert and motivate clients to comply before a full-family sanction is imposed. Three of the study states, Arizona, Georgia, and Utah, use gradual full-family sanctions as penalties for noncompliance. In each of these states, repeat instances of noncompliance with program requirements, by the third occurrence, result in grant termination. In Utah, the penalty for a first sanction is a $100 reduction in cash assistance for a month followed by a full-family sanction for continued noncompliance. All subsequent sanctions result in immediate case closure. Georgia uses a combination of grant reduction and termination, depending on the sanction occurrence. In Arizona, either three consecutive months of nonparticipation or three instances of noncompliance result in a full-family sanction. In Utah, sanctions are applied to a small fraction of the TANF caseload, but about 20 percent of all TANF case closures result from sanctions. In Arizona and Georgia, very few sanctions are imposed.
1. Utah—Salt Lake County
Sanction Policy. In 1994, using federal waivers, Utah began using a gradual full-family sanction to encourage clients to participate. Program administrators emphasize the importance of ensuring that clients make an informed choice not to participate before a sanction is imposed. Within the last year, Utah restructured its sanction policy by decreasing the time it takes to impose a sanction and increasing the stringency of the penalties for repeat sanctions. First sanctions result in $100 reduction in cash assistance for one month. If the client does not comply during the grant reduction period, then the entire cash assistance case is closed. For the second sanction, the clients’ cash assistance case is immediately closed for at least a month. All subsequent sanctions result in immediate case closure for at least two months. The cost of the full-family sanction for a family of three receiving the maximum TANF benefit is $474. TANF sanctions do not affect Medicaid or food stamp eligibility, though food stamp benefits may increase if TANF sanctions contribute to a decline in household income. To ensure that full-family sanctions are imposed appropriately, the center manager must approve all second and subsequent sanctions.
In Utah, the state establishes sanction policy and requires regions to implement a sanction conciliation process within certain defined parameters, but the regions decide exactly what that conciliation process will look like. Utah requires employment counselors to carry out a two-phase problem solving process to understand the client’s reason for noncompliance, uncover and address their hidden barriers to employment, and develop a plan to reengage them in program activities. Clients enter the problem-solving process for nonparticipation or failure to report participation hours and activities. The problem-solving process includes a formal case review by the employment counselor, the supervisor, an in-house licensed clinical therapist, community partners, and the client. Clients may invite others who support them to the case review as well (e.g., family, boyfriend/girlfriend, religious leaders). To cure a sanction, clients are required to participate for up to two consecutive weeks.
Program Requirements. In Utah all clients are required to participate to their maximum ability. As a result of this universal engagement approach, a large proportion of the work-mandatory caseload has serious personal and family challenges. However, employment counselors have considerable flexibility to modify clients’ hours and activities based on a documented barrier to employment. Those without documented barriers are required to participate in hours and activities that meet the federal work requirements. Clients may access employment and training services in-house or, using payment vouchers, at one of the many authorized vendor agencies within the community. In addition, more than 20 licensed clinical therapists are co-located in welfare offices across the state to identify and address clients’ mental health conditions. Most major case management decisions, such as sanctions and modification of work hours and activities, are made in formal case reviews or by case managers in consultation with supervisors or in-house licensed clinical therapists.
Administrative and Staffing Structure. The Department of Workforce Services, an integrated welfare and workforce investment system, operates the Family Employment Program (FEP) for those receiving TANF. Case managers, or employment counselors, in Salt Lake County serve a combined caseload of TANF clients, workforce investment job-seekers, and General Assistance clients. Other parts of the state may specialize caseloads by program. Employment counselors are responsible for all case management activities, including developing an employment plan with the client, monitoring and documenting participation and progress, and initiating the problem-solving (sanction) process. Employment counselors also decide whether to impose sanctions and initiate sanctions in the management information system, but eligibility workers located at a centralized call center make changes to the TANF benefit.
