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III. Laying the Foundation for Implementing TANF Sanctions: Defining and Communicating Program Requirements
The primary purpose of sanctions is to encourage TANF recipients to comply with program requirements. PRWORA explicitly defined 12 program activities in which TANF recipients’ participation would count toward meeting federal requirements. Nine of those activities were identified as activities in which recipients had to participate for a total of at least 20 hours per week. The remaining three were identified as activities in which recipients could participate for the balance of any required hours. All recipients participating in the requisite activities for the requisite number of hours per week are included in the numerator of the participation rate.
Until HHS promulgated Interim Final Rules as required by the DRA, states had considerable latitude in determining the specific activities that would be considered countable within the 12 defined categories. To standardize what counts as work participation across the states, however, HHS used its rule-making process to clarify the definitions of activities that could count within each of the 12 categories. For instance, the DRA’s Interim Final Rules explicitly defined job search and job readiness assistance as activities that involve seeking and preparing for work. They also restricted the definition of community service programs to “structured programs in which TANF recipients perform work for the direct benefit of the community under the auspices of public or nonprofit organizations”1 and clarified that the definition of vocational educational training excludes basic skills, language training, and post-secondary education leading to a baccalaureate or advanced degree. States still have the flexibility, however, to decide what recipients are required to do and may require participation in program activities other than those that count toward the work participation rate. Similarly, although PRWORA explicitly defines the number of hours a recipient must participate in work activities to count toward a state’s work participation rate, states can modify those hours by setting either higher or lower requirements for some or all recipients. States that set lower requirements run the risk of low participation rates, however, since only those participating for at least an average of 30 hours per week may be included in the numerator.
Before passage of PRWORA, the federal government defined the types of individuals that could not be required to participate in work and work-related activities.2 While some states maintained the exemptions that were in place before the advent of TANF, others narrowed the pool of recipients who could be exempt from participating in work activities, and still others required all TANF recipients to participate (i.e., universal participation). Many of those exempted by states from work requirements, though, are included in the denominator of the federal work participation rate.
Before the DRA, calculation of the work participation rate involved some important exclusions from the denominator, which have now been narrowed by the new legislation. Regardless of how states defined who was required to participate or who was exempt, recipients caring for a child under age one (at state option and up to 12 months per lifetime) and those participating in a separate state program (funded with TANF Maintenance of Effort funds) were excluded from the denominator of the work participation calculation before the DRA. In addition, cases in work sanction status were excluded from the denominator as long as they were sanctioned for no more than three of the preceding 12 months. Under the DRA and the accompanying interim final regulation, states retained all the flexibility they previously had to define who would be required to participate in program activities. However, some groups previously excluded from the work participation calculation are now included. For example, recipients in separate state programs funded with TANF Maintenance of Effort funds are now included in the calculation. These may include working families whose grants are paid by the state in order to stop the federal time limit clock or families that have reached the federal time limit on assistance but continue to receive a state grant. Similarly, sanctioned families in which the adult’s needs were removed from the TANF grant due to noncompliance with work requirements are included in the calculation. On the other hand, parents caring for a disabled family member are now excluded from the work participation rate calculation.
Given that sanctions are imposed for failure to participate in program activities as defined by the state (or by the county if the authority is delegated), a first step in understanding the use of TANF sanctions to encourage participation in work activities is to recognize how a state defines who is required to participate in program activities, what activities they are required to participate in, and how that information is communicated to recipients.
The Current All-Families Work Participation Rate Calculationa Parents providing care for a disabled family member who (1) is living in the home and (2) does not attend school on a full-time basis are excluded from the definition of a work-eligible individual. |
A. Defining Who Is Required to Participate in Program Activities
Although five of the study states provided a broad range of exemptions from work requirements before the DRA, none narrowed its exemption policies in response to the DRA, which restricted the categories of recipients who could be excluded from the work participation calculation.
The states included in the study have taken different approaches with respect to exemptions from work participation requirements (see Table III.1). Utah employs a universal participation model; it does not exempt anyone from participation requirements, though the state broadly defines the activities in which TANF recipients may participate. Georgia provides minimal exemptions, requiring all recipients except those caring for a child under age one to participate in program activities. All other states provide broad exemptions, including most of those allowed before passage of PRWORA, though the states have limited the caretaker exemption to those with a child under age one. While states have the flexibility to provide a broad range of exemptions, exempting substantial portions of the caseload from work requirements will have negative consequences for work participation rates.
