oversight

Welfare Reform: States' Early Experiences With Benefit Termination

Published by the Government Accountability Office on 1997-05-15.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                 United States General Accounting Office

GAO              Report to the Ranking Minority Member,
                 Committee on Finance, U.S. Senate



May 1997
                 WELFARE REFORM
                 States’ Early
                 Experiences With
                 Benefit Termination




GAO/HEHS-97-74
      United States
GAO   General Accounting Office
      Washington, D.C. 20548

      Health, Education, and
      Human Services Division

      B-276396

      May 15, 1997

      The Honorable Daniel P. Moynihan
      Ranking Minority Member
      Committee on Finance
      United States Senate

      Dear Senator Moynihan:

      This report, prepared at your request, examines states’ early experiences with benefit
      terminations under welfare reform. The report focuses on the extent to which states have used
      benefit termination provisions, what happens to families after termination, and states’
      experiences in implementing these provisions.

      We are sending copies of this report to the Chairman, Committee on Finance, U.S. Senate; the
      Chairmen and Ranking Minority Members, Committee on Ways and Means and its
      Subcommittee on Human Resources, House of Representatives; the Secretary of Health and
      Human Services; the Assistant Secretary for Children and Families; and other interested parties.
      We will also make copies available to others on request.

      If you or your staff have any questions concerning this report, please call me at (202) 512-7215
      or David P. Bixler, Assistant Director, at (202) 512-7201. Other GAO contacts and major
      contributors to this report are listed in appendix XIII.

      Sincerely yours,




      Mark V. Nadel
      Associate Director
      Income Security Issues
Executive Summary


             The Personal Responsibility and Work Opportunity Reconciliation Act
Purpose      (P.L. 104-193) was enacted in August 1996, instituting the most
             fundamental reform of welfare since the program’s inception. The new law
             ends the individual entitlement to federally supported cash assistance to
             needy families with children and provides for terminating benefits to
             families failing to comply with program rules or after a certain time period.
             With few exceptions, prior federal welfare law has not allowed states to
             terminate benefits to an entire household on the basis of sanctions for
             noncompliance or a time limit.1 Since 1987, however, most states had
             received waivers from statutory requirements to experiment with such
             provisions.

             The Ranking Minority Member of the Senate Committee on Finance asked
             GAO to review states’ early experiences with waiver provisions for benefit
             termination to provide information useful to other states as they
             implement the new law. Specifically, this report describes (1) those
             families whose benefits have been terminated under waivers and why,
             (2) federal or state benefits that are available and are being received after
             termination, and (3) states’ experiences in implementing these provisions.


             Since its inception in 1935, the Aid to Families With Dependent Children
Background   (AFDC) program provided benefits to economically disadvantaged families
             with children lacking support from one or both parents because of death,
             absence, or incapacity. AFDC was funded with federal and state dollars;
             states administered the program and HHS had federal oversight
             responsibility. States were required to provide aid to all people eligible
             under federal law whose income and assets were within state-prescribed
             limits. In fiscal year 1996, AFDC paid benefits of over $20 billion in
             combined state and federal funds to about 4.6 million families a month
             (average nationwide caseload).

             Before the recent reform, federal welfare law limited states’ ability to
             terminate benefits on the basis of sanctions or time limits. Since
             welfare-to-work programs were initiated in 1968, certain categories of
             recipients were required to work or participate in other specified
             activities; however, if recipients failed to comply as required, benefits



             1
              Although referred to here as “prior law,” in general, the law in effect before passage of the new
             welfare reform law remains in effect until July 1, 1997, or 6 months after the date the U.S. Department
             of Health and Human Services (HHS) receives a state plan regarding certain provisions. Effective dates
             could be accelerated at state option.



             Page 2                                             GAO/HEHS-97-74 Welfare Benefit Termination
Executive Summary




could not be terminated but merely reduced. With one minor exception, no
time limits on benefits were allowed.2

The new welfare reform law replaces AFDC with block grants to the states
under Temporary Assistance for Needy Families (TANF). To encourage
work and end welfare dependence, the law has provisions for terminating
benefits for families’ failure to comply with work and child support
enforcement requirements and for teen parents’ failure to comply with
school attendance and living arrangement requirements. In addition, the
new law imposes a 5-year lifetime time limit on receiving federal benefits.

Even before this new welfare reform law was passed, states had been
allowed to experiment with benefit termination under section 1115 of the
Social Security Act, which provides authority for HHS to waive the
statutory requirements for AFDC. Between January 1987 and passage of the
new federal welfare reform law in August 1996, 46 states had received
approval for waiver provisions experimenting with their AFDC and
welfare-to-work programs, including 33 states with benefit termination
provisions similar to the new federal law’s.3 With increased flexibility
under the new law, many states have incorporated their benefit
termination waiver provisions into the state plans required by the new law.

To obtain information for this request, GAO reviewed the law and discussed
benefit termination issues with federal officials and experts from private
research organizations. GAO surveyed states with waiver provisions for
benefit termination based on sanctions or time limits to (1) determine
whose benefits have been terminated and on what basis and (2) select
three states with large numbers of terminations for more detailed study. In
each of these three states—Iowa, Massachusetts, and Wisconsin—GAO
analyzed statewide automated and case file data to determine which
families were being terminated and why and federal or state benefits that
were available and were being received after termination (see app. I). To
explore states’ experiences in implementing benefit termination
provisions, GAO staff talked to state officials, caseworkers, and
representatives of welfare advocacy groups.




2
 Under the Unemployed Parent program, 12 states were allowed to impose time limits on benefits for
two-parent families.
3
 The term “state” includes the District of Columbia in this report.



Page 3                                               GAO/HEHS-97-74 Welfare Benefit Termination
                   Executive Summary




                   So far, states have seldom used benefit termination provisions. Moreover,
Results in Brief   of the 18,000 families whose benefits were terminated under waivers
                   through December 1996, more than 99 percent failed to comply with
                   program requirements. Most terminations took place in Iowa,
                   Massachusetts, and Wisconsin (referred to as “case study” states).
                   Through June 1996, prior recipients’ failure to comply with new
                   enrollment requirements accounted for over half the terminations
                   nationwide. By the end of December 1996, failure to comply with work
                   requirements increased by one-third and became the most significant
                   reason for termination. Recipients’ explanations for this noncompliance
                   included wanting to stay at home with their children and an unwillingness
                   to do community service or work for low wages.

                   Terminating a family’s AFDC benefit represented the loss of a significant
                   source of monthly income. Although more than 80 percent of the families
                   in the cases GAO studied in Iowa, Massachusetts, and Wisconsin were
                   subsequently found to have some source of support or had returned to
                   welfare, the percentages of such families receiving food stamps and
                   Medicaid declined significantly after termination. Before termination, the
                   percentage of cases receiving these benefits ranged from 84 to
                   100 percent; after termination, it ranged from 26 to 61 percent. Many
                   families did not take the steps necessary to continue to receive these
                   program benefits after losing AFDC, even though the waivers provided for
                   program eligibility to be unaffected unless other family circumstances
                   changed.

                   Officials in the three states studied generally believed their benefit
                   termination provisions had improved program effectiveness by
                   contributing to increases in work activity, job placements, and families
                   moving off welfare more quickly. These officials emphasized that only a
                   small percentage of cases had been terminated. Nevertheless, they
                   acknowledged that implementing these provisions had been challenging.
                   For example, states had to develop systems to accurately track hours
                   worked to monitor compliance and to correctly and adequately notify
                   recipients of pending termination actions. In addition, states had to
                   provide certain activities and services before they could terminate a
                   family’s benefits. These states’ experiences with benefit termination
                   provisions under waivers highlight the challenges all states may face in
                   implementing similar provisions of the new welfare reform law.




