ACF OPRE: Sanction Policies

Executive Summary

The 1996 Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) provided a block grant to states to create the Temporary Assistance for Needy Families (TANF) program. In doing so, it required states to engage certain minimum percentages of their TANF caseloads—50 percent of all families and 90 percent of two-parent families—in specified work and work-related activities for a specified number of hours per week. Sanctions, or financial penalties for noncompliance with program requirements, have long been perceived as a major tool for encouraging TANF recipients who might not be inclined to participate in work activities to do so. The logic behind sanctions is that adverse consequences—such as a reduction in the TANF cash grant (a partial sanction) or gradual or immediate termination of the TANF grant (a full-family sanction)—can help influence the participation decisions that welfare recipients make.

In reauthorizing the TANF program, the Deficit Reduction Act of 2005 (DRA) changed the way the work participation rates are calculated and thereby effectively increased the rates required of states. Work participation rates are calculated by dividing a numerator consisting of “participants”—families engaged in federally acceptable work activities for the requisite hours per week—by a denominator that is a count of “total families.” Largely because states received credits in their participation rates for caseload reductions that occurred after 1995 and because the count of “total families” included only certain TANF recipients, the real rates that states had to meet prior to the DRA were substantially below 50 and 90 percent. As of fiscal year 2007, states will receive credits in their participation rates for caseload reductions that occur after 2005 and the count of “total families” will include TANF recipients as well as families receiving assistance through separate state programs that count toward maintenance of effort (MOE) requirements. Because of these changes, states now face the challenge of achieving participation rates that are considerably higher and close to the 50 and 90 percent standards set in the law. As states consider their options for meeting the higher work participation rates, they are likely to consider how they might redefine their TANF and separate state programs and make better use of sanction policies and procedures to encourage higher levels of participation in program activities.

Sanctions may influence the work participation rate in one of two ways. First, sanctions may encourage recipients who are not inclined to participate in program activities to do so. In this case, a state’s work participation rate will be higher than it would be in the absence of sanctions because the numerator of the rate will increase. Second, when gradual or immediate full-family sanctions are applied to noncompliant recipients, they eliminate those clients from the TANF caseload (thereby removing them from the denominator of the TANF work participation calculation). Sanctions may also influence the participation rate indirectly if information about work requirements and penalties for noncompliance lead some people never to apply for assistance in the first place or to leave the caseload on their own.

States can use the sanction process in one of two ways to affect either the numerator or the denominator of the participation rate—they can change sanction policies or they can change sanction procedures. Examples of changes to sanction policies include changes to (1) the effect of the sanction on the TANF grant (i.e., whether it is reduced and by how much or whether it is terminated and when), (2) the length of time a sanction must remain in place, (3) what a family must do to be considered compliant again and resume full receipt of benefits after a sanction, or (4) the consequences for multiple acts of noncompliance. Examples of changes to procedures include (1) implementing new outreach and service strategies to encourage noncompliant recipients to begin participating and reduce the likelihood that a sanction is ever imposed, (2) implementing strategies to impose sanctions more quickly so that noncompliant clients do not remain in the caseload and in the denominator of the participation rate longer than necessary, and (3) implementing new initiatives to re-engage already sanctioned clients in program activities. Changes to procedures indirectly related to sanctions may also affect the participation rate—for example, changing the way participation is monitored so that noncompliance may be identified and addressed more rapidly.

This report documents how some jurisdictions are responding, in their sanction policies and procedures, to the new participation rate requirements imposed by federal law. It is based on a study conducted by Mathematica Policy Research, Inc. (MPR) of sanction policies and practices in eight sites located in seven states. With one exception, the sites included in the study did not introduce major changes to the basic structure of their sanction policies—that is, the effect of sanctions on the TANF grant. They did, however, implement changes to other aspects of sanction policy and/or procedures in an effort to increase engagement in work and work-related activities. After briefly describing the study’s research questions and methodology, the Executive Summary of this report highlights key innovations implemented in the study sites and summarizes what we learned from the study sites’ experiences. It concludes with a discussion of next steps for furthering our understanding of the impact of various sanctioning approaches on increasing participation in work activities and improving recipients’ overall well-being.