Despite the importance of the DRA in changing federal rules, none of the states included in this study changed its exemption policy since the passage of the DRA. Changes may still be made, however, since exemption policies are often part of state legislation, and such legislation may still be enacted. Some states are still in the process of considering the best approach to addressing the needs of TANF recipients who have traditionally been exempt from program requirements and/or excluded from the work participation rate calculation. While one option might be a change in state exemption policies to require more recipients to participate, another might be the creation of solely state-funded programs for specific client groups.
| UT | GA | TX | FL | AZ | NY | CA | |
|---|---|---|---|---|---|---|---|
| Exemption | |||||||
| Caring for a child under one year of age | X | X | X | X | X | ||
| Caring for a child under three months of age | X | ||||||
| Medically incapacitated | X | X | X | X | X | ||
| Toward the end of pregnancy | X | X | X | ||||
| Caring for an incapacitated family member | X | X | X | X | X | ||
| Mental health and/or substance abuse issues | X | X | X | X | |||
| Domestic violence issues | X | X | |||||
| Child in school or vocational school for requisite hours | X | X | X | ||||
| Of older age | X | X | X | ||||
| Percentage of adult clients exempt in a typical month in 2006 | 0 | 21 | 25 | n/a | n/a | 30 | 28 |
| n/a = not available. |
While most states in the study allow several types of exemptions and Georgia only one, exemption rates in Georgia are not substantially lower than those in other states. Among states with broadly defined exemptions, exemption rates range from an estimated 25 percent in Texas to 30 percent in New York in a typical month in 2006. Caring for a young child accounts for a substantial portion of exemptions in all study states. In some states (such as California), most exemptions apply to recipients caring for young children; in other states (such as Texas or New York), the primary reason for an exemption is a medical incapacity, though relatively large numbers of clients are still exempt to care for a young child. This explains why in Georgia, where the only exemption is for those caring for a child under age one, the exemption rate is still relatively high at 21 percent in October 2006. Across all sites in the study, average caseload size among TANF case managers responding to the survey of frontline workers was 107 clients, and the average percentage of clients exempt from work requirements was 16 percent.
Some states have created “partial exemptions.” These states do not approach exemptions as an all-or-nothing policy but instead recognize that, in addition to clients who should be fully subject to work requirements and those who should not be subject to work requirements at all, a middle group of clients may be able to participate in activities but to a more limited extent than others. Florida, for instance, provides two types of exemptions (which the state calls deferrals) from work requirements—total and partial. Clients with severe medical conditions may receive a total exemption and are not subject to any work requirements. Clients with mild medical conditions may receive a partial exemption with modified participation requirements based on the recommendations of private physicians who complete forms indicating the types and amount of activities that clients may perform. About half of the clients with medical exemptions have total exemptions, and about half have partial exemptions; all are included in the calculation of the state’s work participation rate. All clients with total or partial medical exemptions may be required to attend a bimonthly workshop that teaches clients about workplace accommodations for individuals living with disabilities and helps them identify how they might work with their physical limitations. While other states do not explicitly operate a two-tiered exemption system, some modify hour and activity requirements for clients with certain personal challenges (see Section B).
In all study sites, exemptions must be clearly documented and periodically reviewed.
All of the study sites that grant exemptions require documentation of the reason for exemption. Some rely on the recipient to obtain and provide that documentation. For exemptions involving a physical or mental incapacity or pregnancy, documentation usually requires forms completed and signed by a physician. For instance, in Pima County, all medical exemptions require authorization from a medical doctor, indicating the types and amount of work or work-related activities that the client is able and unable to perform and any recommended work accommodations. Other sites have established internal processes for documenting exemptions. For instance, in Suffolk County, all TANF applicants who are not immediately employable (as determined by a TANF agency employability worker during an initial assessment) are referred to a private contractor for in-depth assessment. The contractor conducts drug and alcohol, mental health, and physical health assessments as necessary. It assists TANF staff in determining whether the applicant is employable (potentially with limitations that can be addressed) and subject to work requirements, temporarily unemployable and in need of a work exemption, or disabled and in need of referral to the Supplemental Security Income (SSI) program.
In all study states exemption status is not permanent but is regularly reviewed and updated. Some states require exemption reviews annually, others more frequently. For instance, in Los Angeles County, employment program staff must review exemptions at least once a year, and certain types of exemptions at shorter intervals. The county’s management information system alerts case mangers of exemptions due for review. In Suffolk County, all TANF recipients, regardless of exemption status, must go through an assessment with a TANF agency employability worker (and a private contractor at the worker’s discretion) every six months as a condition of continued TANF eligibility. The sole purpose is to reassess clients’ conditions and make redeterminations of employability or good cause exemptions. In Pima County, exemptions are reviewed every 30 days and require an updated form from a physician every three to four months.