Recent Trends and Initiatives. Recent policy and program changes as well as a strong economy have contributed to a sharp caseload decline in Utah, from 5,546 work-mandatory TANF cases in November 2005 to 3,324 cases in October 2006. The state is in the process of making changes to increase its federal work participation rate. In November 2006, the state’s participation rate was just over 50 percent, but was based on planned hours of participation. Using actual hours of participation, as required by the DRA, the state’s participation rate was substantially lower. Anticipating TANF reauthorization, program administrators initiated major changes in FEP a year before the DRA, and made additional changes after the new requirements were enacted. Major changes include statewide training sessions for employment counselors, encouraging them to assign clients to work activities and hours that meet the federal requirements, speeding up the sanction process and imposing stricter penalties for repeat sanctions, and a new process for verifying and documenting clients’ work hours and activities.
2. Arizona—Pima County
Sanction Policies. Arizona TANF administrators encourage workers to use sanctions as a last resort, if all efforts to remove barriers have failed to get participants to comply with program requirements. All sanction and related policies are established at the state level. For continued nonparticipation without good cause, or failure to contact program staff, case managers may impose a gradual full-family sanction. Clients move from one level to the next for either repeat sanctions or three months of continuous nonparticipation while in sanction status. The consequence of a first sanction is loss of 25 percent of the total cash assistance grant. The penalty for a second sanction, imposed either for repeat noncompliance or at the beginning of the second month of nonparticipation, is a 50 percent grant reduction. The third and all subsequent sanctions or consecutive months of nonparticipation result in a full-family sanction. The cost of a full-family sanction for a family of three is $347 and loss of Medicaid for the adult; food stamp eligibility is not affected.
In 1999, a lawsuit agreement between the William E. Morris Institute for Justice (formerly, the Arizona Justice Institute) and the Department of Economic Security (DES) led to several changes to sanction policies and procedures in an effort to protect clients’ rights to due process. First, Arizona was required to extend the length of the pre-sanction warning period and the number of notices sent to clients. The entire process is designed to take at least a month and typically takes longer. Second, supervisors are required to review all sanction requests using standardized forms. Staff must show that they addressed or attempted to address all barriers identified during assessment and previously documented in the case file. One agency mistake in handling the case requires restarting the pre-sanction process. In addition, each quarter, DES conducts an internal review of all sanctioned cases to check for errors. Finally, clients may cure their sanction or stop the pre-sanction process with a verbal agreement to participate. The process for imposing a sanction is labor-intensive for case managers and sanctions, once imposed, can be cured quickly. Clients, then, often cycle in and out of participation.
Program Requirements. Arizona recently began requiring TANF applicants to complete an upfront 30-minute orientation as a condition of TANF eligibility. Once approved for TANF, clients are required to participate between 35-40 hours per week. However, case managers will only initiate sanctions if clients complete fewer than 30 hours. Clients with documented personal and family challenges may qualify for an exemption or be assigned to broadly defined activities that satisfy state program requirements, such as addressing their child’s health or behavioral problems (for instance, by attending doctor’s appointments or school appointment), attending court appointments, and participating in services to address mental or physical health conditions.
Administrative and Staffing Structure. The TANF program in Arizona is state administered. Two divisions within the Department of Economic Security (DES) serve TANF recipients. The Family Assistance Administration (FAA) handles initial and ongoing eligibility, and the Employment Administration operates the JOBS (TANF) program, providing case management and employment and training services to welfare recipients. In Pima County, staff from the two divisions are co-located within the Irvington Road Job Service Center. JOBS case managers request sanctions when necessary, and one designated FAA eligibility worker imposes them.
As part of a statewide privatization effort, JOBS case management responsibilities will be transferred to contracted service providers. Contracts were supposed to be in place by January 2007; however, the need for a second procurement delayed the process. Now, the goal is for the providers to be fully operational by October 1, 2007.