Research Questions and Study Methodology

The primary objective of the 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. A secondary objective was to define a future research agenda to address outstanding questions about sanction policies and practices. Given the study’s primary objective, sites were selected purposively to maximize variation along key policy and programmatic dimensions. Table 1 identifies the study sites and some key characteristics. To accomplish both objectives, the study addressed five key research questions:

What sanction policies exist, how have they changed, and what has been the role of sanctions in encouraging participation in work activities?
How are sanction policies implemented at the local level?
What strategies do states/local sites use to avoid imposing sanctions?
What strategies do states/local sites use to re-engage noncompliant clients?
What future research could advance understanding of how sanctions increase engagement and participation rates?

To answer the research questions, MPR collected data from three sources: (1) in-depth case studies in all eight sites; (2) a telephone survey of frontline TANF program staff (primarily case managers and eligibility workers) in all eight sites; and (3) administrative data systems in three sites. The purpose of the case studies was to gather qualitative information from a variety of sources to create a comprehensive picture of the implementation of sanction policies and procedures. The purpose of the survey was to shed additional light on (1) how staff perceive the role of sanctions; (2) the extent to which staff understand sanction policies and procedures; (3) the extent to which staff use discretion in the sanction process; and (4) the way in which staff use sanctions to encourage program participation. The purpose of the administrative data analysis was to explore through outcome data the relationship between sanction policy and procedural changes and engagement in work and work-related activities.

Table 1. Study Sites
Site	Major City in or Closest to Site	Type of Sanction	County Work-Mandatory TANF Caseloada
Texas—Tarrant County	Fort Worth	Immediate full-family	5,800-6,000*
Florida—Duval County	Jacksonville	Immediate full- family	900*
Utah—Salt Lake County	Salt Lake City	Gradual full-family	1,600-1,700
Arizona—Pima County	Tucson	Gradual full-family	1,000-1,100
Georgia—DeKalb County	Decatur/Atlanta	Gradual full-family	700-800
California—Los Angeles County	Los Angeles	Partial	26,000-27,000
California—Kern County	Bakersfield	Partial	6,000-7,000
New York—Suffolk County	Long Island	Partial	1,000-1,500

a County or regional work-mandatory TANF caseloads reported during fall 2006. *Indicates regional, rather than county, TANF caseload.

Key Innovations Implemented in the Study Sites

The study sites made different decisions about better use of sanction policies and procedures to achieve work participation rates. Facing a scarcity of evidence on effective strategies for engaging large numbers of recipients in work and work-related activities, the study sites relied on their professional judgment to decide how to use their limited resources to increase participation in these activities. Several factors influenced their decisions including: the type of sanction policy already in place; how roles and responsibilities were allocated between staff in the welfare office and contracted service providers; the site’s overall philosophy and approach for helping recipients make the welfare-to-work transition; the number of families subject to work-oriented sanctions; the availability of funds to implement special initiatives; the availability and use of information on the characteristics and needs of sanctioned families; and legislative or legal constraints. The strategies implemented by the sites with respect to sanctions fall into six broad categories:

Changing sanction policies
Defining and communicating information about work requirements
Monitoring program participation and identifying noncompliance
Re-engaging noncompliant clients before imposition of a sanction
Revising processes to impose sanctions more efficiently
Re-engaging noncompliant clients after imposition of a sanction

Most program administrators and staff in the sites perceived the changes they made in these areas as improvements that will contribute to increased participation rates. However, little to no data exist to provide evidence of their effectiveness. The bullets below highlight innovations among the sites in the six areas. Information in the text boxes presents findings from the administrative data analysis on the outcomes of strategies implemented in Texas, Georgia, and Los Angeles County. Despite the lack of proven effects, program administrators in other states and localities might want to experiment with some of the strategies listed below or use them as a springboard for other ideas on revising sanction practices or implementing new re-engagement initiatives.