In addition, some exemptions are defined as temporary at the outset. In Florida, for example, medical problems expected to last fewer than 90 days are considered worthy of a temporary deferral from work requirements for 90 days instead of a total or partial exemption. Temporary deferrals may be granted for mental health and substance abuse issues that are considered temporary but may last longer than 90 days. A physician or licensed psychiatrist must evaluate the client at the 90-day mark to determine whether the deferral should continue. In Kern County, case managers have considerable discretion in granting exemptions or temporary good cause in 30-day increments. They receive a list of more than 50 examples of allowable reasons, including domestic violence, homelessness, mental health conditions, drug and alcohol addiction, incarceration, lack of transportation (only in rural areas), or legal issues. Clients are also allowed a temporary good cause exemption if they need to secure childcare before participating in work activities. If possible, clients are required to provide verification for a temporary exemption, though case managers may still grant temporary exemptions without written verification.
B. Defining Client Expectations
Half of the study sites implemented more stringent hour requirements than established in the DRA to ensure that recipients who miss some hours of activities still meet the minimum federally acceptable level of participation.
Half of the study sites require work-ready clients to participate in program activities for more than the average of 30 hours per week needed to count toward the federal work participation rate for the month (see Table III.2); two require only slightly more (32 hours), and two require substantially more (40 hours). Some of the other sites inform clients that they must participate for more than 30 hours per week but penalize them only if they participate for fewer than 30. For instance, Pima and Duval counties tell clients that they must participate for 40 hours per week but will accept (and ultimately expect) 30 hours. This permits clients to miss some hours of activities because of unforeseen circumstances such as doctor’s appointments or caring for sick children yet still meet the minimum federally acceptable level of participation. In addition, most sites require parents with children under age six to participate for a fewer number of hours per week—typically 20 hours in sites that require 30 hours of other single parents and 30 hours in sites that require 40 hours of other single parents. Further, some sites (such as Pima County) calculate participation hours monthly rather than weekly, providing clients with the flexibility to miss hours in some weeks and make them up in others. In these sites, a client may work 20 hours one week, 40 hours the next, and 30 hours the last two weeks of the month and still meet the participation rate.
The degree to which study sites tailor initial and subsequent activities to meet clients’ individual needs varies across sites.
Typically, sites assign clients to a countable activity for at least 20 hours per week and an allowable or other activity for the balance of the required hours. They use one of three basic approaches to determine the specific activities to be included in clients’ employment or personal responsibility plans. Figure III.1 presents the three approaches. In the first approach, sites make no distinction between clients’ strengths and challenges at the outset and assign all clients to the same initial activity and same sequence of subsequent activities. In the second approach, clients are assigned to the same initial activity, but then move into different subsequent activities according to their needs and/or interests. In the third approach, the first assigned activity and all subsequent activities vary from client to client depending on the client’s level of employability. The first approach is relatively the easiest to implement; it does not require much decision- making on the part of program staff with respect to which activities may be appropriate to client circumstances. The second approach can enable clients to self-sort into subsequent activities based on their success in the initial activity. Typically, the initial activity is a job search. Successful clients move on to unsubsidized employment or perhaps transitional jobs while clients who are not successful in the initial activity may be assigned to an array of more intensive services. The third approach has implications for the timing of employability and other in-depth assessments. To make an appropriate initial-activity assignment, program staff need to understand clients’ strengths, challenges, and needs at the outset; accordingly, sites following the third approach generally carry out in-depth assessments early in the program process.
