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V. Engaging the Unengaged: Initiatives for Clients in Sanction Status
If efforts to re-engage clients (described in Chapter IV) fail, most sites almost always impose sanctions. Program administrators in most sites believe, however, that, while necessary, sanctions are not beneficial to anyone. They hurt clients by limiting financial assistance to families. They can hurt counties and states with partial sanctions by adversely affecting work participation rates. To reduce the number of clients in sanction status, some sites continue to work with sanctioned clients to identify and address the root causes of their nonparticipation and to encourage rapid participation in work-related activities. These efforts are an acknowledgment that investments in engaging the unengaged may yield more returns for families and programs than allowing noncompliant clients to remain idle on caseloads or even leave caseloads without adequate supports. This chapter describes initiatives implemented by study sites to re-engage sanctioned clients.
Initiatives to engage sanctioned clients serve two purposes, with benefits to both clients and agencies. First, they provide ongoing support to clients who may be particularly vulnerable if their financial assistance is reduced or terminated. Second, they encourage client participation in activities while in sanction status. Clients benefit if the initiatives help them progress toward self-sufficiency while in sanction status. Agencies benefit because compliant clients may be included in the numerator of the federally defined work participation rate when their sanction period ends or when they return to TANF. Just over half (55 percent) of respondents in the survey of frontline staff are responsible for contacting sanctioned clients either by telephone or in person to help them re-engage in program activities (see Table V.1).
|
Among Staff Required to Contact Sanctioned Clients to Re-Engage Them | ||||
|---|---|---|---|---|---|
| A Lot | Some | A Little | None | Don’t Know | |
| Priority that staff place on re-engaging sanctioned clients | 53.4 | 14.8 | 15.9 | 11.4 | 4.5 |
| Amount of telephone contact staff usually have with sanctioned clients | 21.6 | 37.5 | 21.6 | 15.9 | 3.4 |
| Amount of in-person contact staff usually have with sanctioned clients | 11.4 | 33.0 | 27.3 | 26.1 | 2.3 |
| Sample size | 88 | ||||
| Source: MPR survey of frontline workers. |
Sites with partial and full-family sanctions may develop these initiatives for different reasons. Sites with partial sanctions are likely motivated because sanctioned clients remain indefinitely on their caseloads and in the denominator of the participation rate (by federal regulation, sanctioned clients may be excluded from the participation rate calculation only if sanctioned for fewer than three months within a 12-month period). Sites with full-family sanctions may develop initiatives as a safeguard for families that have lost a significant source of financial support along with the employment and supportive services built into TANF. Concern about the well-being of sanctioned families is warranted; previous research has shown that sanctioned families are more likely to experience material hardship than non-sanctioned families (Cherlin et al. 2001; Kalil et al. 2002). In addition, previous studies have found that, while some sanctioned recipients may find employment after closure of their TANF case, they do so at substantially lower rates than non-sanctioned recipients (Born et al. 1999; Edelhoch et al. 2000; Westra and Routely 2000).
Initiatives for sanctioned clients emphasize identifying and resolving barriers to participation, or engaging clients in work activities. Those that focus on barriers to participation generally share three common goals: (1) emphasizing the importance of work requirements, (2) determining which clients are able and willing to participate in work activities and which are not (and why), and (3) informing clients of the supports available while they are in sanction status that may help them resolve issues affecting participation. Initiatives to engage clients in work activities are primarily designed to ensure that clients nearing the end of a minimum sanction period are already participating in a federally acceptable activity so that they can immediately have their sanction lifted and be counted again toward the work participation rate.
Whichever emphasis is adopted, the cost of these efforts confronts agencies with a choice between post-sanction initiatives and earlier preventive approaches. Program administrators who implement initiatives for sanctioned clients have attempted to measure outcomes as a basis for justifying their costs and ensuring that their efforts are cost-effective. After experimenting with initiatives for sanctioned clients, some sites have determined that intensive, upfront efforts designed to avoid sanctions are more productive or efficient than efforts directed to sanctioned clients. Los Angeles County, for instance, found that once clients were sanctioned, home visit staff had difficultly re-engaging them in program activities. Others have experienced positive returns on their investments in post-sanction initiatives, and have continued to hone and even expand programs for sanctioned clients. States and localities with limited resources that are exploring options for engaging unengaged clients may need to consider the trade-offs of offering non-sanctioned clients preventive services early versus offering sanctioned clients supportive services later.