Recent Trends and Initiatives. Arizona program administrators are focused on selecting contracted service providers and transferring case management responsibilities to them. In addition, they are exploring ways to increase the state’s low work participation rate. Under the state’s original calculation, the participation rate in Arizona was around 30 percent. Using the new DRA calculation requirements, Pima County’s rate was about 12 percent in October 2006.2 Providers will bear some of the responsibility for achieving higher work participation rates; DES administrators plan to include formal language in their contracts to define these objectives. DES administrators also have been pushing for a shorter sanction warning period so that sanctions may be imposed more quickly. The legal team overseeing the lawsuit agreement recently approved this proposal and the process is now in place. Finally, the state has instituted a process of triaging clients based on an assessment of their work readiness in an effort to heighten the focus on program engagement.
3. Georgia—DeKalb County
Sanction Policy. Georgia TANF administrators see the purpose of sanctions as encouraging clients to “do what they need to do.” Georgia uses a gradual full-family sanction to achieve this purpose. The first instance of noncompliance results in a formal conciliation with no effect on the TANF benefit. The second instance results in a 25 percent reduction in the TANF grant for three months. At the end of three months, sanctioned clients are required to meet with their case manager to renegotiate their employment plan within 30 days or their entire cash assistance case is closed. The third instance of noncompliance results in immediate case closure for at least three months. Subsequent sanctions, which are rare, alternate between a 25 percent grant reduction for three months and immediate TANF case closure for a year.3 To cure a sanction, clients must meet with their case manager after the minimum penalty period to renegotiate their employment plan. Clients must reapply for benefits if the sanction resulted in full TANF case closure. No sanctions affect Medicaid eligibility, but when a sanction results in case closure, TANF benefits are no longer considered in calculating the food stamp benefit amount, so food stamp benefits are likely to increase. Very few sanctions are ever imposed, especially third and subsequent sanctions, largely because of the state’s formal and informal conciliation processes.
Program Requirements. Georgia has a stringent upfront pre-approval requirement. Work-mandatory TANF applicants who are determined to be job ready are required to participate full-time (40 hours per week) in four weeks of job search activities, but counties can define the structure of those activities. Providers in DeKalb County estimate that about half of all applicants referred to them complete the requirements and are approved for TANF. Once approved, most clients are required to engage in activities that count toward the federal participation rate. In DeKalb County, providers establish minimum participation requirements for their programs (as long as they are at least 30 hours per week) and county staff enforce their requirements. Most providers in DeKalb require 40 hours of participation per week.
Administrative and Staffing Structure. The state Department of Human Resources, Division for Family and Children Services (DFCS) administers the TANF program in Georgia. DFCS case managers handle ongoing eligibility and case management responsibilities for TANF families. They refer clients to a variety of employment and training service providers under contract with DFCS. Clients who did not find employment during their applicant job search are usually referred to one of two contractors that provide intensive job search assistance and clients with disabilities are referred to a third contractor for in-depth assessment and individualized employment services. DFCS hired three full-time community resource specialists as liaisons between DFCS and contracted service provider staff. They share information with DFCS and contractors, and report client nonparticipation to DFCS case managers immediately. DFCS case managers determine when to initiate a sanction and impose it electronically in the case file. As a safeguard to protect clients, supervisors must approve all sanctions to ensure they are imposed appropriately.
Recent Trends and Initiatives. Georgia recently initiated a statewide social marketing campaign entitled, “The Right Work the Right Way,” to change the culture of the welfare agency by reeducating administrators, welfare staff, contracted service providers, and clients about the importance of work. The strong message about work, combined with a variety of minor policy changes, has contributed to a 50 percent reduction in the TANF caseload since 2004. At the same time, the state’s work participation rate has risen to about 66 percent in FY2006.
C. Partial Sanctions
The largest states, California and New York, implemented partial family sanctions with the implementation of PRWORA. In these states, sanctioned clients comprise a substantial proportion of the TANF caseload. In New York, at any given time, about 30 percent of adult TANF and MOE cases include an adult in sanction status—that is, are in benefit reduction status or in the conciliation or fair hearing process. Sanction rates in California were 20 percent among single-parent cases and 13 percent among two-parent cases in October 2006.