| Site | Hours per Week | Typical First or Primary Activity | Other Typical Activities |
|---|---|---|---|
| Salt Lake County, UT | 30 | Semistructured job search |
Broad range |
| DeKalb County, GA | 40 | Structured job search |
Education and training, work experience |
| Tarrant County, TX | 30 | Structured job search |
Community service |
| Duval County, FL | 30a | Semistructured job search |
Community service |
| Pima County, AZ | 30a | Unstructured job search |
Work experience, education and training, paid employment |
| Suffolk County, NY | 40 | Job readiness training | Employment, work experience, education, and training |
| Kern County, CA | 32 | Job readiness workshop or assessment workshop | Employment, employment preparation, job placement, education and training, behavioral health services |
| Los Angeles County, CA | 32 | Structured job search |
Employment, work experience, education and training, job search, specialized supportive services, vocational education/training, employment-related job skills training, work experience (paid and unpaid) |
a These sites inform clients that they must participate for 40 hours per week but penalize them only for not participating for at least 30 hours per week. |
Tarrant County provides an example of the first approach. The county initially assigns all clients to job search activities and then to a community service program called Career Steps,3 a program that assists clients in starting on a career path by finding appropriate work in transitional jobs or through community service at a hospital. Clients unable to fulfill all of their work participation hours through Career Steps must participate in core activities for the remaining hours. Duval County is another site that uses the first approach.
Los Angeles County offers an example of the second approach. The typical employment plan begins with a four-week job club program, which consists of job preparation and job search activities but can vary considerably after that. Clients who find employment are required to work 32 hours per week. Clients with no jobs at the end of the job club may take one of four paths: the client may attend some type of school program; the client may enter a work experience program; the client may continue looking for a job, relying on the county’s Office of Education or TANF program job developers; or the client may enter specialized supportive services. The only clients who do not go through the job club program are those already enrolled in a self-initiated training or education program or those already employed 32 hours per week.
Kern County provides an example of the third approach. All work-ready clients are assigned to a two-and-a-half-day job-readiness workshop followed by three weeks of a guided job search during which they are required to apply for 25 jobs per week. Clients who are unsuccessful in obtaining employment then complete a comprehensive two-day assessment of their skills, interests, and abilities, with the results informing the assignment of subsequent activities. Clients with personal and family challenges are first referred to a five-day workshop designed to identify mental health, substance abuse, and domestic violence issues. After completion of these initial activities, a social worker and the client develop a formal employment plan that includes the client’s ongoing work activities. Assigned activities depend on the client’s needs and interests and may include employment preparation, job placement, unsubsidized employment, education and training, and behavioral health services. Other sites that use the third approach include Suffolk County, DeKalb County, Pima County, and Salt Lake County.4
[D] |
Some sites have developed specific processes—such as periodic assessments or case conferences—to ensure that clients progress rather than stagnate in the same activity for extended periods.
Some sites have developed specific processes for ensuring that clients progress rather than stagnate in the same activity for extended periods. Some sites implement these processes at major transition points—for instance, at the end of a defined job search period—while others implement them periodically throughout a client’s participation in the program, or when it is evident that a client is experiencing difficulty in obtaining employment. In Kern and Los Angeles counties, clients undergo an extensive vocational assessment followed by a formal employment planning process if they have not found jobs after three weeks of job search. In Georgia, case conferences take place at least every three months and often more frequently for clients who remain unemployed after participating in required work activities at the assigned provider. During case conferences, the client, case manager, case manager’s supervisor, and provider discuss the client’s participation and any issues that may be inhibiting the client’s progress. Staff may also decide to invite to the conference a domestic violence specialist, mental health specialist, or other professional with expertise in various issues that may pose barriers to the client. The conference may lead to modification of the client’s employability plan, and the client may be referred to a new provider that offers a different set of activities or may be better able to address the client’s issues. Tarrant and Duval counties, which assign most clients to the same sequence of initial and subsequent activities, do not have formal reassessment or review processes to determine the appropriateness of assigned activities for individual clients.
For clients with difficult life challenges, most study sites allow a broader set of activities than specified in the DRA, but such flexibility affects the calculated participation rate.
Logistical and personal challenges are common among TANF recipients (Pavetti 2002). Respondents to the survey of frontline staff suggested that the most prevalent challenges facing clients in the study sites are childcare problems, motivational issues, and transportation problems (see Table III.3). In addition, a nontrivial share of respondents cited physical and mental health problems as the most common challenges. Previous studies have found that all of these challenges are more common among sanctioned versus non-sanctioned clients (Cherlin et al. 2001; Kalil et al. 2002; Mancuso and Linder 2001; Hasenfeld et al. 2002; Polit et al. 2001).