This chapter provides examples of initiatives for sanctioned clients within both categories of initiatives and discusses the resources they require. It also discusses organizational strategies used by some sites to maximize the time and resources available for re-engaging sanctioned clients and clients at risk of sanction.
A. Intensive Efforts to Identify and Resolve Barriers to Participation
Two of the eight study sites conduct outreach to sanctioned clients to identify and address barriers to compliance, using two different models. Kern County relies on in-house staff, while Suffolk County contracts with a community based service agency. Each approach has its respective advantages. In selecting a model, administrators should weigh their relationships with and the strength of community organizations against the skills of their own current or potential staff. The decision may also be a function of the financial resources available to support the effort; in-house services are often less costly than contracted services.
1. Conducting Outreach to and Group Sessions for Sanctioned Clients: Kern County
Kern County uses in-house staff to conduct outreach to and information sessions for sanctioned clients. Together, these efforts help some clients cure their sanctions.
Staff working exclusively with sanctioned clients have the time and resources to obtain comprehensive information about clients’ circumstances.
Several years ago, Kern County designated a sanction re-engagement team (SRT) to reach out to sanctioned clients. Two staff members are charged solely with contacting all sanctioned clients in the county at least once every six months. (This long interval is the standard because many clients remain in sanction status for extended periods; on average there are 500 to 600 cases each month that are sanctioned or in the process of being sanctioned.) Contact with clients occurs primarily through telephone calls and letters, though the SRT occasionally makes home visits to clients who may, for example, be experiencing domestic violence, be physically incapacitated, or have an open child protective services case. Before contacting clients, SRT staff research clients’ cases by using the county’s eligibility and case management databases and conduct criminal background checks.
The SRT’s contact with clients can serve several purposes that together may help to resolve sanction situations. First, SRT staff discuss barriers to employment clients may be facing and to inform clients about resources available to address such barriers. SRT staff may be able to expedite access to certain supportive services, such as mental health services. A second purpose is to identify clients who should not be in sanction status, such as those who are working but failed to report their employment. For clients with medical incapacities previously unknown to program staff, the SRT may be able to obtain verification from a licensed professional to exempt the client from work requirements and reverse the sanction. A third purpose of the SRT’s contact is to inform clients about the steps necessary for curing their sanction, including attendance at an orientation session for sanctioned clients.
Group sessions are an efficient way for staff to explain the steps needed to cure a sanction and the services and supports available to sanctioned clients.
During mandatory sanction orientation sessions, clients wishing to cure their sanctions receive critical information on the process and on the supports available to them. To cure their sanctions, most clients in Kern County are required to participate in a one- to two-hour group session. During the session staff emphasize the importance of the work requirements, schedule appointments for clients to develop compliance plans, and inform clients about in-house and community resources for addressing personal and family challenges. County staff provide information about work and sanction cure requirements while community partners—such as mental health and substance abuse agencies—present information about available resources. The group format ensures that all clients receive accurate and consistent information. Clients may attend the session at any time and often do so only once they are ready to return to compliance. Thus, information they receive on steps required to cure a sanction is current and timely.
Based on information from MPR’s previous study of TANF sanctions, at least one local welfare office in New Jersey conducts similar sessions. In this office, sanctioned clients must participate in a two and a half-hour meeting as a condition of curing their sanctions. The purpose of the meeting is to (1) assess clients’ circumstances, (2) advise clients what they must do to reverse their sanctions, and (3) assist clients in obtaining alternative childcare and transportation assistance (in New Jersey, sanctioned clients are not eligible for these work supports through TANF). A case manger working exclusively with sanctioned clients conducts the meeting. According to other case mangers in the office, centralization of re-engagement efforts reduces their workloads since many clients who indicate an interest in curing their sanctions do not follow through.
A sanction hotline increases the efficiency and utility of the orientation process in Kern County. Clients may call the hotline at any time to hear a recorded message indicating the times and dates of sanction orientations. The hotline also allows clients to indicate their desire to cure their sanction; a recorded message then informs clients of their specific cure requirements (i.e., dates for their required 30-day compliance period).
