Q & A: Caseload Reduction Credit Reports
Caseload Reduction Credit Reports
Q1: If States do not have the distribution of denials or closures and have no way to construct such numbers at this point (or have some numbers but have no faith in the numbers because they were developed at a point when coding had no consequences), are we going to accept caseload reduction reports that do not contain such numbers?
A1: If a State does not have certain data required by the caseload reduction report, it should explain as clearly as possible why it has not submitted those data and why it is unable to make a plausible estimate and include these explanations with the report. We will consider such submissions on a case-by-case basis.
Q2: If a State has an extraordinary number of eligibility changes (e.g., 150 in Ohio), may it bundle those changes for the purpose of estimating their impacts?
A2: A State should list the impacts of each change separately, as required by the caseload reduction report, where it has the data to do so. If a State does not have separate denial codes for each eligibility criterion and cannot develop reasonable estimates of the impact of each eligibility change, the State may submit an estimate of the combined impact of all eligibility changes reflected in the single denial codes. The State should include an explanation of any such combined estimates as part of the report.
Q3: What kinds of administrative changes must be captured in the caseload reduction reports?
A3: States must report all administrative requirements that affect eligibility for benefits, along with estimates of the impact of each. Examples of administrative changes that would be subject to reporting would be waiting periods and additional documentation required as a condition of receiving benefits.If a change were purely administrative in nature, presumably it would have no impact on caseload.
Q5: The regulations (§261.42(b)) require a State to include separate State program (SSP) cases in the prior-year caseload data for the caseload reduction credit calculation. Since the regulations permit adjustments to the FY 1995 base caseload, could a State simply exclude SSP cases from the prior-year figure and adjust the FY 1995 caseload figure to remove any similar cases?
A5: No, the regulation at §261.43(a) is clear that the caseload reduction credit is based on decreases in caseloads receiving assistance not only under a State's TANF program, but also under separate State programs: (1) whose expenditures are used by the State as MOE; and (2) that address basic needs. The only exception is that, with proper documentation, States may exclude SSP cases that overlap with, or duplicate, cases in the TANF caseload and cases made ineligible for Federal benefits by PRWORA and receiving State-funded cash, nutrition assistance, or other benefits.
Q6: In its separate State program, a State has participation requirements, but not expressed as hourly requirements. How does it deal with the portions of the form (i.e., data elements 42-56 of the SSP MOE Data Report) that seek information concerning hours of participation in specified activities? If it fails to specify this information, would we determine that it failed to submit a complete report? Would such a determination have an adverse effect on its eligibility for a caseload reduction credit?
A6: See Q1 in TANF DATA REPORTING--SSP MOE Data Report.