Changing Sanction Policies

In recent years, many states have changed the basic aspect of their sanction policy—the effect of a sanction on the TANF cash grant—sometimes as part of a larger reform of their welfare systems. All states that have done so have moved to a more stringent model—that is, from a partial to a full-family (six states) or from a gradual full-family to an immediate full-family sanction policy (three states). Other states have made changes to other dimensions of their sanction policy, some of which have increased and others that have eased the stringency of sanctions, while maintaining the policy’s basic structure with respect to effects on the TANF grant. One of the states in the study—Texas—made major changes to the basic structure of its sanction policy and others made more minor changes along other dimensions.

Shift from a partial to full-family sanction. In September 2003, Texas shifted from a partial to full-family sanction with strict cure requirements. Before 2003, failure to comply with work requirements resulted in a benefit reduction equal to the entire adult portion of the grant. Repeat acts of noncompliance had the same effect on the TANF grant but were subject to progressively longer minimum sanction periods. The new policy requires termination of the TANF grant for one month for all clients who fail to meet their work activity hours. During that month, clients remain on the caseload in sanction status. After a second consecutive month of noncompliance, Texas drops clients from the TANF rolls completely. To cure a sanction, clients must perform one month 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.

Outcomes of the Shift from a Partial to Full-Family Sanction—The Case of Texas

In the wake of its new policy, Texas has experienced a substantial increase in its work participation rate—from 28.1 in FY 2003 to 34.2 in FY 2004. Administrative data suggest that the increase in Texas’ work participation rate likely resulted from several different factors. First, the number and proportion of cases participating in work activities was higher immediately after the implementation of full-family sanctions than before, but declined over time to levels similar to those among cases subject to partial sanction policies. More importantly, however, the caseload—the denominator of the participation rate—declined. The rate of sanctioning in Texas did not change when the state shifted to an immediate-full-family sanction policy. However, substantially more cases subject to the full-family policy left the caseload over the course of a year than those subject to the original partial sanction policy. Either they were sanctioned off the caseload or they left voluntarily, perhaps after taking the work requirements and stricter consequences for noncompliance into account. After the policy change was implemented, many families left the caseload for employment (and more did so than before the policy change), however, they do not affect the work participation rate because they are no longer part of the TANF caseload. In addition, while 1.7 times as many people left TANF with or for employment in the year after the policy change than in the year before it, 2.5 times as many left TANF without employment. The administrative data, however, cannot distinguish the effects of changes in sanction policies from the effects of other factors, such as other changes in TANF policy or practice, economic influences on the behavior of low-income families, or changes in policy or practice in other programs serving low-income families.

Increased penalties for multiple sanctions. In 1994, using federal waivers, Utah began using a gradual full-family sanction to encourage clients to participate. 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. Before, all sanctions resulted in a $100 grant reduction for two months followed by case closure for continued noncompliance. Now, first sanctions result in $100 reduction in cash assistance for one month followed by case closure for continued noncompliance. Second sanctions result in immediate case closure for at least one month and all subsequent sanctions result in immediate case closure for at least two months.
Elimination of durational sanctions. 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.

Defining Work Requirements and Communicating Information About Them

The DRA’s Interim Final Rules reduced the flexibility afforded to states to define what activities count toward the work participation rates. States still have the flexibility, however, to decide what recipients are required to do and may allow participation in 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 (though only those participating for at least an average of 30 hours per week may be included in the numerator of the participation rate). Acknowledging that many TANF recipients do not understand either what is expected of them or the consequences for not meeting those expectations, all of the sites tried to do a better job of communicating information about work requirements and sanctions to clients. Their hope was that the more clients understand about program rules, the more likely they would be to abide by them, and the more clients understand about sanctions, the more likely they would be to avoid them.