|
Percentage of Program Staff Reporting Challenge as One of Two Most Common Challenges Clients Face |
|---|---|
| Childcare problems | 42.3 |
| Motivational issues | 36.9 |
| Transportation problems | 29.7 |
| Mental health issues | 16.2 |
| Physical health issues | 16.2 |
| Homelessness or housing problems | 6.3 |
| Lack of information about program | 5.4 |
| Domestic abuse issues | 4.5 |
| Child behavioral problems | 4.5 |
| Poor education | 4.5 |
| Substance abuse problems | 3.6 |
| Lack of soft skills | 3.6 |
| Sample size | 111 |
| Source: MPR survey of frontline workers. |
Most of the study sites therefore modify work requirements for recipients with personal and family challenges. The sites allowed adjustments after concluding that some clients with challenges would have difficulty fully complying with participation requirements and following the standard sequence of activities. For instance, Kern County recipients with mental health, substance abuse, or domestic violence issues typically are not exempt from participation but may receive special supportive services, a reduction in required work hours, or assignment to activities other than those that are federally countable or allowable. Their participation requirements are based on recommendations from a licensed professional of appropriate activities and hours given their limitations and abilities and may include treatment and in-depth ongoing assessment. In Florida, a case conference is required to establish an alternative participation plan for clients with non-medical challenges such as domestic violence or severe child behavioral problems. Case managers, supervisors, and external social service providers typically attend the conference. Victims of domestic violence may fulfill their participation requirements by filing court injunctions against their abuser and participating in counseling. Clients with other non-medical challenges may be required to participate in a four-week life skills management program to help them learn to cope with the challenges in their lives. Clients may also be referred to the vocational rehabilitation agency or a local mental health or substance abuse treatment provider.
Some sites use specialized staff to work with clients whose challenging circumstances have necessitated adjustments to their work requirements. In Los Angeles County, for instance, clients who have requested assistance with domestic violence, substance abuse, or mental health issues are transferred to the Specialized Supportive Services (SSS) unit. The SSS worker refers clients to specialized contracted service providers for further assessment and participation planning. SSS workers understand the issues and know the providers well, help facilitate receipt of services, and assist in resolving issues related to accessing or using services. SSS clients may work, but their required weekly hours are largely determined by contractor staff and may be few if they require careful attention and therapy. In Utah, case managers determine the activities and hours required of clients with challenging life circumstances. In Suffolk County, staff or contractors with specialized expertise make decisions about work schedule adjustments.
Extending a broad menu of activities to clients with personal barriers to employment can be a strategy for making a no-exemptions policy feasible. Utah, for example, has balanced its no-exemption policy with substantial flexibility for clients with respect to assigned activities. Generally, work-ready clients are required to participate for 30 hours per week in federally defined work activities. They typically begin with two to three weeks of job search followed by placement in a work experience, vocational education, or training program. However, hard-to-employ clients may be referred to a contractor for assessment, case management, job search and job preparation, and job placement and retention services. Clients with substantial personal and family changes may be assigned to a treatment or crisis counseling program. Those with documented disabilities may be referred to the Choose-to-Work program, a collaborative effort of the TANF and vocational rehabilitation agencies, which offers intensive case management and help with work accommodations. Case managers have the flexibility to include tailored activities in a client’s employability plan. For instance, clients with a mental health condition may have attending counseling appointments as the only activity in the plan for a limited period, and a new mother may have attending doctor’s appointments and enrolling in a GED program as the central components of her plan.
Modification of work requirements for clients with personal and family challenges affects work participation rates. Hours spent in activities outside what the DRA considers countable or allowable cannot be counted toward the federal 30-hour requirement for single parents. Thus, in the short term, assigning clients to such activities could reduce the work participation rate by decreasing the numerator without simultaneously decreasing the denominator. Often, however, the rationale for assigning clients to such activities is to enable them to address issues that may pose barriers to their participation in countable or allowable activities, thereby making participation in these activities easier in the future. Agencies making the choice to modify work requirements believe that clients with mental health problems who have received counseling or clients with substance abuse issues who have received treatment will be better prepared to participate in work and work-related activities. To the extent that their belief is borne out, modification of work requirements for clients with personal and family challenges can have a positive effect on work participation rates in the longer term.
Modifying work requirements for clients with personal and family challenges also has implications for sanction rates. By modifying work requirements, program staff attempt to place more realistic demands on clients who may be incapable of participating in work activities for 30 or more hours per week. Sanction rates will likely be reduced if clients are better able to meet the modified requirements. Sanction rates may also be reduced because instead of sanctioning a client who is not meeting standard work requirements, case managers have the option to review and modify the client’s employment plan to reduce the required hours or to replace the required activities with ones that may be more appropriate given the client’s circumstances.