In-house initiatives to re-engage sanctioned clients need not be costly.
All re-engagement efforts in Kern County are in-house and economical. The total budget for the SRT is $174,539 and covers two full-time social workers who are part of a unit with five other social workers. The unit supervisor oversees all SRT activities. Sanction orientation sessions are held twice a week at a central office and accommodate between 10 and 30 clients. The county kept the costs of the orientation sessions to a minimum by having existing in-house social workers conduct the sessions rather than hiring additional staff or contractors.
While the county’s efforts encourage some clients to participate, many remain sanctioned.
Despite initial efforts, many clients do not follow-through on curing their sanctions. In any given month, about one-quarter of clients contacted by the SRT attend a sanction orientation session; of those, between 38 and 47 percent cure their sanctions. Most do so by coming back into compliance with program requirements; fewer than five percent cure their sanction by disclosing that they are employed or obtaining an exemption. Program staff perceive that outreach efforts have been most successful with clients sanctioned for fewer than six months.
The SRT documented the frequency of barriers it identified among sanctioned clients during client contacts and background research. The SRT indicated that most sanctioned clients have criminal histories and that some have active warrants for their arrest. Another particularly prominent barrier is mental health conditions such as depression, anxiety, and psychiatric disorders. SRT staff also identified issues such as involvement in the child welfare system and substance abuse.
2. Using a Local Social Service Agency to Identify and Resolve Barriers: Suffolk County
Suffolk County contracts with a community based service agency to conduct outreach to sanctioned clients. To save resources, the county limited the type of outreach the contractor conducts and engaged in-house staff to work with specific types of sanctioned clients.
Interaction with sanctioned clients helps staff identify which clients would comply if they received assistance in addressing their barrier.
Many sanctioned clients in Suffolk County remain in sanction status for extended periods. Until recently, a common perception among program staff was that a substantial portion of these clients were content to remain in sanction status and indefinitely accept reduced benefits in exchange for relief from work requirements. Program staff assumed that they would comply with program requirements if they so desired.
To substantiate the reasons that clients remain sanctioned for extended periods, the TANF agency in Suffolk County hired a local organization to assess sanctioned clients during home visits. It hired the Education and Assistance Corporation (EAC), a non-profit social service agency active in the county since 1969. Between 2002 and 2003, EAC staff completed 43-page assessments of 600 to 700 sanctioned clients, documenting reasons for noncompliance and personal and family challenges. EAC found that the majority of sanctioned clients are not in fact content being sanctioned but would comply with program requirements to restore full benefits if they received additional assistance in addressing barriers to participation. The assessment uncovered several barriers—such as domestic violence, mental health issues, substance abuse, and lack of childcare—that could be resolved with additional services.
In response to EAC’s findings, the TANF agency entered into a follow-up contract with EAC in 2004 to conduct the Sanction Intervention Project. Under the contract, EAC meets with clients in a first sanction to explore the reasons for noncompliance, help ameliorate conditions that led to the sanction, and to encourage clients to return to compliance. Meetings take place at one of five TANF service centers in the county and are a condition of continued TANF eligibility; failure to participate in a meeting with EAC results in TANF case closure.
Program administrators and staff believe that contractors will be relatively more successful than TANF case managers in motivating sanctioned clients to comply because clients may perceive contractors as relatively more committed advocates for their needs.
EAC staff emphasize to clients that EAC is not part of the TANF agency and that staff are interested only in identifying families’ needs and supporting their efforts to achieve self-sufficiency. As an unbiased third party, EAC may be better positioned than the TANF agency to convince clients that complying with program requirements is in their interest. As a practical matter, TANF and employment services program staff are often overburdened and do not have time to delve into personal issues with clients. EAC, however, is devoted solely to this task. During meetings with clients, EAC staff explain the sanction process and reasons for the current sanction and educate clients about how to comply with program requirements and restore full benefits. They also identify emotional and other issues families may be facing and provide referrals to their own programs or other social and supportive services. To support its efforts, EAC has compiled an extensive community resource database.