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                             Executive Summary




Principal Findings

Most Families’ Benefits      Through December 1996, 14 of the 33 states with benefit termination
Terminated on the Basis of   provisions had not terminated any families’ benefits. Of the 19 states that
Sanctions in a Few States    had terminated benefits, 7 had terminated benefits in fewer than 100 cases,
                             according to available data.4 In addition to relatively small, less urban
                             caseloads, many states had a gradual phase-in of the program, which
                             limited the number of families whose benefits were terminated. In
                             addition, the program’s structure—which either required a minimum
                             amount of time to elapse before termination or excluded large portions of
                             the caseload from coverage—limited the number of terminations. States’
                             view of the role of benefit termination in their programs also affected the
                             number of cases terminated. For example, some states continued to
                             assume primary responsibility for ensuring that recipients complied with
                             program requirements and viewed benefit termination as a failure of their
                             programs to work as intended. These states established rigorous processes
                             to keep the number of terminations low. In contrast, other states sought to
                             shift primary responsibility for compliance to recipients and viewed
                             benefit termination as a needed strengthening of their sanctions to enforce
                             recipients’ obligation to move toward self-sufficiency. Most terminations
                             took place in the latter states. The three states with the most
                             terminations—Iowa, Massachusetts, and Wisconsin—all shared this view
                             and accounted for about 13,000 of the approximately 18,000 (or about
                             72 percent) terminations nationwide through December 1996.

                             Between June and December 1996, the proportion of terminations
                             nationwide based on failure to comply with enrollment requirements
                             decreased from 57 to 44 percent; terminations based on failure to comply
                             with work requirements increased from 34 to 47 percent. The proportion
                             of terminations for failure to comply with other requirements—such as
                             child support enforcement, teen parent school attendance, and teen parent
                             living arrangements—remained constant at about 8 percent. Less than
                             1 percent lost benefits because of a time limit, although this percentage
                             will probably change as increasing numbers of families begin reaching
                             their time limits.

                             State surveys and discussions with caseworkers in selected sites provided
                             various explanations for families’ failure to comply. For example, state and
                             local officials suggested that some families may have had unreported

                             4
                              Neither North Carolina nor Ohio had data on the number of cases terminated; data from Oregon were
                             available only through Nov. 15, 1996 (see app. II).



                             Page 5                                           GAO/HEHS-97-74 Welfare Benefit Termination
                       Executive Summary




                       employment, extended family support, or other sources of income.
                       According to state surveys and case file notes, families did not comply for
                       such reasons as not feeling well; caring for a sick household member;
                       wanting to stay home with their children; wanting to follow their own
                       career plans, including higher education; and an unwillingness to do
                       community service or work for low wages.

                       In general, the demographic characteristics of families whose benefits had
                       been terminated in Iowa, Massachusetts, and Wisconsin were similar to
                       the characteristics of families in the states’ overall caseloads. The most
                       significant variations resulted from the structure of states’ programs. For
                       example, a disproportionately high number of parents under age 20 had
                       their benefits terminated in Massachusetts, which imposed school
                       attendance and living arrangement requirements on teen parents.


After Loss of AFDC,    Under most states’ waiver provisions, families whose benefits were
Families Had Various   terminated for noncompliance could have had their AFDC cases reopened if
Sources of Support     they subsequently complied with program requirements. From 18 to
                       47 percent of such families returned to welfare, according to available data
                       from seven states. In Massachusetts and Wisconsin, about one-third of
                       families whose benefits had been terminated after enrollment
                       subsequently had their cases reopened because of demonstrated
                       compliance or documented exemption or because their cases had been
                       closed due to administrative error, according to an analysis of state data.
                       In Iowa, families whose benefits are terminated must wait 6 months before
                       reapplying; however, once this period had elapsed, about one-third of
                       families studied also had returned to welfare.

                       AFDC provided a significant source of income for most families before
                       termination, including those studied in Iowa, Massachusetts, and
                       Wisconsin. After AFDC benefits had been terminated, between 43 and
                       48 percent of the cases studied in these three states included household
                       members who reported income from wages, pensions, or child support;
                       and most likely, additional households had support that did not have to be
                       reported. In addition, about 75 percent of terminated cases studied
                       included household members who were receiving benefits from one or
                       more other federal programs—such as food stamps, Supplemental
                       Security Income, housing assistance, or Medicaid.5


                       5
                        GAO used household as the unit of analysis, which may include household members not included in
                       the AFDC family unit used for determining AFDC eligibility and calculating AFDC benefit levels before
                       termination.



                       Page 6                                            GAO/HEHS-97-74 Welfare Benefit Termination
                           Executive Summary




                           Although in many cases the sources of support were a continuation of
                           income or benefits that were being received before termination, the
                           percentage of cases receiving food stamps and Medicaid declined
                           significantly. Reductions ranged from 23 to 70 percent among cases not
                           returning to welfare. According to waiver provisions of all three states,
                           termination was not to affect eligibility to receive these program benefits,6
                           but many families did not take the steps necessary to keep their benefits
                           after losing AFDC, even though they may have continued to be eligible.
                           Because reported income and receipt of benefits provide only a limited
                           indication of the well-being of families losing AFDC, states tried to locate
                           such families and determine their status.


Termination Provisions     In all three case study states, benefit termination provisions had
Were Effective but Posed   encouraged those with other means of support to move off welfare more
Challenges                 quickly and those who truly needed assistance to cooperate more fully
                           with program requirements, according to state officials. Declines in all
                           three states’ caseloads exceeded the national average. While crediting the
                           economy as a major factor, state officials believed at least some of the
                           decline was due to their waiver programs and that the threat of benefit
                           termination had significantly improved program participation. Officials
                           reported increases in job placements in all three states.

                           In implementing these provisions, however, states faced challenges in
                           establishing systems to track recipients’ work participation to accurately
                           determine when benefits should be terminated for noncompliance and in
                           adequately notifying recipients of these actions. This was particularly true
                           in Wisconsin, where monthly benefits and sanctions were based on the
                           number of hours worked in a previous month and the state tried to
                           implement its complex provisions statewide with no pilot program. In
                           Milwaukee County, 44 percent of benefit termination notices through
                           August 1996 were subsequently reversed because county officials
                           determined that program requirements had been met or the sanctions had
                           been based on inaccurate data.

                           Providing enough services to afford recipients a reasonable opportunity to
                           comply with requirements and avoid termination posed another challenge
                           for states. To meet increased demand for activities and services under
                           their new programs, all three states opened or expanded job centers to
                           help with job search activities, created new partnerships with employers

                           6
                            In Wisconsin, however, termination of AFDC benefits could result in a sanction reducing the food
                           stamp allotment to $10 per month.



                           Page 7                                            GAO/HEHS-97-74 Welfare Benefit Termination
                  Executive Summary




                  to provide placements, and increased funds for child care. Despite such
                  efforts, however, both welfare advocates and state officials raised
                  concerns that workers were not adequately trained in case management.
                  In addition, high caseloads and complex new program rules prevented
                  workers from paying enough attention to individual cases to ensure that
                  recipients, many with barriers to employability, were assigned appropriate
                  work requirements and provided sufficient supports. For example, state
                  reviewers in Iowa found that 50 percent of the cases referred for sanction
                  for noncompliance with work requirements had not received sufficient
                  case management and the cases had been sent back to the caseworkers for
                  more services.

                  Although state officials acknowledged these challenges, they maintained
                  that the guiding principle of their new programs—consistent with the new
                  federal reform law—is that it is ultimately the recipients’ responsibility to
                  either comply with program requirements, inform their caseworkers of any
                  barrier to employment or service need, provide good cause reason for
                  noncompliance, or have their benefits terminated.


                  GAO   is not making recommendations in this report.
Recommendations
                  GAO obtained comments on a draft of this report from the three case study
Agency Comments   states: Iowa, Massachusetts, and Wisconsin. The states generally agreed
                  with the report’s findings and made technical comments, which were
                  incorporated as appropriate. Comments were requested but were not
                  received from HHS.