In response to DRA, California and New York instituted new efforts to reengage nonparticipants and sanctioned clients. Both states now encourage the use of sanctions as a last resort. In addition, they allocated additional funds to reengage sanction clients or those at risk of being sanctioned. Finally, California eliminated durational sanctions in an effort to reengage clients in federally countable work activities sooner. In the past, a first sanction could be cured immediately, a second sanction resulted in a reduction of cash assistance for at least three months, and a third sanction resulted in a grant reduction for at least six months. Now, clients may cure any sanction at any time and thus return to the numerator of the participation rate sooner than before.
1. California—Los Angeles and Kern Counties
Sanction Policy. Recipients who do not meet program requirements may be subject to a partial sanction involving elimination of the adult portion of the grant. Clients continue to receive food stamps after a sanction is imposed. However, the amount of food stamps is calculated based on the full TANF grant rather than the amount after the partial sanction thus preventing an increase in food stamp benefits as a result of a TANF sanction. A sanction has no affect on Medicaid eligibility. The California Department of Social Services (CDSS) sets all sanction policies to be implemented throughout the state. Counties may implement additional requirements or supports to reengage sanctioned CalWORKs (TANF) clients. To cure a sanction, clients must engage for up to 30 days in the activity that led to the sanction. As a result, some individuals may cure a sanction by attending a one-hour orientation while others must participate in 30 days of job search or work experience.
Program Requirements. State policy requires clients to complete a two-phase pathway of activities aimed at getting a job quickly. Clients begin with 3-4 weeks of structured job search. If the client does not land a job, an in-depth assessment is required to develop an employment plan with the case manager. All non-exempt clients must complete 32 hours of work or work-related activities per week. At least 20 hours must be federally countable activities; the remaining 12 hours may be from a broad list of state defined activities. California, however, offers a broad range of exemptions from work requirements and a broad range of program activities for those with personal and family challenges.
State Administrative Structure. The TANF program in California is called CalWORKs. The California Department of Social Services (CDSS) defines CalWORKs policy and provides guidance and oversight to counties as they administer the program. Counties submit formal plans which CDSS reviews for consistency with state and federal law. Counties were recently asked to update their TANF plans and describe how they would implement legislative initiatives to increase the state’s work participation rates. A variety of additional state agencies (e.g., California Department of Mental Health, California Department of Alcohol and Drug, California Department of Education, and California Community Colleges) administer and provide oversight to specialized services and education programs for CalWORKs clients throughout the state.
a. Los Angeles County
County Administrative and Staffing Structure. The Los Angeles County Department of Public Social Services handles CalWORKs eligibility in 24 offices throughout the county and administers 7 GAIN (Greater Avenues to Independence) offices that handle all case management and work and work-related activity functions. The Los Angeles County Office of Education operates Los Angeles County’s job search program and several community colleges provide education and training opportunities for CalWORKs clients. Providers report clients’ participation to GAIN case managers, who reengage nonparticipants and initiate sanctions by contacting CalWORKs eligibility workers to impose them.
Recent Trends and Initiatives. Los Angeles County created a home visiting program to engage TANF recipients who have been or risk being sanctioned. The home visit program was part of a larger plan to reduce the sanction rate in Los Angeles County, which is about a quarter of CalWORKs families at any given time. As of the fall of 2006, the county work participation rate was between 25 and 27 percent, far below the DRA standard, though the state recently implemented new participation rate standards so that counties would be held accountable to the DRA standards. In an effort to address clients’ personal and family challenges promptly, Los Angeles County is hiring new GAIN case managers to decrease the client-case manager ratios and make it more feasible for case managers to become involved with clients before they stop participating. The current caseloads are about 110 cases per worker and have been as high as 150 cases. GAIN case managers will eventually be assigned 90 CalWORKs clients and will be required to meet with them at least monthly.
b. Kern County
County Administrative and Staffing Structure. The Kern County Department of Human Services (DHS) determines eligibility for CalWORKs applicants and provides ongoing case management. DHS works closely with TANF and workforce investment service providers co-located in the local One-Stop center. These agencies provide employment and training services to most TANF recipients. The County Department of Mental Health, another partner at the One-Stop Center, provides mental health and substance abuse treatment services to TANF recipients as needed. The DHS social worker refers clients to these providers, monitors their participation, and initiates sanctions when necessary. DHS eligibility workers impose sanctions.