If clients present with barriers to employment (or if they have not had a TANF program employability assessment within the past six months), EAC refers them back to the TANF agency for an assessment. In fact, EAC refers about 95 percent of its clients for an assessment. If clients do not present with barriers to employment, EAC refers them to an employment services case manager for re-engagement in activities. EAC staff actually make the appointments with TANF agency or employment services case managers based on the client’s schedule. EAC has no additional direct contact with clients after making referrals but does track whether clients attended their appointments and whether benefits eventually were reinstated.
Triaging clients in durational sanctions by their willingness to comply is one way to attempt to avert the expenditure of limited resources on those who may refuse to participate in activities until they can receive full benefits in return.
Given the durational nature of second and subsequent sanctions in New York, EAC’s ability to re-engage clients is limited primarily to clients in a first sanction. Most clients in second and subsequent sanctions are reluctant to participate fully in program activities until they may see their sanctions lifted and resume the receipt of full benefits. Thus, instead of expending EAC resources on these clients, the county recently engaged the Special Investigation Unit (SIU) within the Department of Social Services (DSS) to investigate whether fraud explains why clients remain noncompliant and to encourage clients to comply. SIU refers to EAC only clients for whom it finds both no evidence of fraud and a willingness to comply. Such procedures ensures that willing-to-comply clients in second and subsequent sanctions still receive services and that EAC expends resources only on clients for whom investments are likely to pay off in the near term.
After conducting background research on clients in second and subsequent sanctions, SIU schedules meetings with clients at one of the five county TANF service centers. Background research includes a review of Department of Motor Vehicle, credit records, and employment and earnings data from the state Wage Reporting System as well as field work (i.e., driving by a client’s home, talking to neighbors, and visiting local schools). During meetings with clients, SIU staff inquire about current and recent employment, other available income such as support from absent parents, and how the client survives on reduced benefits. The meetings are mandatory; failure to attend may result in TANF case closure.
The SIU meetings result in one of four possible outcomes. If SIU finds no fraud and the client is willing to comply with program requirements, SIU refers the client to EAC for an interview (EAC’s interviews with these clients are the same as its interviews for clients in a first sanction). If SIU finds no fraud and the client is unwilling to comply, no additional action is taken and the sanction remains in place. If SIU finds no fraud and the client indicates no further need for assistance, SIU notifies the appropriate DSS unit of the need to close the case. If SIU finds evidence of fraud, it proceeds with recouping overpaid benefits through direct deductions from the TANF benefit, obtaining a legal order requiring the client to repay the county for benefits obtained fraudulently, or prosecution.
Home visits can be a particularly resource-intensive activity, and successful outreach to sanctioned clients is sometimes possible without them.
Due to resource constraints, EAC is not required or expected to conduct home visits with sanctioned clients. During EAC’s initial study of sanctioned clients, DSS and EAC found the process of scheduling and conducting home visits resource-intensive. It required substantial coordination between DSS and EAC and the constant transfer of management information system data and case files. 1 Thus, the current Sanction Intervention Project does not provide for home visits to sanctioned clients. Rather, EAC staff meet with sanctioned clients at the DSS centers, where staff can use the county’s management information systems to pre-screen clients instead of requiring paper copies of client forms and case files. The $186,000 in TANF funds EAC receives through its flat-fee contract with DSS is sufficient to cover its current outreach efforts. The funds support two full-time EAC staff members, two part-time EAC staff members, and one EAC supervisor, all of whom work exclusively on the Sanction Intervention Project.2
The mandatory in-office meetings EAC conducts with sanctioned clients are generally successful. Most clients who attend the meetings comply with program requirements and see their sanctions lifted. However, a non-trivial portion of clients referred to EAC do not attend the meetings, suggesting that convincing sanctioned clients to attend meetings may be more challenging than encouraging them during the meetings to return to compliance. Table V.2 illustrates the number of clients EAC has served over the past three years and the outcome of its efforts.