Employability plans that go beyond hours of work required for federal work participation rate. 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. 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.
Employability plans that include a broad range of activities. Most study sites allow a broader set of activities than specified in the DRA for clients with difficult life challenges. Offering a broad menu of activities can make it feasible to provide limited or no exemptions from work participation requirements. Utah, for example, provides no exemptions from work requirements but offers substantial flexibility for clients with respect to activities. Work-ready clients typically are assigned to job search followed by placement in a work experience, vocational education, or training program. However, clients with substantial personal and family changes may be assigned to a treatment or crisis counseling program and those with documented disabilities may be referred to a program that offers intensive case management and help with work accommodations through a collaborative effort between TANF and vocational rehabilitation agencies.
Home visits during the TANF application process. In Los Angeles County, eligibility workers make home visits to help potential TANF clients complete their TANF applications. Home visitors provide information orally and in writing on program requirements, consequences for noncompliance, and available services. They 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).
A statewide social marketing campaign. In 2004, Georgia initiated a statewide social marketing campaign entitled, “The Right Work the Right Way.” The goal was to change the culture of the welfare agency by reeducating administrators, welfare program staff, contracted service providers, and clients about the importance of work. In addition to encouraging counties to engage more TANF recipients in work and work-related activities, the initiative encouraged counties to move more TANF applicants away from the welfare rolls and toward stable employment. While Georgia always had an upfront applicant job search requirement in place, many counties—in response to the initiative—modified the way in which they implement the upfront job search process.

Outcomes of a Statewide Social Marketing Campaign—The Case of Georgia

Georgia’s TANF caseload has declined consistently and substantially since 2004 and, at the same time, its participation rate has been rising sharply—from 10.9 percent in FY 2003 to 24.8 in FY 2004 and 69.0 percent by April 2006. Administrative data suggest that the state has moved more TANF applicants away from the rolls, but has not increased the absolute number of recipients engaged in work activities. Since the implementation of the initiative there has been no net increase in the number of families meeting the federal work requirements. It does appear, however, that the strong messages about work and program expectations communicated by program staff to applicants may be dissuading families from ever applying for TANF. The number of TANF applications steadily increased between FY 2000 and FY 2003 and then steadily decreased between FY 2003 and FY 2006. Application approval rates have also decreased substantially, and those who do apply are increasingly being denied because of failure to cooperate with eligibility requirements (most typically the up-front job search) or voluntary withdrawal of their applications. It is likely that many of those who could not or would not comply with work requirements during application would not be able or willing to comply with work requirements once on the rolls. Trends in outcomes, however, cannot be definitively linked to changes in the state’s initiative rather than concurrent changes in policy or other factors.

Monitoring Program Participation and Identifying Noncompliance

To ensure that clients comply with program requirements, TANF agency staff in all sites closely monitor clients’ participation in required activities. Some sites attempted to improve the processes of monitoring participation to identify noncompliance more quickly. Their goal was to decrease the amount of time clients remained noncompliant and in the denominator of the participation rate without being in the numerator.

A specialized monitoring and tracking unit. In an effort to create an efficient system for collecting information on program participation, Suffolk County created a specialized monitoring and tracking unit in which staff members are solely responsible for collecting participation data. Each staff member is assigned to one of five types of employment services (employment, work experience, job search, education and training, or medical follow-up) and collects participation information for all clients receiving that service. Staff members in other units handle other time consuming functions such as employment plan development and case management.
A web-based reporting system. Utah created a new web-based management information system called YODA (Your On-line Data Access) that allows case managers to monitor the work participation of each client in real time. Program administrators, supervisors, and front-line staff can view clients' participation hours and activities from their workstations at any time. Case managers use reports from the system regularly to identify those meeting the federally defined work participation rate and to alert them to clients in need of reengagement. Supervisors also use reports from the system regularly to hold case managers accountable for assigning clients to appropriate work activities and hours and monitoring their ongoing program compliance.
Liaisons between contracted service providers and case managers. In DeKalb County, three staff members, called community resource specialists, act as liaisons between contracted service providers and case managers. In addition to receiving daily participation reports from providers, they visit providers several times a week to collect more detailed information about clients with personal and family challenges and to problem-solve directly with clients. The specialists relay information about clients’ circumstances to case managers and immediately inform case managers when a client stops participating, allowing case managers to act quickly. Rapid action prevents issues from remaining undetected or ignored due to lags in communication between providers and case managers.

Re-engaging Noncompliant Clients Before Imposition of a Sanction

Some sites have established formal processes that provide noncompliant clients with an opportunity to address participation issues and conciliate impending sanctions. Typically, discussions between noncompliant clients and program staff about participation issues occur informally and during impromptu telephone or in-person conversations. In the absence of specific procedures for addressing participation issues before a sanction, however, the likelihood of any dialogue between client and case manager often depends on the client-case manager relationship. Establishing a protocol can ensure that all noncompliant clients have the same opportunities to present evidence of good cause for their nonparticipation and/or to work with program staff to resolve barriers to participation and develop a plan for future compliance.