                  Page 8                                GAO/HEHS-97-74 Welfare Benefit Termination
Page 9   GAO/HEHS-97-74 Welfare Benefit Termination
Contents



Executive Summary                                                                                   2


Chapter 1                                                                                          14
                       The Welfare System Before Recent Federal Reform                             15
Introduction           Benefit Termination Under Welfare Reform                                    16
                       States’ Waiver Provisions for Termination Generally Similar to              17
                         New Law
                       Objectives, Scope, and Methodology                                          19

Chapter 2                                                                                          20
                       Most States Had Few, If Any, Terminations                                   20
Most Families’         Most Terminations Were Based on Failure to Meet Enrollment                  26
Benefits Terminated     and Work Requirements
on the Basis of
Sanctions in a Few
States
Chapter 3                                                                                          33
                       Many Families Had Returned to Welfare                                       33
After Losing AFDC,     Families Lost Income, but Many Had Some Sources of Support                  35
Families Had Various   Other Indicators of Family Well-Being                                       45
Sources of Support
Chapter 4                                                                                          48
                       Provisions Resulted in Increased Compliance and Declining                   48
Termination              Caseloads
Provisions Were        Establishing Tracking and Notification Systems Challenged                   50
                         States
Effective but Posed    Providing Sufficient Case Management Services Also Challenged               53
Challenges               States

Chapter 5                                                                                          56
                       Conclusions                                                                 56
Conclusions and        Comments From the States                                                    57
Comments From the
States




                       Page 10                              GAO/HEHS-97-74 Welfare Benefit Termination
                       Contents




Appendixes             Appendix I: Scope and Methodology                                          58
                       Appendix II: Overview of States Terminating Benefits Under                 60
                         Waivers as of December 31, 1996
                       Appendix III: Full-Family Sanction Provisions in State Welfare             63
                         Waivers Approved Between January 1987 and August 1996
                       Appendix IV: Time-Limit Provisions in State Welfare Waivers                76
                         Approved Between January 1987 and August 1996
                       Appendix V: Reasons for Excluding Cases From Coverage in                   88
                         Selected States
                       Appendix VI: Overview of Waiver Programs in Iowa,                          91
                         Massachusetts, and Wisconsin
                       Appendix VII: Bases for Terminations Nationwide, by State                  95
                       Appendix VIII: Demographic Profile of Total Caseload Compared              98
                         With Terminated Cases Studied in Iowa, Massachusetts, and
                         Wisconsin
                       Appendix IX: Massachusetts Data on High School, Work                      100
                         Experience, and Primary Language
                       Appendix X: Reported Income and Benefits Received by                      102
                         Terminated Cases Studied in Iowa, Massachusetts, and Wisconsin
                       Appendix XI: Average Benefits, Child Support Payments, and                105
                         Unemployment Rates in States Terminating Benefits Under
                         Waivers
                       Appendix XII: AFDC Caseload Participation in Selected Programs            107
                         in States Terminating Benefits Under Waivers
                       Appendix XIII: GAO Contacts and Staff Acknowledgments                     108

Bibliography                                                                                     109


Related GAO Products                                                                             112


Tables                 Table 3.1: Sources of Income Before Termination for Households             36
                         Studied
                       Table 3.2: Reported Wages Before and After Termination                     39
                       Table VII.1: Terminations as of June 30, 1996                              95
                       Table VII.2: Terminations as of December 31, 1996                          96

Figures                Figure 1.1: Percentage of Families Nationwide Receiving Benefits           14
                         From Aid to Families With Dependent Children, 1970-95
                       Figure 2.1: States Terminating Benefits to Families as of                  21
                         December 31, 1996




                       Page 11                             GAO/HEHS-97-74 Welfare Benefit Termination
Contents




Figure 2.2: Bases for Terminations Nationwide                             27
Figure 3.1: Percentage of Cases Reopened After Termination for            34
  Noncompliance
Figure 3.2: Percentage of Households Reporting Income After               38
  Benefit Termination
Figure 3.3: Percentage of Households Receiving Benefits After             41
  Termination, by Program
Figure 3.4: Percentage of Households Receiving Food Stamps and            43
  Medicaid Before and After Termination
Figure 4.1: AFDC Caseload Declines in Case Study States                   49
  Exceeded National Average, 1993-96




Abbreviations

AFDC       Aid to Families With Dependent Children
CWEP       Community Work Experience Program
HHS        Department of Health and Human Services
HUD        Department of Housing and Urban Development
JOBS       Job Opportunities and Basic Skills Training
LIHEAP     Low-Income Home Energy Assistance Program
SSI        Supplemental Security Income
TANF       Temporary Assistance for Needy Families
TEEM       Training, Education, Employment, and Management


Page 12                            GAO/HEHS-97-74 Welfare Benefit Termination
Page 13   GAO/HEHS-97-74 Welfare Benefit Termination
Chapter 1

Introduction


                                     With the stated intent of making our nation’s welfare system “more
                                     consistent with fundamental American values—by rewarding work and
                                     self-reliance, encouraging personal responsibility, and restoring a sense of
                                     hope in the future,” the Congress enacted the Personal Responsibility and
                                     Work Opportunity Reconciliation Act (P.L. 104-193) in August 1996. The
                                     law was passed amid a growing number of families receiving benefits and
                                     increasing dissatisfaction with the system (see fig. 1.1). Although more
                                     recently, caseloads had begun to decline, many people continued to
                                     criticize a system that they believed discourages work and encourages
                                     dependency and that, according to the Congress, failed to promote
                                     personal responsibility.


Figure 1.1: Percentage of Families
Nationwide Receiving Benefits From   20   Percentage
Aid to Families With Dependent
Children (AFDC), 1970-95

                                     15




                                     10




                                      5




                                      0

                                      1970                1975                1980               1985                1990                 1995




                                     Sources: Social Security Bulletin, “Annual Statistical Supplement - 1995,” table 9.G1; Statistical
                                     Abstract of the United States - 1996; and the U.S. Census Bureau, Current Population Reports,
                                     Series P20-488, “Household and Family Characteristics: March 1995” and earlier reports.




                                     The new federal welfare reform law ended an individual’s entitlement to
                                     welfare benefits and replaced it with a block grant to the states, changing
                                     the fundamental structure of the more than 60-year-old welfare system.
                                     Among its provisions, the new law allows states to terminate benefits to a




                                     Page 14                                             GAO/HEHS-97-74 Welfare Benefit Termination
                        Chapter 1
                        Introduction




                        family on the basis of penalties (called sanctions) for noncompliance and
                        requires states to terminate federal benefits to a family who has reached a
                        5-year time limit. With few exceptions, prior federal welfare law did not
                        allow states to terminate a family’s benefits on the basis of sanctions or
                        time limits; however, it did allow for states to obtain waivers to
                        experiment with termination provisions.7


                        Since its inception in 1935, AFDC provided benefits to economically needy
The Welfare System      families with children lacking support from one or both parents because of
Before Recent Federal   death, absence, or incapacity. AFDC was funded with federal and state
Reform                  dollars. States administered the program, and HHS had federal oversight
                        responsibility. States were required to provide aid to all people eligible
                        under federal law whose income and assets were within state-prescribed
                        limits. In fiscal year 1996, over $20 billion in combined state and federal
                        funds were paid in benefits to a nationwide caseload that averaged about
                        4.6 million families a month. Families with children could receive benefits
                        if they conformed with income eligibility criteria and lacked parental
                        support, until 1968 when work incentives and welfare-to-work programs
                        were established.8 These programs introduced the ideas of mutual
                        obligation and transitional benefits, reflecting an expectation that the
                        recipient should move toward self-sufficiency in exchange for welfare
                        benefits and that receiving benefits should be temporary—not a way of
                        life. With passage of the Family Support Act of 1988, the Congress
                        combined elements of these earlier programs into a single, more
                        comprehensive program: Job Opportunities and Basic Skills Training
                        (JOBS). The act also expanded the Unemployed Parent program,
                        introducing time-limited benefits for two-parent families in some states.9

                        The purpose of the JOBS program was to ensure that AFDC families obtained
                        the education, training, and employment that would help them avoid


                        7
                         Although referred to here as “prior law,” in general, the law in effect before the new welfare reform
                        law was passed remains in effect until July 1, 1997, or for 6 months after the date HHS receives a state
                        plan regarding certain provisions. Effective dates could be accelerated at state option.
                        8
                         See Welfare to Work: States Begin JOBS, but Fiscal and Other Problems May Impede Their Progress
                        (GAO/HRD-91-106, Sept. 27, 1991), pp. 10-11.
                        9
                         Beginning in 1961, states were given the option of providing AFDC to two-parent families who were
                        needy due to the unemployment of the principal wage earner. The Family Support Act of 1988 required
                        all states to implement such programs, and those states that did not already have a program in place
                        were allowed to impose a time limit on the receipt of benefits. The 29 states and territories with
                        programs already in place were required to continue operating their programs with no time limit.
                        However, remaining states implementing new programs were allowed to deny benefits to two-parent
                        families once they had received benefits for at least 6 of the preceding 12 months. As of February 1996,
                        12 of these states had chosen to impose time limits on benefits for two-parent families.