| 2004 | 2005 | 2006 | |
|---|---|---|---|
| Cases referred to EAC | 480 | 498 | 680 |
| Cases meeting with EAC | 384 | 319 | 405 |
| Cases with lifted sanctions | 303 | 201 | 385 |
| Cases referred for closurea | 123 | 95 | 137 |
| a These cases either did not comply with the EAC interview or indicated during the interview an unwillingness to comply with program requirements. |
SIU’s experience with clients in a second or subsequent sanction is similar to EAC’s experience with clients in a first sanction. SIU receives about 45 to 50 referrals per month and about half of referred clients initially fail to appear for their SIU interview (though many call to reschedule the meeting). Among the 366 clients SIU reviewed between May and November 2006, 126 (34.4 percent) failed to appear at any time for an SIU interview, 8 requested case closure, and 8 saw their cases closed by DSS before SIU was able to contact them. Program staff estimate that ultimately about 20 percent of sanctioned cases are closed for failure to participate in an SIU interview.
EAC has encountered a range of issues that affect program participation and likely contribute to the rate of noncompliance with EAC and SIU meetings. EAC staff describe the most significant issue as lack of knowledge about program requirements; most clients do not know how to comply. Another major issue is clients’ lack of transportation in a county with limited public transportation given its relatively vast geographic area. SIU staff found fraud in 80 of 366 cases they reviewed from May through November 2006. Most fraud involves unreported earnings.
B. Employment Programs or Policies to Engage Sanctioned Clients in Work Activities
Two of the eight study sites—Tarrant and Suffolk counties—have developed employment programs specifically aimed at sanctioned clients. Both focus on assisting sanctioned clients in getting jobs but follow different approaches. Tarrant County takes an indirect approach; it provides a range of job search and job preparation services. Suffolk County takes a more direct approach; it refers sanctioned clients to a contracted Sanctions Intensive Case Services (ICS) program that, in addition to providing other services, refers the client to a temporary employment agency that makes placements directly into regular paid jobs. Suffolk developed its model only after facing obstacles with initial plans to place sanctioned clients in transitional jobs.
1. Engaging Clients in Job Search and Job Preparation: Tarrant County
Sanctioned clients in Tarrant County may be removed from the TANF caseload, but remain attached to the TANF program through the Rapid Employment Attachment Program (REAP). The Women’s Center, an employment services contractor, operates REAP, which is designed to help sanctioned clients resume full benefit receipt. The program began in 2003 in response to the state’s shift from a partial- to full-family sanction policy. Concerned about the large number of clients at risk of being sanctioned off the caseload as a consequence of the policy shift, Tarrant County sought to design a program that would allow clients to satisfy their work requirements and avoid case closure.
Contracting with one local service provider to re-engage sanctioned clients is administratively efficient; REAP provides a comprehensive set of services to all sanctioned clients for a fixed fee.
The Women’s Center is responsible for all interactions with sanctioned clients, including outreach. The Women’s Center regularly receives a list of newly sanctioned clients. A REAP case manager researches client histories in the county’s eligibility and employment services databases and then reaches out to clients—through telephone calls and postcards—to bring them into the program.
Once program staff have made initial contact with clients, they attempt to engage them in job search activities for four consecutive weeks at 40 hours per week. Activities include structured morning job search classes five days per week, job fairs, resume workshops, and unstructured job searches on site via computer and telephone (comparatively, job search activities for non-sanctioned clients vary among local offices). If a sanctioned client is still on the TANF rolls and allowable weeks in job search have expired, REAP staff attempt to engage the client in a combination of community service, transitional jobs, or other activities as needed. If a client has been sanctioned off the caseload, weeks spent in REAP do not count against the client’s allowable job search weeks. In addition, REAP may tap community partners to assist in serving clients with learning disabilities or mental health needs. REAP clients are provided with childcare assistance, bus passes, and gas cards as long as they participate in work activities. They have access to various written guides on interview skills and resume development.
The $400,000 the Women’s Center receives from Workforce Solutions supports its outreach and engagement efforts with sanctioned clients. Not all of these funds are dedicated to sanctioned clients; part of the $400,000 supports the Center’s other work with TANF clients such as conducting TANF program orientations. Twelve staff work exclusively in REAP.
In light of the diverse needs of sanctioned clients and pressures to re-engage clients rapidly, provider staff must be flexible and creative.