Problem solving sessions with highly skilled staff. Utah provides nonparticipants with an opportunity to identify and resolve issues before the imposition of sanctions through a two-phase problem solving process. The first phase is a meeting between the client, case manager, and a social worker. The second is a case conference with a wider variety of staff and partners such as child welfare agency staff, employment service providers, probation officers, and mental health therapists. Including these individuals provides different perspectives on how best to assist the client in resolving participation issues and identify available supports. It also ensures that several people review a case before it is sanctioned off TANF, providing a check on the decisions of case managers who have substantial discretion in initiating the sanction process.
Mediation sessions with on-the-spot decision-making. In Suffolk County, a TANF agency staff member who is responsible for imposing sanctions and a mediator (who is employed by the county) meet with each noncompliant client. The meeting provides an opportunity for the client to explain his or her circumstances and present evidence of good cause. To create a relaxed atmosphere and avoid confrontation between the client and the staff member who recommended the sanction, employment services counselors (or case managers) do not participate in the meeting. The county has recently expedited the mediation process. Staff used to take a few days to weeks to decide whether a sanction was warranted based on the mediation and used to notify clients of the decision by mail. Now, they make decisions on the spot so that clients who are not sanctioned as a result of the meeting can re-engage in program activities immediately. The mediator physically walks clients back to the employment services staff who re-engage them then and there.
Home visits to encourage compliance planning. California requires all noncompliant clients to attend a meeting to determine whether good cause exists and, if not, to develop a written plan for the client’s return to compliance. The compliance plan is distinct from the client’s original employment plan in that it specifies the activities in which the client must participate in order to avoid a sanction. It usually includes the activity in the original employment plan that is associated with the client’s noncompliance. However, it may also include additional or alternative activities that may be more reasonable for the client to accomplish or that may be useful for the client’s continued participation. In Los Angeles County, clients are notified by mail that a home visit will occur one day after the meeting if the client does not attend. The notification of possible home visit alone seems to “shock” clients into complying. Most never actually receive a home visit. Rather, they receive notification that a home visit might occur and develop a compliance plan to avoid the visit.

Outcomes of Home Visits to Encourage Compliance Planning—The Case of Los Angeles County

In the first year of implementation of the home visiting project, 41,233 TANF recipients in Los Angeles County were deemed noncompliant and potentially subject to home visits. Among them, 77 percent successfully resolved their noncompliance sanction and only one in ten of those required a home visit; 11 percent were sanctioned and 12 percent were pending. The number of recipients sanctioned in Los Angeles County has been declining since implementation of the home visiting project due to both a reduction in new (initial and subsequent) sanctions and an increase in the number of sanctions cured or resolved. However, factors other than the home visiting initiative may have influenced the rates of sanction and sanction resolution, and the changes in those rates have not translated into an increase in the county’s work participation rate. Many noncompliant clients had their cases resolved in a manner that presumably would have a positive effect on the county’s work participation rate; 22 percent agreed to participate in work activities, and another 7 percent were employed. At the same time, many other cases were resolved in a manner that would have an adverse effect on the county’s work participation rate; one-third were found to be exempt from work requirements or to have good cause for not participating. Many of these cases likely would remain in the denominator and out of the numerator of the participation rate.

Revising Processes to Impose Sanctions More Efficiently

In most of the study sites, case managers had high caseloads and multiple responsibilities. With high caseloads or workloads, case managers often are able to identify and address clients’ personal and family challenges only after a finding of noncompliance and then only to a limited extent. In addition, the process of imposing sanctions can be complicated and time consuming for case managers or eligibility workers who may put the process off in the face of competing demands for their time. Inefficiencies in sanction processes can hurt work participation rates. Thus, some sites took steps to improve the efficiency of the process for imposing sanctions and implementing re-engagement efforts to reduce the amount of time noncompliant recipients spent in the denominator without being in the numerator.