                        Page 15                                             GAO/HEHS-97-74 Welfare Benefit Termination
                       Chapter 1
                       Introduction




                       long-term welfare dependence. JOBS required states to develop
                       employability plans based on assessments of each recipient’s
                       employability skills and supportive services needs. JOBS also required
                       states to offer a broad range of education, training, and work-related
                       activities. States were further required to guarantee child care if necessary
                       for the recipient to work or participate in education and training or other
                       activities specified under JOBS and to pay or reimburse recipients for
                       transportation and other work-related expenses. Recipients, on the other
                       hand, who were able-bodied individuals aged 16 or older were required to
                       participate in the activities specified in their employability plans. If a
                       recipient failed to comply with program requirements without good cause,
                       benefits could be reduced by the amount attributable to the noncomplying
                       recipient, but the entire family’s benefits could not be terminated.

                       More than half of AFDC recipients were exempt from participating in JOBS,
                       however, most often because they were caring for a young child,10 and a
                       large portion of the nonexempt recipients were not required to participate
                       due to limited state funding. Historically, less than a third of those required
                       to participate actually participated in JOBS because, according to program
                       administrators, the states could not provide all the needed services and
                       assistance.11


                       The new federal welfare reform law ended the AFDC program, including
Benefit Termination    JOBS, and replaced it with block grants to the states under a new title,
Under Welfare Reform   Temporary Assistance for Needy Families (TANF). TANF allows states more
                       flexibility to operate programs designed to end dependence on
                       government benefits by promoting job preparation, work, and marriage.
                       To accomplish these goals, states must submit plans reflecting the
                       obligations of both the state and the recipient. These plans must outline
                       how the state intends to conduct a program that provides recipients with
                       job preparation, work, and support services enabling them to leave
                       welfare and become self-sufficient as well as how the state intends to
                       require recipients to engage in work.

                       10
                         Other recipients exempted from participation in JOBS included those who were ill, incapacitated, or
                       of advanced age; needed in the home because of the illness or incapacity of another family member;
                       the parent or other relative of a child under age 3 (or younger than 3 but not younger than age 1 at
                       states’ option) who was personally providing the care for the child; employed 30 or more hours a
                       week; a child under age 16 or attending an elementary, secondary, or vocational school full time; a
                       woman who was in at least the second trimester of pregnancy; or residing in an area where the
                       program was not available.
                       11
                        Federal matching funds for JOBS were available as a capped entitlement, set at $1.0 billion in fiscal
                       year 1996. See also Welfare to Work: Current AFDC Program Not Sufficiently Focused on Employment
                       (GAO/HEHS-95-28, Dec. 19, 1994), pp. 5-8.



                       Page 16                                            GAO/HEHS-97-74 Welfare Benefit Termination
                        Chapter 1
                        Introduction




                        To encourage recipients to fulfill their obligations, the law includes
                        provisions allowing states to terminate benefits to a family for failure to
                        comply with work and other requirements. After no more than 24 months
                        of receiving benefits (whether or not consecutive), parents and caretakers
                        must engage in work. The recipient must work a minimum average of 20
                        hours a week (increasing to 30 hours a week by the year 2000) in most
                        circumstances to meet this requirement. Unmarried teen parents under
                        age 18 who do not attend high school (or its equivalent), or who do not
                        live with their parents, legal guardian, or other adult relative, may not
                        receive assistance under TANF unless extenuating circumstances exist, as
                        specified in the law.12 In addition, states are allowed to deny TANF benefits
                        to a family for not cooperating with child support enforcement actions,
                        including establishing paternity, or establishing, modifying, or enforcing a
                        support order. The new law generally allows states to use their discretion
                        in establishing criteria for exempting families from these requirements;
                        however, the extent to which states exercise this discretion could affect
                        their ability to meet prescribed participation rates and avoid financial
                        penalties.

                        To ensure that assistance is temporary for most recipients, the law also
                        includes provisions for a 5-year lifetime time limit on benefit receipt. After
                        no more than 60 months of benefit receipt (whether or not consecutive) by
                        an adult in the family, the family may no longer receive any federal
                        assistance under the program. By allowing up to 20 percent of the
                        caseload to be exempt from the time limit, the law intends to protect those
                        who experience genuine and intractable hardship.


                        Although prior law limited states’ ability to terminate benefits to entire
States’ Waiver          households on the basis of sanctions or time limits, it did provide a way
Provisions for          for states to experiment with such provisions. Section 1115 of the Social
Termination Generally   Security Act authorizes the Secretary of HHS to grant states waivers of
                        statutory requirements for the AFDC program, including JOBS. Between
Similar to New Law

                        12
                          The new welfare reform law specifies that requiring teen parents to live with their parents, legal
                        guardians, or other adult relatives would not be appropriate when (1) the teen parent has no living
                        parents, legal guardian, or other appropriate adult relative with whom to live or the whereabouts of
                        such individuals are unknown; (2) such individuals will not allow the teen parent to live with them;
                        (3) the state determines that the teen parent is, has been, or may be subject to serious physical or
                        emotional harm, sexual abuse, or exploitation in such individuals’ home; or (4) the state determines it
                        is in the best interest of the teen to waive the requirement. In cases in which living with parents, legal
                        guardians, or other adult relatives is not an option for the teen parent, the state must help the teen
                        locate an alternative adult-supervised living arrangement, unless it determines that the teen parent’s
                        current living arrangement is appropriate.



                        Page 17                                              GAO/HEHS-97-74 Welfare Benefit Termination
Chapter 1
Introduction




January 1987 and the passage of welfare reform in August 1996, 46 states13
had received approval to implement waiver provisions experimenting with
changes to their AFDC and JOBS programs, including 33 states that had
provisions to terminate benefits to entire families either for failure to
comply with program requirements or for reaching a time limit.14 Such
provisions reflected states’ belief that they needed stronger measures to
deal effectively with recipients who fail to meet program requirements.15
With their increased flexibility under the new federal reform law, many
states have incorporated their benefit termination waiver provisions into
their new state plans.16

Thirty-one states had received approval to implement waiver provisions
terminating benefits to entire families (referred to as full-family sanctions)
for failure to comply with one or more requirements similar to those in the
new welfare reform law. In most cases, such families could have had their
benefits restored upon compliance with the requirements; but in some
cases families must wait several months before being eligible to reapply.
(For a more detailed description of states’ full-family sanction provisions,
see app. III.)

Fourteen states had received approval to implement waiver provisions
terminating benefits to a family after a specified of time period, somewhat
similar to the time-limit provision in the new welfare reform law. However,
states’ waiver provisions to terminate benefits due to a time limit differed
from the new law in significant ways, such as allowing an unlimited
percentage of cases to be exempt and providing for extensions or the
opportunity to reapply after a certain time period had elapsed.17 (For a
more detailed description of states’ time-limit provisions, see app. IV.)




13
  The term “state” includes the District of Columbia in this report.
14
 Under prior law, states could also choose to terminate a family’s benefits on the basis of failure to
comply with teen living arrangements without a waiver.
15
  See Welfare Waivers Implementation: States Work to Change Welfare Culture, Community
Involvement, and Service Delivery (GAO/HEHS-96-105, July 2, 1996), pp. 30-32.
16
 In addition, the new law provides states the option of continuing under certain conditions to
implement any waiver provisions in effect or requested before enactment of the new law if approved
by July 1, 1997.
17
 In addition, several of these and other states had time-limit provisions that called for imposing some
consequence other than benefit termination upon reaching a time limit, including work requirements,
benefit reduction, or use of vouchers. (See app. IV.)