The REAP supervisor seeks to hire staff who are skilled group facilitators, creative thinkers, and good motivators. These characteristics are important because REAP staff must be able to handle the unpredictability and diversity of clients’ needs and respond to pressure to serve clients quickly (recall that that to cure a sanction, clients must perform 30 consecutive days of work activities and 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). In particular, the supervisor hires staff willing and able to alter the structure and content of classes they conduct to accommodate the classes’ constantly shifting composition. REAP typically serves approximately 30 clients at any one time, but clients constantly cycle in and out because enrollment is rolling. The supervisor also tries to hire staff skilled at motivating favorable behaviors. One of REAP’s greatest challenges is engaging clients in the program long enough to cure sanctions. Clients are often angry about their sanctions and harbor hostility toward TANF program staff. In response, staff emphasize that REAP is “not part of the sanction, but part of the solution” and clarify to clients that REAP staff did not make the sanction decision. Still, no more than five clients cure their sanctions in an average month.
2. Engaging Clients in Unsubsidized Jobs: Suffolk County
In 2006, New York State appropriated $15 million for outreach to sanctioned clients and noncompliant clients at risk of sanction. Local districts received shares of the appropriation according to the percent of their caseloads in sanction status or in the sanction process. The appropriation was intended to acknowledge that the state’s many noncompliant families adversely affect the denominator of the participation rate and that additional outreach might re-engage these families. Suffolk County received $286,787 from the appropriation in early 2007 and is using the funds to expand EAC’s role in re-engaging sanctioned clients.
Suffolk’s new project targets clients who are in second or subsequent sanction status, have been through SIU (see above), and have indicated a willingness to return to compliance. This approach prevents the expenditure of resources on clients who do not need or want services or supports. EAC conducts home visits with clients to identify how they live on a reduced grant and whether they are immediately employable. Compliance with the visit is mandatory; failure to comply results in TANF case closure. After the visit, EAC refers clients immediately employable to a temporary employment agency for job placement. EAC has hired a program coordinator, senior case manager, two case managers, case management supervisor, and vocational counselor for this initiative.
Use of a temporary employment agency to place sanctioned clients in jobs is mutually beneficial; the temporary agency increases its volume of business, and the TANF agency and its clients gain access to employers.
EAC uses a temporary employment agency to place clients directly into jobs. The agency conducts some screening and officially hires clients it finds acceptable for employment. It then refers clients to specific unsubsidized jobs in private businesses. Jobs are plentiful and always available, though they may be entry-level, may not be in the clients’ areas of interest, and may be limited to as few as 25 hours per week. However, all jobs provide clients with a paycheck and work experience. Once clients are placed in jobs, EAC helps them arrange transportation and childcare and provides ongoing case management as they adjust to the workplace. To date, 8 of the 12 clients EAC referred to the employment agency have obtained permanent jobs through their initial temporary placements. While the employment agency does not receive any direct financial gain, it benefits from a steady stream of customers from the TANF agency.
EAC refers clients who are not immediately employable to the appropriate services and transports and escorts them to and from those services. This ensures that they receive the attention they need to address their issues and that EAC does not jeopardize its relationship with the employment agency by referring clients poorly prepared for work. Most clients are not immediately employable. Of 76 clients referred to EAC through March 2007, EAC successfully conducted home visits with 50 to 60 and found only 12 to be job-ready. The largest number of referrals for clients who are not job-ready is for physical and mental health assessments.
Encouraging employers to offer jobs to sanctioned clients is challenging; many employers require a high school education, and wage subsidies are insufficient to convince them to relax this requirement.
Suffolk County’s original intent was to place employable clients into transitional jobs with private employers. EAC planned to recruit employers willing to offer jobs to clients within a week of EAC’s home visit. EAC staff would serve as on-the-job coaches/mentors for a minimum of 90 days, and EAC would subsidize clients’ wages at 75 percent in two-week intervals for a maximum of six weeks. If the employer retained the client as an employee for an additional six weeks, then EAC would pay the employer the remaining 25 percent of the client’s wages for the initial six-week period.