Specialized staff for imposing sanctions. Pima County, AZ and Duval County, FL counties have designated one staff person, and Tarrant County, TX and Suffolk County, NY have designated a separate unit that is solely responsible for imposing sanctions. In Pima and Suffolk counties specifically, responsibility for imposing sanctions used to lie with eligibility workers, but heavy and diverse workloads prevented them from imposing sanctions in a timely manner. Both counties made the change in structure in an effort to speed the sanction process and have indeed minimized the time clients spend in the denominator of the participation rate while awaiting sanction processing.
Specialized staff for sanction prevention or re-engagement activities. Four counties in the study—Los Angeles County in CA, Kern County in CA, Suffolk County in NY, and DeKalb County in GA—have hired staff specifically and exclusively dedicated to one or more sanction-related functions, such as home visits, other outreach efforts to noncompliant clients, and formal or informal conciliation with noncompliant clients. Such specialized staff can focus all of their time and energy on participation issues while case managers or other in-house staff must divide their time among many responsibilities.
Time constraints on imposing sanctions. California requires that sanctions be imposed 21 days after the identification of noncompliance unless participation issues are adequately resolved in the interim. In Los Angeles County, sanction functions are automated and thus the time clock is enforced rigidly. As soon as a case manager notes in the management information system that a client is noncompliant, a sanction clock starts; if the case manager does not stop or reset the clock, the system automatically imposes a sanction 21 days later. The automated 21-day clock keeps staff and clients focused on completing all re-engagement efforts in a timely manner.

Re-engaging Noncompliant Clients after Imposition of a Sanction

Program administrators in most sites believe that, while necessary, sanctions are not beneficial to anyone. They hurt clients by limiting financial assistance to families and 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 participation in work-related activities. Initiatives to engage sanctioned clients can be beneficial to both clients and agencies. 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 during their sanction, when their sanction period ends, or immediately when they return to TANF.

Outreach and group information sessions. In Kern County, two staff members are charged solely with contacting all sanctioned clients in the county at least once every six months. They discuss barriers to employment and inform clients about resources available to address those barriers. They also attempt to identify clients who can be removed from sanction status, such as those who are working but failed to report their employment. In addition, staff inform clients about the steps necessary to cure their sanction, including attendance at a group orientation session for sanctioned clients. 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.
Barrier identification and resolution. Suffolk County contracts with a local social service agency to re-engage sanctioned clients in program activities. Agency staff meet with clients in a first sanction to explore the reasons for noncompliance, help ameliorate the conditions that led to the sanction, and encourage clients to re-engage in program activities. All meetings with the agency are a condition of eligibility; failure to participate results in TANF case closure. Program administrators and staff believe that the contractors—particularly those that are community-based organizations—will be more successful than TANF case managers in motivating sanctioned clients to comply because clients may perceive contractors as more committed advocates for their needs. And, Suffolk County administrators believe that TANF and employment service program staff are often overburdened and do not have time to delve into personal issues with clients, while contracted agencies are devoted solely to this task.
Immediate job placement. Suffolk County also contracts with a local social service agency to meet with clients in a second or subsequent sanction to identify how they live on a reduced grant and whether they are in fact immediately employable. After the visit, the agency refers clients immediately employable to a temporary employment agency for job placement. Use of a temporary agency to place sanctioned clients into jobs is mutually beneficial; the temporary agency increases its volume of business and the TANF agency and its clients gain access to employers.
Job search and job preparation services. Tarrant County contracts with a local social service provider to engage sanctioned clients in 40 hours of work-related activities per week for 4 consecutive weeks. Activities include job search, community service, transitional jobs, or others as needed. In addition, agency staff tap community partners to assist in providing sanctioned clients with specialized services such as mental health treatment.
Provision of work supports. Georgia tries to encourage sanctioned clients to find jobs or participate in program activities by providing them with work supports that are highly valued. 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, all TANF sanctions automatically discontinue childcare and transportation assistance. Recently, to encourage clients to work or participate in activities while in sanction status, the state restored access to these supports to clients who do so.