Page 18                                              GAO/HEHS-97-74 Welfare Benefit Termination
                     Chapter 1
                     Introduction




                     The Ranking Minority Member of the Senate Committee on Finance asked
Objectives, Scope,   us to review states’ early experiences with benefit termination provisions
and Methodology      under waivers to provide information useful to other states as they
                     implement the new law. Specifically, this report describes (1) those
                     families whose benefits have been terminated under waivers and why,
                     (2) federal or state benefits that are available and are being received after
                     termination, and (3) states’ experiences in implementing these provisions.

                     To obtain information for this request, we reviewed the law and discussed
                     benefit termination issues with federal officials and experts from private
                     research organizations. To determine which states had terminated benefits
                     under waivers and the bases for those terminations, we examined waivers
                     approved from January 1987 through passage of the new law in
                     August 1996 and surveyed all states with approved benefit termination
                     provisions. To determine whose benefits had been terminated, identify
                     what federal or state benefits were available and were being provided after
                     termination, and describe states’ experiences in implementing these
                     provisions, we selected Iowa, Massachusetts, and Wisconsin (three states
                     with large numbers of terminations) for more detailed study. In each of
                     these states, we chose a group of families whose AFDC benefits had been
                     terminated and relied upon state and federal automated records to
                     determine if these families were receiving benefits from various programs,
                     including food stamps, Supplemental Security Income, housing assistance,
                     and Medicaid. We also identified other sources of income to the extent
                     such information was reported, including partial data on wages, pensions,
                     and child support. (See app. I for a more detailed discussion of case
                     selection and analysis of automated data.) To identify implementation
                     issues, we discussed the provisions with state officials and representatives
                     of welfare advocacy groups and caseworkers in selected sites.

                     We conducted our work between April 1996 and April 1997 in accordance
                     with generally accepted government auditing standards.




                     Page 19                               GAO/HEHS-97-74 Welfare Benefit Termination
Chapter 2

Most Families’ Benefits Terminated on the
Basis of Sanctions in a Few States

                       Of the 33 states with waiver provisions to terminate AFDC benefits on the
                       basis of full-family sanctions or a time limit, most had terminated the
                       benefits of few, if any, families through December 1996. Iowa,
                       Massachusetts, and Wisconsin had the highest number of terminations. Of
                       the 18,000 families whose benefits were terminated nationwide, over
                       99 percent had failed to comply with program requirements. Most failed to
                       comply with new JOBS enrollment or work requirements. The demographic
                       characteristics of families losing their AFDC benefits in these three states
                       were generally comparable to the characteristics of families in the states’
                       overall caseloads. The most significant variations were due to the state
                       programs’ structure.


                       Through December 1996, 14 of the 33 states with benefit termination
Most States Had Few,   provisions had not terminated the benefits of any families on the basis of
If Any, Terminations   such provisions. (See fig. 2.1.) Of the 19 states that had terminated
                       benefits, 7 had terminated fewer than 100 cases, according to available
                       data.18 Less than half of the 19 states had terminated benefits for families
                       living in large urban areas with populations over 500,000—either because
                       the state had no large urban areas or because the waiver provisions had
                       not been implemented statewide. (For a more detailed description of
                       states terminating benefits, see app. II.)




                       18
                        Neither North Carolina nor Ohio had data on the number of cases terminated; data from Oregon were
                       available only through Nov. 15, 1996 (see app. II).



                       Page 20                                          GAO/HEHS-97-74 Welfare Benefit Termination
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                                           Most Families’ Benefits Terminated on the
                                           Basis of Sanctions in a Few States




Figure 2.1: States Terminating Benefits to Families as of December 31, 1996




                                           Note: NA = not available.

                                           a
                                            According to state officials surveyed, North Carolina and Ohio had terminated benefits for some
                                           families because of noncompliance with program requirements under waivers as of Dec. 31,
                                           1996, but their data systems could not provide the number of families losing benefits.
                                           b
                                           Data from Oregon were available only through Nov. 15, 1996.




                                           Page 21                                           GAO/HEHS-97-74 Welfare Benefit Termination
                              Chapter 2
                              Most Families’ Benefits Terminated on the
                              Basis of Sanctions in a Few States




Program Structure Led to      In addition to some states’ having relatively small, less urban caseloads,
Few Terminations in Most      many had a limited number of terminations because of the program’s
States                        being gradually phased in, requiring a minimum amount of time to elapse
                              before termination, or excluding large portions of the caseload from
                              coverage. States’ views of the role of benefit termination in their programs
                              also affected the number of families losing benefits.

Not Enough Time Had Elapsed   Most of the 33 states with benefit termination provisions based on either
                              full-family sanctions or a time limit began implementing their programs in
                              1995 and 1996. Because of this, not enough time had elapsed through
                              December 1996 for families to have been in the programs long enough to
                              have had full-family sanctions imposed or to have reached a time limit. In
                              some states, no terminations were yet possible due to the structure of the
                              programs. In addition, for recipients cycling on and off welfare, the length
                              of time required to reach a time limit is extended beyond when it would
                              have been met if benefits had been received continuously.19

                              Among the 26 states with termination provisions based on noncompliance
                              with work requirements, most terminated benefits only after a specified
                              time period had been reached (referred to as a “work trigger”)20 or
                              graduated sanctions imposed. For example, Delaware and North Dakota
                              had work trigger time limits of 24 months; Vermont had a 30-month time
                              limit for most families.21 Other states, such as Illinois, had graduated
                              sanction processes lasting 6 months to a year before terminating benefits.
                              These states had terminated the benefits of relatively few, if any, families.

                              Among the 14 states with termination provisions based on a time limit,
                              most allowed families to receive benefits for at least 24 months or longer
                              before termination. Only one state, Florida, had implemented its program




                              19
                               Researchers using monthly data have found that no more than 30 percent of recipients receive
                              welfare in 24 consecutive months. Many recipients leave welfare for a month or two and then cycle
                              back on. (See LaDonna Pavetti, The Number and Characteristics of Families Who Will Potentially Be
                              Affected by Policies to Time-Limit AFDC Benefits, The Urban Institute (Washington, D.C.: 1996)).
                              20
                                Of the 26 states terminating benefits on the basis of work requirements, 12 provided for the
                              requirements to be imposed after work triggers ranging from 60 days to 60 months of receiving
                              benefits. The other 14 states either imposed the work requirement immediately on families entering
                              the program or set the length of time before imposing the requirement on a case-by-case basis.
                              21
                                Vermont had a work trigger time limit of 15 months for two-parent families.



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                              Most Families’ Benefits Terminated on the
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                              long enough to have terminated the benefits of any families because of a
                              time limit through December 1996.22

Large Portions of Caseloads   Some states limited implementation of their waiver programs to selected
Excluded                      sites; those implementing their programs statewide generally phased in
                              implementation over periods lasting up to a year. Thus, these states
                              initially excluded large segments of their caseloads.

                              In addition, some states initially excluded large portions of their caseloads
                              from benefit termination primarily on the basis of exemptions.23 Variation
                              in states’ exemption provisions, especially regarding the age of the
                              youngest child, significantly affected the portion of the caseload exempted
                              from work requirements. For example, Iowa set its age-of-youngest-
                              child exemption at 6 months and excluded 24 percent of its caseload from
                              having to comply with work requirements; Massachusetts set its
                              age-of-youngest-child exemption at 6 years and excluded 69 percent of its
                              caseload from having to comply with work requirements. (See app. V.)