The DRA has not undercut the value study sites place on offering a wide range of activities, though it may be leading some sites to increase their emphasis on federally defined countable and allowable activities. Utah, for example, has been providing an incentive payment of $40 per month since 1994 to TANF recipients who participate in activities that can count toward the federal work requirement for at least 30 hours per week. The state recently increased the incentive payment to $60. In October 2006, about 17 percent of TANF recipients in the central region where the study site visit took place received a bonus payment. In addition, Utah has recently expanded the range of contracted service providers and work placement sites offering federally countable work activities.
Given that case managers often are not trained to recognize mental health, substance abuse, and domestic violence issues, reliance on specialized, credentialed staff and contractors helps TANF program staff identify recipients who may experience difficulty meeting the standard work requirements.
Many welfare offices briefly screen TANF applicants and clients for personal and family challenges that may interfere with program participation. Screening often takes place during standard eligibility and intake procedures, or during the meetings in which clients and case managers develop the client’s employment or personal responsibility plan. This approach to screening relies on the skills of case managers—often generalists who are not trained to identify acute barriers such as mental health, substance abuse, or domestic violence issues—to distinguish between clients with and without specialized service needs. Pima and Duval counties are good examples of this typical approach to assessment. In Pima County, intake workers briefly ask clients about their reasons for requesting cash assistance and about personal and family challenges that may interfere with employment. Once a client is determined eligible, employment program case managers conduct a more detailed assessment after an initial orientation session. The assessment, which includes employment plan development and lasts between 60 and 90 minutes, covers basic background information, employability, family needs, and barriers to employment. Duval County evaluates all TANF clients for their education and reading level (with a tool similar to the Test for Adult Basic Education, or TABE) and completes a checklist during program orientation that assesses client job readiness. Then, during an employment plan development meeting, a case manager informally assesses the client by relying primarily on personal skills and knowledge to determine a client’s special needs.
Some study sites supplement standard assessment procedures by employing the specialized skills of private service providers. Those sites recognize that case managers may not have the requisite skills and expertise to identify, on their own, clients with substantial personal challenges. Suffolk County, for instance, uses a two-stage process to identify clients with substantial personal barriers to participation—a cursory assessment with a TANF agency employability worker and an in-depth assessment with a specialized contractor, which employs state credentialed alcoholism substance abuse counselors. The contractor conducts drug and alcohol, mental health, and physical health assessments as necessary and assists the TANF agency employability worker in determining whether the client is (1) employable with limitations and subject to work requirements; (2) temporarily unemployable and in need of an exemption; or (3) disabled and in need of an SSI referral. The contractor then refers applicants to treatment programs or back to the employability worker for referral to job search.
In Georgia, the role of the private contractor is to triage clients claiming a disability. Certified SSI advocates employed by the contractor conduct an in-depth three-day assessment by using SSI manuals; skills tests; personal profiles; mathematics, reading, and vocabulary assessments; and other tools. Their specialized skills enable them to distinguish among clients with more and less severe conditions, which traditional TANF program case managers previously were unable to do very successfully. Assessments classify clients into one of four groups: (1) disabled; (2) sick with disabling conditions; (3) sick without disabling conditions; and (4) able to work with accommodations. The contractor walks clients in the first three groups who are likely to be approved for SSI through the entire SSI application process. All other clients, regardless of classification, must participate in job search and a variety of workshops that the contractor offers for five days per week and up to 6 hours per day (for a minimum of 24 hours per week), though specific activity requirements vary among clients.
In California, state law requires counties to administer specialized assessments to clients who do not find jobs through initial job search activities. Specifically, the state requires all counties to assess such clients for potential learning disabilities and to ensure that properly qualified and credentialed staff conduct the assessments. Most counties contract with an outside provider to conduct the assessments. Kern County uses an outside agent to conduct an in-depth examination of clients’ capabilities, needs, and vocational potential, and to compile the results into a comprehensive report with recommendations for employment plan development. Areas covered in the assessment include family situation, work history, education, occupational skills, interests, aptitudes, attitude toward and motivation to work, behavior patterns affecting employment potential, family resources and needs, supportive service needs, and personal employment information. Specialized masters-level staff conduct the assessments and compile the results.