Recent Trends and Initiatives. Kern County developed three special initiatives to help clients cure their sanctions and avoid future sanctions. Most sanctioned clients are required to attend a 1½ -hour sanction orientation meeting designed to emphasize the importance of program participation, set an appointment to develop a cure plan with the social worker, and learn about in-house and community resources to address personal and family challenges. Clients may call the sanction hotline to find out when sanction orientation sessions are held during the upcoming week. In addition to the sanction hotline and orientation, DHS created a sanction reengagement team to inform TANF clients about the process for curing their sanction and to identify clients who may qualify for an exemption from the work requirements. County administrators estimate that, during an average month, about one-fourth of the TANF caseload is in sanction status. Kern County has one of the higher county work participation rates at about 55 percent.
2. New York—Suffolk County
Sanction Policy. New York imposes partial sanctions by removing the adult portion of the TANF grant. Unlike California, New York still imposes durational sanctions, with each progressive sanction resulting in a longer minimum sanction period. First sanctions last until program compliance. Second sanctions last at least three months and third and subsequent sanctions remain in place for at least six months. Unless a client is otherwise exempt from Food Stamp employment and training requirements, a partial reduction in the food stamp grant is also imposed when a TANF sanction is imposed. A TANF sanction does not affect eligibility for Medicaid. To cure a sanction, clients are required to contact program staff and indicate a willingness to comply with program requirements and to attend an assessment interview. The state does not require clients to participate for a minimum amount of time to cure their sanction, though local districts have the authority to require clients to demonstrate compliance for a period of time. The longest period of time local districts have required is 10 days. The sanction rates for New York and Suffolk County are 30 and 38 percent, respectively.
Program Requirements. New York state policy requires single-parent TANF recipients to participate in federally countable work activities for at least 30 and up to 40 hours per week, as defined by the local county. Suffolk County requires nearly all clients to participate the full 40 hours a week in federally countable activities.4 They are typically assigned to job search, work experience, or unsubsidized employment provided in-house or by community partners.
Administrative and Staffing Structure. The Office of Temporary Disability Assistance (OTDA) administers the TANF program in New York. In Suffolk County, the Department of Social Services (DSS) determines initial and ongoing eligibility for TANF recipients while the Department of Labor, divided into four main units, defines clients’ program requirements, and monitors their participation in required activities. Clients move progressively through the first three units – the registration unit (initial intake and orientation), client services unit (assessment and employment plan development), and monitoring unit (monitoring and tracking assigned activities). The noncompliance unit reviews cases referred by the monitoring and tracking unit for noncompliance and initiates the sanction process. A DSS compliance examiner initiates the conciliation process and imposes sanctions. DSS contracts with a community based service agency to re-engage sanctioned clients.
Recent Trends and Initiatives. Suffolk County contracts with a local social service provider to provide outreach to sanctioned clients to encourage them to re-engage in program activities. New York State recently appropriated $15 million statewide for additional outreach to sanctioned clients and those at risk of a sanction. In addition, local program administrators recently shifted their philosophy regarding the use of sanctions in response to the effectively increased work participation rate requirements specified in the DRA. They are now telling local staff to follow up more aggressively with nonparticipants before imposing sanctions. In addition, the state and county require greater leniency with respect to the first instance of noncompliance with good cause. Suffolk County’s work participation rate has been fairly stable at 46 percent since spring of 2006.
1 Where relevant, we weave findings from the previous study into this report. (back)
2 These rates rely on different data sources and may not be completely comparable. (back)
3 After a 25 percent reduction in the TANF grant for three months, clients are required to contact their case manager within 30 days or the TANF case is closed. (back)
4 With supervisory approval, clients with a child under age six and a demonstrated hardship may be required to participate fewer hours. (back)
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