                              Under the new welfare reform law, states still have discretion in
                              establishing criteria for exempting families from work and other
                              requirements, with few exceptions.24 The extent to which they exercise
                              this discretion, however, will affect their ability to meet the prescribed
                              participation rates and avoid financial penalties.25




                              22
                                In addition, Florida initially implemented its program in only 2 of its 67 counties (Alachua and
                              Escambia), covering no large urban areas. Because of the program’s structure, terminations through
                              December 1996 based on Florida’s time limit were restricted to these two initial counties, which
                              covered only about 8,000 families (or about 4.3 percent) of a statewide caseload of about 187,000
                              families.
                              23
                               Families were also excluded from the waiver provisions because they were assigned to a control
                              group for evaluation purposes or for other reasons (see app. V).
                              24
                                For example, the law stipulates that a state may not reduce or terminate assistance on the basis of a
                              refusal to work if the household includes a single parent and a child under 6 years old and child care is
                              unavailable due to (1) unavailability of appropriate child care within a reasonable distance from the
                              individual’s home or work site, (2) unavailability or unsuitability of informal child care by a relative or
                              under other arrangements, and (3) unavailability of appropriate and affordable formal child care
                              arrangements. Although exempted, such families must still be counted in determining the state’s
                              participation rate. The law also allows states not to require a single parent caring for a child under 1
                              year old to engage in work and to disregard such families in determining the state’s participation rate.
                              25
                                The new law requires prescribed percentages of a state’s caseload to participate in specified work
                              and work-related activities for the state to avoid financial penalties. In fiscal year 1997, 25 percent of a
                              state’s caseload must participate; by fiscal year 2002, 50 percent must participate. Separate, higher
                              rates are prescribed for two-parent families. For further discussion of these issues, see Welfare
                              Reform: Three States’ Approaches Show Promise of Increasing Participation Rates (GAO/HEHS-97-80,
                              forthcoming report).



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                              Most Families’ Benefits Terminated on the
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Role of Benefit Termination   Prior law placed primary responsibility for acting to move recipients
                              toward self-sufficiency on the states by requiring states to provide
                              specified activities and support services. Under waivers, some states
                              sought to shift primary responsibility for such action to the recipients;
                              other states continued to assume primary responsibility for ensuring that
                              recipients complied with program requirements. The latter states often
                              viewed benefit termination as a failure of their program to work as
                              intended. Their waiver programs required caseworkers to provide
                              intensive case management services, including home visits if possible, and
                              established a rigorous conciliation and review process before termination.
                              Such states terminated benefits only after they had determined that
                              recipients were making an informed choice, were mentally and physically
                              able to participate, and barriers to participation had been identified and
                              addressed. Florida established a review panel consisting of seven
                              community members to advocate for recipients by reviewing cases of
                              those not meeting program requirements and finding ways to help,
                              including requiring provision of additional or new services when
                              appropriate. After 2 years of implementation, 74 families had reached their
                              time limits and had their benefits terminated; of these, 31 had a family
                              member who had found a job or who was working before termination.26 In
                              Michigan, rigorous conciliation efforts resulted in continued benefits for
                              727 (81 percent) of the first 895 cases nearing benefit termination.

                              In addition to intensive case management services and rigorous review
                              processes, some states also had flexible definitions of the activities
                              required to meet participation requirements, lessening instances of
                              noncompliance. For example, Utah exempted no one over age 15 from
                              program participation but defined a wide range of activities as meeting the
                              requirements. Utah allowed such activities as attending postsecondary
                              education programs, drug and alcohol counseling, parenting classes, and
                              even weight-reduction programs for 2 or 3 hours a week, to qualify as
                              meeting the work requirement. These activities, however, would not meet
                              the more restrictive definition of participation under the new federal




                              26
                                These families had continued to be eligible for benefits until reaching their time limit due to the
                              increased amount of earned income disregarded under the waiver program. In addition, under
                              Florida’s waiver, officials had to determine whether terminating a family’s benefits could result in a
                              child being placed in an emergency shelter or foster care; if so, the family’s benefits would be reduced
                              but not terminated. Through December 1996, three Florida families who had reached their time limits
                              continued to receive reduced benefits because the state determined the children to be at risk.



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                           Most Families’ Benefits Terminated on the
                           Basis of Sanctions in a Few States




                           welfare reform law.27 After more than a year of using these flexible
                           definitions of participation, Utah had terminated 180 families’ benefits.
                           Nebraska also used a flexible definition of participation, allowing the
                           hourly participation requirement to be individually based and requiring
                           families with a child under 6 months to participate part time in such
                           activities as family nurturing and pre-employment skills. After more than a
                           year of implementation, Nebraska had terminated 59 families’ benefits for
                           failure to participate.


Three States Account for   Most terminations based on implementation of full-family sanction or time
Most Terminations          limit waiver provisions nationwide took place in three states: Iowa,
                           Massachusetts, and Wisconsin.28 Through June 1996, these three states
                           accounted for about 7,700 of the nearly 9,800 terminations or about
                           78 percent. Through December 1996, these states still accounted for about
                           13,000 of the approximately 18,000 terminations or about 72 percent,
                           according to available data.

                           All three states placed requirements on recipients immediately upon entry
                           into their new waiver programs. In Iowa, a family’s failure to comply
                           meant placement in a Limited Benefit Plan, leading to benefit termination.
                           Families in the Limited Benefit Plan were to receive 3 months of full
                           benefits (this period of receiving full benefits was eliminated in
                           February 1996), followed by 3 months of reduced benefits and then 6
                           months of no benefits.29 Families whose benefits had been terminated
                           could reapply only after the 6-month period of no benefits had elapsed.
                           Massachusetts and Wisconsin terminated benefits more quickly for


                           27
                             The new law requires the recipient to work a minimum average of 20 hours a week (increasing to 30
                           hours a week by the year 2000) and stipulates the following limited list of activities as meeting its
                           definition of work activities: unsubsidized employment, subsidized private-sector employment,
                           subsidized public-sector employment, work experience (including work associated with the
                           refurbishing of publicly assisted housing) if sufficient private-sector employment is not available,
                           on-the-job training, job search and job readiness assistance, community service programs, vocational
                           educational training (not to exceed 12 months for any individual), job skills training directly related to
                           employment, education directly related to employment in the case of a recipient without a high school
                           diploma or certificate of high school equivalency, satisfactory attendance at secondary school or in a
                           course of study leading to a certificate of general equivalence in the case of a recipient who has not
                           completed secondary school or received such a certificate, and the provision of child care services to
                           an individual who is participating in a community service program.
                           28
                            On the basis of data provided in April 1997 as this report went to press, Virginia also had a large
                           number of terminations, nearly as many as Massachusetts (see app. II).
                           29
                             After February 1996, families in Iowa’s Limited Benefit Plan immediately entered the 3-month period
                           of reduced benefits, followed by 6 months of no benefits. In addition, if families entered a second or
                           subsequent Limited Benefit Plan, they would immediately enter the 6 months of ineligibility without
                           the initial 3 months of reduced benefits.



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                        Most Families’ Benefits Terminated on the
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                        noncompliance, but families could reapply at any time and have benefits
                        restored once they had demonstrated compliance.

                        Both Massachusetts and Wisconsin had large urban areas; therefore,
                        although Massachusetts excluded a large portion of its caseload from
                        coverage, it still had a large number of terminations. Finally, all three of
                        these states sought to shift primary responsibility for moving toward
                        self-sufficiency from the state to the recipient and viewed benefit
                        termination as a needed strengthening of their sanctions to enforce
                        recipients’ obligation to move toward self-sufficiency. Although the states
                        provided support services to help recipients become self-sufficient,
                        recipients were responsible for using these services if they wished to
                        continue to receive AFDC benefits. With the increased flexibility provided
                        under the new federal welfare reform law, all three states planned to
                        continue implementing the basic provisions of their programs. (For a more
                        detailed description of the benefit termination provisions implemented as
                        part of the reform programs in Iowa, Massachusetts, and Wisconsin, see
                        app. VI.)


                        Nearly all families having their AFDC benefits terminated through
Most Terminations       December 1996 failed to comply with various program requirements. Over
Were Based on Failure   90 percent of terminations were based on failure to comply with either
to Meet Enrollment      JOBS enrollment or work requirements, although the proportions shifted
                        between June and December (see fig. 2.2). In our three case study states,
and Work                the demographic characteristics of the families losing AFDC benefits were
Requirements            generally comparable to those of families in the states’ overall caseloads,
                        with the most significant variations attributable to the state programs’
                        structure.