Kern County also takes a unique approach to the upfront appraisal the state requires to identify the immediate service needs of newly approved TANF clients. Using a standardized county guide, social workers conduct appraisals for most clients during home visits.5 The guide is divided into five broad sections: (1) household (verification of who resides in the home); (2) resources (child care and transportation); (3) education (completed and current education and training); (4) hurdles (mental health, substance abuse, domestic violence, learning disabilities, and criminal history/legal issues); and (5) employment (past and current). Perhaps the greatest advantage of conducting in-home appraisals is that clients often respond to the questions in the guide more openly and honestly when they are in their home versus in the welfare office. In addition, social workers learn a lot by observing clients in their own home. They can often assess who resides in the household, material possessions, living conditions, and other characteristics not addressed in the appraisal guide but that may affect program participation.
C. Communicating Expectations to Clients
All sites recognize the importance of clearly communicating information to recipients about work requirements, but some sites supplement standard efforts with innovative outreach activities to ensure that messages are heard and understood.
Many TANF recipients do not understand what is expected of them or the penalties for non- participation (Los Angeles County 2005; Hassenfeld et al. 2004; Pavetti et al. 2004; U.S. DHHS 1999; Nixon, Kauff, and Losby 1999; Overby 1998). To address this concern, all of the study sites provide information to clients about work requirements and sanctions at several points and in several formats. At program orientations, which represent the primary venue for such communication, clients usually receive information packets and short handouts highlighting the most important information. They also listen to program staff explain program rules and have an opportunity to ask questions. In addition to orientations, staff use intake interviews, discussions of employment plans, and ongoing case management meetings and telephone calls as opportunities to reinforce information about requirements and sanctions.
Some sites have been particularly innovative in their approaches to communicating with clients and holding their attention during orientations. Orientation in Utah, for instance, includes a PowerPoint presentation that summarizes work requirements, consequences for nonparticipation, and the purpose and structure of the problem-solving process for noncompliant clients. Three slides focus on the consequences of nonparticipation. The first instructs clients that they should call their case manager if they (1) cannot complete an activity in their employment plan; (2) cannot keep an appointment; (3) cannot turn in what the case manager has requested; or (4) have had a change in their situation. The next slide is entitled “What happens if I choose not to do the activities after I have signed the plan?” and explains the problem-solving process and the possibility of consequences for failure to complete the activities in the plan. The final slide describes in detail the consequences for nonparticipation. The use of a visual aid to convey information that is typically presented verbally and/or in writing ensures that recipients with different learning styles have equal access to the information.
Sites with partial sanctions, in particular, supplement standard efforts with additional outreach to ensure that clients hear and understand messages. Partial-sanction sites have considerable incentive to engage in outreach; the more clients understand about sanctions, the more likely they are to avoid them and the fewer clients who are sanctioned, the higher the work participation rates will be. (In full-family sanction sites, in contrast, the more clients who are sanctioned, the higher the work participation rates will likely be since noncompliant clients will be removed from the caseload and thus the denominator of the rate.)
One way that partial-sanction sites conduct additional outreach is through home visits. Los Angeles County, for instance, has established a Home Interview Program (HIP), under which eligibility workers make home visits to help potential TANF clients complete their eligibility applications. The home visits were initially intended to deter fraud, but they now provide potential TANF recipients with information on the county’s employment and training program before approval of their application for assistance. Home visitors provide information orally and in writing on program requirements and available services and set up an appointment for the client’s initial appraisal and orientation. The aim is to reduce the number of people who fail to show up for the initial meetings. The appraisal and orientation appointment is usually made for one month after the home visit, allowing time for approval of the TANF application and for the family to arrange childcare. During home visits, workers also try to identify clients who may be exempt from work requirements or are already in school or working.
Home visits guarantee that clients receive information about work requirements (though they don’t guarantee that clients understand the information). Thus, home visits also may be useful in sites with full-family sanctions where the consequences for nonparticipation are severe. Based on information from MPR’s previous study of TANF sanctions, case managers in at least one local TANF office in South Carolina, a state with full-family sanctions, visit newly approved TANF clients in their homes. During the visits, case managers provide an overview of TANF, conduct an initial client assessment, and inform clients verbally and in writing of the program requirements and consequences of noncompliance.
Effective and consistent communication to clients requires staff themselves to have a strong understanding of policy; often, however, they do not.