When EAC began recruiting employers to offer transitional jobs, it struggled to find employers willing to accept clients without a high school diploma or GED. The advantages of subsidized wages and a pre-screened group of potential employees (the TANF and/or temporary agency screens clients for mental health, physical health, and substance abuse issues as well as for criminal background) were insufficient to convince employers to accept clients with less education. EAC is still pursuing employers, however, and hopes to offer transitional jobs in the future.
3. Engaging Clients in Federally Countable Activities by Offering Incentives: Georgia
Offering supportive services to sanctioned clients who find jobs or participate in work activities can be an effective incentive to engage such clients in federally countable activities.
Georgia tries to encourage sanctioned clients to find jobs or participate in program activities by providing them with incentives rather than services. Given that Georgia’s cash grant is relatively low (the cash grant for a family of three is $280), many families applying for TANF are more interested in childcare assistance than cash assistance. In Georgia, however, any TANF sanction—that is, a grant reduction or termination—automatically discontinues childcare and transportation assistance. Recently, to encourage clients to work or participate in activities while in sanction status (clients in sanction status are not required to participate in activities but may do so), the state restored access to childcare and transportation assistance to clients who do so. This policy change not only helps sanctioned clients by enabling them to maintain vital supportive services and rewarding them for continued efforts toward self-sufficiency, but may also help the state boost its work participation rate. Sanctioned clients who work or participate for the requisite number of hours per week may be counted in the state’s numerator.
C. Organizational Strategies to Support Re-Engagement Initiatives
The process of imposing sanctions can be lengthy and can drain staff resources that might otherwise be used to interact with clients, particularly noncompliant clients.
Imposing sanctions can be a complex process. In some sites, imposition of a sanction is a relatively straightforward, mechanical process that involves changes to a few codes in the management information system. The process can be more complicated and time-consuming, however, if it also requires program staff to change or open a separate food stamp or Medicaid case or to terminate or reduce any additional assistance, such as childcare assistance or rent supplements, the family may have been receiving. The process of imposing a sanction can take a few months and can require program staff to produce extensive documentation and obtain supervisory approval. Table V.3 presents what it takes to impose a sanction in each site, and Table V.4 indicates the amount of time and level of effort needed for respondents to the survey of frontline staff to impose sanctions.
| Average length of time from first sanction notification to sanction imposition | Number of staff involved in process | Minimum number of required notices to client | Supervisory approval required | |
|---|---|---|---|---|
| Suffolk County, NY | 2 months | 3 | 2 | Yes |
| Pima County, AZ | 1-2 months | 2 | 4 | Yes |
| Duval County, FL | 1 month | 2 | 3 | No |
| DeKalb County, GA | 1 month | 1 | 2 | Yes |
| Tarrant County, TX | 1 month | 2 | 3 | Yes |
| Los Angeles County, CA | 21 days | 2 | 4 | Yes |
| Kern County, CA | 1-2 months | 2 | 2 | No |
| Salt Lake County, UT | 1 month | 2 | 3 | Yes |
Division of labor can help maximize the resources available for specialized re-engagement efforts.
Some sites have tried to ease the burden of imposing sanctions through greater division of in-house staff responsibility. Traditionally, case managers or eligibility workers in most sites have been responsible for making changes in the management information system to impose sanctions. Some sites, however, have designated one staff person (Duval County in Florida, and Arizona, for instance) or created a separate unit (Texas and Suffolk counties, for instance) that is solely responsible for imposing sanctions. Based on information from MPR’s previous study of TANF sanctions, offices in Illinois also have designated one staff person and offices in New Jersey also have designated a separate unit to process all sanctions. Sites that have designated a specific person or unit have done so largely in an effort to improve the timeliness of sanctions and to free up resources for conciliation and other re-engagement activities.
Historically in Arizona, eligibility workers imposed sanctions by making electronic changes in the management information system. Case managers had to request that eligibility workers make the changes, including a shift from a 25 percent grant reduction to a 50 percent grant reduction and from a 50 percent reduction to benefit termination for clients who do not participate in activities from one month to the next. If case managers did not request or eligibility workers did not implement second- or third-level sanctions, clients’ full grants were automatically restored. Eligibility workers, however, had difficulty making electronic changes in a timely way. As a result, clients who were supposed to move to higher-level sanctions saw their full grant restored. Two changes in Pima County improved the process. First, the county centralized all sanction responsibilities so that one eligibility worker carries out all sanction actions. The worker has thus far experienced no difficulty in imposing sanctions within the required timeframe. Second, by the fifth of each month, the employment and training supervisor provides the eligibility worker’s supervisor with a list of all needed sanction actions for the month. Both changes have reportedly improved the timeliness of sanctions.