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                                               Most Families’ Benefits Terminated on the
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Figure 2.2: Bases for Terminations Nationwide

                        a                                                                      a
 Through June 1996                                              Through December 1996

                            57.1%
                                                                                          44.2%




                                              2.3%                                                     2.2%
                                              2.2%                                                     1.3%

                                             3.8%                                                     4.8%




               34.4%                                                        47.0%


            Failure to Comply With Enrollment Requirements

            Failure to Comply With Work Requirements

            Failure to Comply With Child Support Enforcement Requirements

            Failure to Comply With Teen Parent School Attendance Requirements

            Failure to Comply With Teen Parent Living Arrangement Requirements

                                               a
                                                Terminations based on reaching a time limit were 0.2 percent through June 1996 and
                                               0.4 percent through Dec. 1996 (not included in figure).




Many Families Had                              Over half the families losing their AFDC benefits nationwide failed to meet
Benefits Terminated in                         new JOBS enrollment requirements under waiver programs, but, by the end
Transition to New                              of December 1996, the percentage had dropped below half (see fig. 2.2). Of
                                               the 11 states with termination provisions for failure to comply with
Programs                                       enrollment requirements, 4 states—Iowa, North Carolina, Virginia, and




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Wisconsin—had terminated benefits to families on the basis of these
provisions.30

In Wisconsin, converting the existing caseload of families to the new
program accounted for the relatively large proportion of terminations for
failure to appear and enroll in JOBS. Once the program was fully
implemented, the state expected that other reasons for termination would
predominate. In the first 4 months of program implementation, Wisconsin
terminated 1,634 ongoing cases for failure to meet this requirement (about
74 percent of families whose benefits had been terminated). For the most
part, such cases included recipients who had been under partial sanction
for failure to participate in the previous program but got a second chance
to comply with the new program. When told to enroll in JOBS and
participate up to 40 hours per week, about half of these recipients chose
not to do so. Once the state converted ongoing cases to the new program,
cases terminated for failure to enroll in JOBS were limited to existing cases
involving families who failed to appear after losing an exempt status (such
as families whose youngest child reached the age of 1 year). The state did
not identify new applicants’ cases as terminations for failure to enroll in
JOBS because they were not eligible for AFDC benefits unless they first
completed 60 hours of JOBS activities; because these families had received
no AFDC benefits, none had benefits terminated. As expected, over time
monthly caseload statistics reflected a sharp drop in terminations for
failure to enroll—from about 1,300 in May 1996 to about 300 in
September 1996. A Wisconsin program official predicted the number
would level off at a few hundred per month.

Iowa’s waiver required families to enter into a Family Investment
Agreement and stipulated a time frame and specific JOBS activities leading
to self-sufficiency. If they failed to enter into an agreement, families would
be placed in a Limited Benefit Plan, leading to benefit termination. Under
Iowa’s waiver, however, families could receive benefits for a limited time
even when they failed to enroll. As a result, although Iowa implemented
the program more than 2 years ago, over 80 percent of terminations
continued to result from families’ failure to enter into such agreements.




30
  For more details, see app. III for the states with termination provisions based on enrollment
requirements and app. VII for the number of families whose benefits were terminated due to these
requirements, by state.



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                                   Chapter 2
                                   Most Families’ Benefits Terminated on the
                                   Basis of Sanctions in a Few States




Increasing Proportion of           Between June and December 1996, the proportion of families losing their
Terminations Based on              AFDC benefits due to failure to comply with work requirements increased

Failure to Comply With             nationwide from 34 to 47 percent (see fig. 2.2). Of the 26 states with
                                   termination provisions for failure to comply with work requirements, 15
Work Requirements                  had terminated benefits to families on the basis of these provisions. Most
                                   states based compliance on recipients’ participation in activities specified
                                   in an individualized contract or plan, with failure to participate resulting in
                                   termination. In addition, some states also terminated benefits for
                                   recipients’ failing to accept job offers or quitting jobs. Explanations for
                                   families’ failure to comply varied.

                                   The proportion of families losing their AFDC benefits due to failure to
                                   comply with other requirements remained constant at about 8 percent,
                                   with less than 1 percent losing benefits due to reaching a time limit (see
                                   fig. 2.2). These proportions are most likely to change, however, over time
                                   and after existing cases are converted to the new programs. (For details
                                   on the bases for termination, by state, see app. VII.)

Noncompliance Due to Various       Recipients cited various reasons for not complying with work
Reasons                            requirements, according to state surveys of families losing AFDC benefits
                                   and our review of case files in Des Moines, Boston, and Milwaukee. For
                                   example, recipients said they would not participate because they

                               •   wanted to continue an activity that no longer qualified, such as attending
                                   beauty school or college;
                               •   were unwilling to do community service or work for low wages;
                               •   wanted to stay home with their children;
                               •   had other means of support;
                               •   did not feel well enough to work; and
                               •   needed to care for a sick household member.

                                   In the three case study states, caseworkers generally believed that families
                                   who allowed their benefits to be terminated had sufficient other sources of
                                   income—such as from unreported employment, extended family support,
                                   or other benefit programs. Caseworkers believed that if such families truly
                                   needed the assistance, they would call, come back into the office, and try
                                   to comply. According to surveys and case file notes, those families whose
                                   benefits were terminated often believed that the work activity available
                                   through the program was beneath them or the family simply disappeared.
                                   Many cases were later reopened or had other sources of support (see ch.
                                   3). Welfare advocacy groups have raised concerns that some families may
                                   truly need the assistance and have good cause for their failure to comply



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                                 but nevertheless fail to contact the office to explain their situation. State
                                 officials maintain, however, that it is recipients’ responsibility—not the
                                 caseworker’s—to either comply or to inform caseworkers of any good
                                 cause reason for noncompliance.31

States Have Limited Experience   Of the 14 states with termination provisions based on time limits, only 1
With Terminations Based on       state, Florida, had families reaching their time limits through
Time Limits                      December 1996. Under Florida’s waiver, families reaching their time limits
                                 were allowed extensions and a job guarantee if they had substantially
                                 complied with program requirements. Of the 74 Florida families whose
                                 benefits were terminated due to reaching a time limit as of
                                 December 1996, 43 families had substantially complied with program
                                 requirements and 31 families had not. All 43 families who complied
                                 nevertheless had their benefits terminated: 31 were employed and had
                                 continued to be eligible for AFDC until reaching their time limits only
                                 because of the waiver’s higher earned income disregard provisions, and
                                 the remaining 12 recipients got job offers from the state upon reaching
                                 their time limits) that they declined for various reasons. The 31 families
                                 who did not comply with program requirements had their benefits
                                 terminated and received no job offers upon reaching their time limits.32 In
                                 addition, more than 30 families left the program voluntarily before
                                 reaching the time limit because of employment or to retain some months
                                 of eligibility for the future.

Proportions Will Most Likely     The proportion of families whose benefits are terminated due to time
Change Over Time                 limits will most likely increase significantly over time, although this
                                 proportion was negligible in the early stages of program implementation.
                                 As more families in Florida and the other 13 states with time-limit waiver
                                 provisions begin to reach their time limits, the number of such
                                 terminations will most likely increase significantly. Under the new federal
                                 welfare reform law, families in all 50 states will begin to reach the 5-year
                                 federal time limit and have their benefits terminated in the year 2001 or
                                 2002.

                                 In addition, the proportion of terminations based on failure to comply with
                                 work requirements will most likely increase over time, compared with


                                 31
                                  For further discussion of these issues, see Evelyn Z. Brodkin, “The State Side of the ‘Welfare
                                 Contract’: Discretion and Accountability in Policy Delivery,” Social Security Administration Working
                                 Paper No. 6, Social Security Administration (Washington, D.C.: Nov. 1995.)
                                 32
                                   Another four Florida families who had not complied with program requirements also had reached
                                 their time limit as of Dec. 1996 but did not have their benefits terminated: three families continued to
                                 receive reduced benefits because the state determined that the children may be at risk for placement
                                 in foster care, and one family had benefits reinstated upon appeal.