Clients are likely to respond positively to work requirements and sanction policies only if they understand them, yet the survey of frontline workers suggests that program staff are themselves often ill-informed about such policies. Many staff erroneously believe (1) that certain circumstances might exempt clients from participation requirements or (2) that other circumstances might not exempt clients from participation requirements (see Table III.4). Almost six percent of frontline workers were not aware of the number of hours that single parents of children over age six must participate in work-related activities (see Table III.5). Many program staff responsible for informing clients about sanctions did not know how a sanction would affect a family’s TANF grant or the time a sanction must remain in effect (see Table III.6). There is no clear evidence that the level of staff knowledge about work participation and sanction policies varies across sites or types of sites (e.g., sites with partial, gradual, or immediate full-family sanctions).
| Circumstance Potentially Meriting Exemption | Percentage of Program Staff | |||
|---|---|---|---|---|
| In Sites Where Clients Are Exempt | In Sites Where Clients Are Not Exempt | |||
| Said Exempt | Said Not Exempt | Said Exempt | Said Not Exempt | |
| Clients with very young children | 67.3 | 30.9 | 38.7 | 61.3 |
| Parents working a certain number of hours per week | 50.0 | 49.1 | 38.7 | 54.8 |
| Clients with disabilities or personal health conditions | 89.1 | 9.1 | 87.1 | 12.9 |
| Clients caring for family members with disabilities | 90.0 | 8.2 | 96.8 | 3.2 |
| Clients beyond a certain point in pregnancy | 87.3 | 11.8 | 35.5 | 61.3 |
| Clients with domestic abuse issues | 80.0 | 14.5 | 54.8 | 35.5 |
| Clients with severe personal and family challenges | 78.1 | 18.2 | 67.7 | 29.0 |
| Sample size | 141 | |||
| Source: MPR survey of frontline workers. |
| Accurate or Inaccurate Staff Statements in Survey Responses | Percentage of Program Staff |
|---|---|
| Said correct number of hours required per week | 70.2 |
| Said fewer hours than required per week | 13.0 |
| Said more hours than required per week | 11.2 |
| Did not know number of hours required per week | 5.6 |
| Sample size | 161 |
| Source: MPR survey of frontline workers. |
| Issue Related to Sanction Policies | Percentage of Program Staff | |
|---|---|---|
| Generally Knowledgeablea | Not Knowledgeable | |
| The effect of a first sanction on TANF grant | 90.0 | 10.0 |
| The effect of a second sanction on TANF grant | 82.3 | 17.7 |
| The effect of a third sanction on TANF grant | 76.2 | 23.9 |
| Minimum time a first sanction must remain in place | 49.2 | 50.8 |
| Minimum time a second sanction must remain in place | 66.9 | 33.1 |
| Minimum time a third sanction must remain in place | 63.1 | 36.9 |
| Length of time clients must participate in activities to end a sanction and receive full benefits again | 60.8 | 39.2 |
| Sample size | 130 | |
| Source: MPR survey of frontline workers. a Staff who are “generally knowledgeable” understand the policy completely or understand the basic features of the policy but not the details as defined by specific criteria (for example, know that a first sanction reduces the TANF grant by a certain percentage, but do not know what the correct percentage is; or know that there is a minimum period of time a first sanction must remain in place, but do not know what the correct period of time is). |
These findings suggest that additional staff training on work requirements, exemptions, and sanction policies and procedures may be warranted in TANF programs across the country. The sites in the study typically conduct training for new frontline workers or all local program staff only after the introduction of significant policy changes. States often provide training to regional directors or local office administrators or supervisors who then must convey the information to subordinates via memoranda or in-person meetings. It is possible that information is lost or misinterpreted as it is conveyed. Previous research, which suggests that staff with more work experience more thoroughly understand sanction policy and the implications of sanctions, also underscores the need for training among workers with less experience in particular (Los Angeles County, 2005).
1 Previously, some states had been counting some job search or job readiness activities, participation in substance abuse or mental health treatment and domestic violence counseling, and caring for a disabled household member as community service. (back)
2 Exemptions from employment and training requirements were broad and included applicants or recipients who were (1) ill or incapacitated or of advanced age; (2) needed in the home because of another family member’s illness or incapacity; (3) the parent or other relative of a child under age 3 who was personally caring for the child; (4) employed 30 or more hours per week; (5) a child under age 16 or attending an elementary, secondary, or vocational school full-time; (6) a woman in at least the second trimester of pregnancy; or (7) residing in an area where the employment and training program is not available. PRWORA passed down to the states responsibility for defining who is and is not required to participate in work activities. (back)
3 Clients who have already completed six weeks of job search activities within a fiscal year are assigned directly to Career Steps. (back)
4 In DeKalb County, however, all TANF applicants go through the same four-week job search program. Once approved for TANF, clients are assigned to activities based on individual needs and interests. (back)
5 The appraisal is conducted in the office if the client has received cash assistance within the last three months. (back)
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