Percent of Program Staff |
||
|---|---|---|
| Required to provide supervisors with written documentation of efforts to encourage participation before sanctioning | 47.8 | |
| Among those required, percent who think that the documentation process requires | A lot of effort | 37.7 |
| Some effort | 41.6 | |
| Not very much effort | 16.9 | |
| No effort at all | 1.3 | |
| Don’t know | 2.6 | |
| Personally required to change codes in the computer system to impose a sanction | 49.1 | |
| Among those required, percent who think that the process of changing codes is | Very easy | 50.6 |
| Somewhat easy | 41.8 | |
| Somewhat difficult | 5.1 | |
| Very difficult | 1.3 | |
| Don’t know | 1.3 | |
| Required to send a request to someone else to impose a sanction in the computer system | 19.3 | |
| Among those required, percent who need supervisory approval before making the request | 32.3 | |
| Time it takes staff to make first change in the computer system to impose a sanctiona | Less than 1 month | 74.5 |
| 1 to 2 months | 14.5 | |
| 3 to 4 months | 0.9 | |
| More than 4 months | 0.0 | |
| Don’t know | 10.0 | |
| Time entire sanction process takes | Less than 1 month | 16.8 |
| 1 to 2 months | 63.4 | |
| 3 to 4 months | 8.7 | |
| More than 4 months | 1.2 | |
| Don’t know | 9.9 | |
| Percent who think imposing sanctions is | Very easy | 21.7 |
| Somewhat easy | 39.8 | |
| Somewhat difficult | 25.5 | |
| Very difficult | 7.5 | |
| Don’t know | 5.6 | |
| Among those who think imposing sanctions is difficult, reasons for difficulty | Length of process | 20.8 |
| Bureaucratic hurdles/required documentation | 28.3 | |
| Personal sympathy for client or family | 11.8 | |
| Opportunities for conciliation | 22.6 | |
| Another reason | 28.3 | |
| Sample size | 161 | |
| Source: MPR survey of frontline workers. a Percents are based on the 110 respondents who said that they are personally required to make changes in the computer system or to send a request to another person or agency to impose a sanction in the computer system. |
Similarly, in Suffolk County, staff in DSS’s eligibility and ongoing benefit determination units used to be responsible for imposing sanctions, but heavy workloads prevented them from doing so in a timely fashion. Since the county implements partial-sanctions, nonparticipating clients (not counted in the numerator of the county’s participation rate) were remaining in the denominator of the work participation rate for extended periods while awaiting sanction processing. In response, DSS’s Compliance Unit assumed all responsibility for processing sanctions. According to a local office memorandum, “This workflow change was developed to decrease processing time and improve the district’s employment participation rate.” Since the shift of responsibility to the Compliance Unit, sanction processes are indeed progressing more rapidly.
Other sites have attempted to maximize the resources available for re-engagement efforts by hiring specialized staff or creating specialized contracts. Georgia and Los Angeles, Kern, and Suffolk counties have all hired staff exclusively dedicated to one or more sanction-related functions (i.e., home visits and other outreach efforts to noncompliant clients and formal or informal conciliation with noncompliant clients). In addition, Suffolk and Tarrant counties have entered into contracts with local, community-based nonprofit organizations to provide services to sanctioned clients. Reliance on specialized staff or contractors—rather than case managers or in-house staff with other responsibilities—to perform outreach and conciliation enables dedicated staff to focus all of their time and energy on assisting sanctioned clients and to engage frequently with clients around participation issues.
1 The cost of conducting the actual home visits (i.e., travel and deployment of EAC staff) was relatively less problematic. (back)
2 There are no funds dedicated specifically to SIU for this initiative; SIU simply absorbed new responsibility for working with sanctioned clients into its routine functions. However, two investigators and one SIU supervisor work exclusively with clients in second or subsequent sanction. (back)
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