Lessons Learned From the Study Sites’ Experiences

The experiences of the study sites provide several lessons for state and federal policymakers and for program administrators. Broadly speaking, their experiences expand our knowledge of the range of approaches used by states and local TANF offices to engage more recipients in work and work-related activities. But this study also has another contribution to make: identifying what we have learned from the sites’ experience in implementing policy and programmatic changes that can help decision makers consider the limits and possibilities for using sanction policies and procedures to increase participation in work and work-related activities. The bullets below identify lessons from the study sites’ experiences.

Although nearly all TANF recipients are included in a state’s work participation rate calculation, most of the study sites continue to exempt clients with serious personal and family challenges from work requirements; none of the study sites narrowed its exemption policies in response to the DRA.
Case managers devote substantial time to gathering and verifying participation data, limiting the time they have to provide personal support to help recipients resolve participation barriers. To address this issue, some of the sites have hired dedicated workers either to gather and verify work participation data or to provide specialized support to recipients who need it.
Sanction conciliation processes are an important safeguard for clients; in particular, those that involve a variety of staff can assist case managers in making difficult decisions.
While there were exceptions, the sites with partial sanction policies focused more intensively than sites with full-family sanctions on reducing their sanction rates.
To meet high work participation rates, it is not enough for states with partial sanction policies to reduce their sanction rates; they must actively assist nonparticipants to comply with program requirements.
The highest work participation rates are in full-family sanction sites and reflect primarily fewer nonparticipating clients on the caseload rather than more clients engaging in program activities; while some families who leave the TANF rolls find employment, many do not.
Additional research on effective strategies for engaging large numbers of recipients in work and work-related activities is necessary; in the absence of such research, the sites relied on their professional judgment to decide how to use their limited resources to increase participation in program activities.

Next Steps

The study sites are good examples of how states and local TANF offices use sanction policies and procedures to achieve higher work participation rates. However, absent a rigorous experiment designed to test the impacts of these approaches, we cannot know whether any of them will, in fact, have a positive impact on increasing participation in program activities or what impact they will have, if any, on other key outcomes of interest such as employment and material hardship.

Given the keen interest in increasing participation in work activities and the limited information on effective strategies for doing so, the current policy and programmatic environment provides an opportunity to rigorously test the impact of sanction policies and procedures on program participation, employment, and material hardship. For instance, states and local welfare offices are looking for new approaches to increase work participation rates, and some large states (e.g., California and New York) are investing additional financial resources in county welfare offices for the purpose of experimenting with new sanction-related approaches. Large numbers of recipients are involved in these efforts, as demonstrated not only by those who have been touched by Los Angeles County’s home visiting outreach project, but also by the many recipients who remain in sanction status in Los Angeles County and other large counties/cities in California and New York.

Random assignment demonstration projects could test the effects of both major sanction policy changes and alternative sanction procedures. First, several states have recently moved from a partial to a full family sanction policy and more states may soon follow suit. This shift could provide a natural laboratory for rigorously evaluating proponents’ claims that full family sanctions encourage greater participation in work activities and opponents’ claims that such sanctions simply remove families from the caseload—especially those facing personal and family challenges—without increasing participation in work activities. In states planning to move from partial to full sanctions, the new policy could be phased in by randomly assigning applicants and current recipients to treatment and control groups. The treatment group would be subject to full family sanctions, while the control group would continue to be subject to the partial sanction. Second, some of the study sites made a special effort to reach out to and/or provide additional services for families at risk of sanction or already sanctioned. To test the effectiveness of these services, a demonstration project could be designed to leave the current sanction policy intact while varying the procedures and/or services that accompany the implementation of the policy. In this experiment, all recipients would be subject to the same sanction policy, but the treatment group would be offered additional services, either at the point at which a recipient is notified of the work requirements, when a sanction is being considered, or after it has been levied.

In the current environment, sanctions are perceived as a crucial tool for encouraging TANF recipients to participate in work activities. In light of increased pressures to meet high work participation rates, sanctions will continue to be of interest as states and counties seek innovative ideas that will help to boost their rates. Today’s environment is ideal for testing whether some of the strategies implemented by the study sites have the potential to significantly increase work participation and employment rates without significantly increasing material hardship.

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