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                              Chapter 2
                              Most Families’ Benefits Terminated on the
                              Basis of Sanctions in a Few States




                              other nonwork requirements. Many states’ waivers called for work
                              requirements to be imposed after a specified time period, allowing
                              families—including new applicants—to be enrolled in the program and to
                              receive benefits for a time without having to comply. As a result, states
                              would almost always identify cases closed due to failure to comply with
                              work requirements as terminations. In contrast, those states with waivers
                              calling for benefit termination for failure to comply with other, nonwork
                              requirements often treated those other requirements as eligibility criteria.
                              As a result, states would identify as terminations only ongoing cases that
                              became subject to the requirements and failed to comply. Thus, like the
                              proportion of terminations for failure to appear and enroll, the proportion
                              of terminations for failure to comply with these nonwork requirements
                              often primarily reflected the conversion of existing cases to the new
                              programs during initial implementation and will most likely decline once
                              programs are fully implemented. This trend will most likely continue
                              under the new federal welfare reform law as well because states may still
                              provide up to 24 months of federal benefits to families before imposing
                              work requirements; while states must impose school attendance and living
                              arrangement requirements on teen parents immediately as eligibility
                              criteria.33


Characteristics of Families   The characteristics of families losing AFDC benefits were generally
Losing AFDC Varied Due        representative of states’ overall caseloads. In Iowa, Massachusetts, and
to State Programs’            Wisconsin, most of the families studied reflected the states’ overall
                              caseloads: they had been receiving assistance less than 3 years and
Structure                     comprised a female head of household aged 20 to 39, with one or two
                              children (see app. VIII). The most significant variations resulted from the
                              structure of states’ programs regarding requirements placed on teen
                              parents and the age-of-youngest-child exemption.

                              In Massachusetts, for example, which had termination provisions for
                              families headed by teen parents who fail to comply with requirements for
                              school attendance and living arrangement, a disproportionately high
                              percentage of terminated cases studied were headed by a parent under age
                              20. Although teen-headed families constituted about 6 percent of the
                              state’s overall caseload, they accounted for almost 19 percent of the
                              terminated cases studied as of June 1996.



                              33
                                Under the new law, states have an incentive to keep the period of time brief for which they provide
                              benefits to families before imposing work requirements, however, because participation rates and
                              federal funding levels under the block grant could be affected (see footnote 25).



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Chapter 2
Most Families’ Benefits Terminated on the
Basis of Sanctions in a Few States




In addition, states’ provisions for the age-of-youngest-child exemption
resulted in disproportionately fewer families with children under the
designated age having their benefits terminated. For example, in
Wisconsin, families were exempt if their youngest child was under age 1.
Such families constituted more than 18 percent of the state’s total
caseload but less than 3 percent of the terminated cases studied.34
Similarly, Iowa exempted families if their youngest child was under 6
months old.35 Families with a child under age 1 constituted about
12 percent of the state’s total caseload but less than 7 percent of the
terminated cases studied. Massachusetts did not impose a mandatory
work requirement on families if their youngest child was under age 6. Such
families constituted 61 percent of the state’s total caseload but less than
33 percent of the terminated cases studied.36

Most states had little information on family characteristics, such as
education, work experience, and primary language, for their overall
caseloads compared with those families losing benefits. In Massachusetts,
which did gather such data, recipients in families losing their benefits
were less likely to have finished high school or to have worked in the past
10 years. (See app. IX.) Most of these differences could be attributed,
however, to the disproportionately large percentage of teen parents among
the families losing their benefits. In Michigan, where state officials also
compiled data on the educational background of heads of household, the
data indicated that although 38 percent of the total caseload was headed
by a recipient who had not completed high school or its equivalent, this
was true in 61 percent of cases terminated as of April 1996. Unlike in
Massachusetts, however, this difference could not be attributable to
benefit termination provisions for teen parents failing to comply with
school attendance and living arrangement requirements because Michigan
had not yet implemented such provisions.




34
  According to a state analyst who examined these cases, Wisconsin’s terminations of families with a
child under 1 year old were mostly because these were two-parent families. Two-parent families could
only exempt one parent for the care of a child under age 1, and noncompliance by the other parent
resulted in benefit termination.
35
 Iowa’s age-of-youngest-child exemption was lowered to under 3 months of age in a waiver
amendment implemented on Nov. 1, 1996.
36
  Massachusetts families with children under age 6 still had other requirements, such as the teen
school attendance and living arrangement requirements, for which noncompliance resulted in benefit
termination.



Page 32                                           GAO/HEHS-97-74 Welfare Benefit Termination
Chapter 3

After Losing AFDC, Families Had Various
Sources of Support

                      Families losing AFDC benefits lost a significant source of monthly income.
                      Although more than 80 percent of families in our analysis were
                      subsequently found to have one or more sources of support, or had
                      returned to welfare, the number of families continuing to receive food
                      stamps and Medicaid after losing AFDC dropped significantly in all three
                      states. Because reported income and receipt of benefits provide only a
                      partial indication of families’ well-being after losing AFDC, states tried to
                      locate such families and determine their status.


                      Under most states’ waiver provisions, families whose benefits were
Many Families Had     terminated for noncompliance could have had their AFDC cases reopened if
Returned to Welfare   they had subsequently complied with program requirements. In addition,
                      families reaching a time limit could generally have had their AFDC benefits
                      extended (at least temporarily) if they had complied with program
                      requirements or could have had their cases reopened after a specified time
                      period. A few states had variations to these basic provisions. For example,
                      in Iowa, families placed in the Limited Benefit Plan leading to benefit
                      termination for not signing a Family Investment Agreement may choose to
                      comply and sign such an agreement at any point before termination; once
                      terminated, however, all families must wait 6 months before their AFDC
                      cases may be reopened. Under the new federal welfare reform law,
                      families may have their cases reopened upon compliance only until they
                      reach their 5-year lifetime time limit, after which no further federal cash
                      benefits may be provided under the TANF grant.

                      Several states had many families (ranging from about 18 to 47 percent)
                      who lost AFDC benefits due to noncompliance and subsequently had their
                      cases reopened (see fig. 3.1).37 In Massachusetts and Wisconsin, about
                      one-third of enrolled families whose cases had been closed for
                      noncompliance were subsequently receiving AFDC. States reopened cases
                      on the bases of demonstrated compliance and documented exemption or
                      because cases had been closed due to administrative error. In Iowa, once
                      the 6-month benefit termination period had elapsed, about one-third of the
                      families studied also had returned to AFDC rolls.




                      37
                        We gathered data on case status between Sept. and Dec. 1996, which in most instances represented
                      the case status 2 to 8 months after case closure but varied by state (see app. I).



                      Page 33                                           GAO/HEHS-97-74 Welfare Benefit Termination
                                  Chapter 3
                                  After Losing AFDC, Families Had Various
                                  Sources of Support




Figure 3.1: Percentage of Cases
Reopened After Termination for    Percentage
Noncompliance                     50
                                                                                       47.0

                                  45

                                  40                                                                        37.7

                                  35   32.8
                                                                         33.7
                                                    32.1

                                  30

                                  25
                                                            21.0
                                  20                                                            17.8

                                  15

                                  10

                                   5

                                   0
                                         a



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                                                   hu




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                                               ss




                                                                                So
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                                  a
                                   In Wisconsin, this figure represents the percentage of cases reopened for those whose benefits
                                  were terminated for noncompliance after enrolling in JOBS. Those families whose benefits were
                                  terminated for failure to enroll had a much lower percentage of their cases reopened—about
                                  4 percent.


                                  The number of reopened cases demonstrated that the stronger sanctions
                                  were working as intended—to reinforce the need for recipients to comply
                                  with requirements if they wished to continue receiving benefits, according
                                  to state officials. As one Boston caseworker said, “Many clients don’t take
                                  the program seriously until the checks stop. Loss of just the adult portion
                                  of the grant isn’t enough to get their attention. [But] when they get no
                                  benefits at all, they’re on the phone with their caseworker right away.”38 In
                                  most cases, recipients agreed to comply or provided a reason for an
                                  exemption; in some cases, however, administrative errors were revealed
                                  (see “Establishing Tracking and Notification Systems Challenged States” in
                                  ch. 4).



                                  38
                                   Under the JOBS program, the sanction for noncompliance was removing the adult portion of the
                                  grant, commonly referred to as “reduced benefits” (rather than terminated benefits) or a “partial
                                  sanction” (rather than a full-family sanction).



                                  Page 34                                                     GAO/HEHS-97-74 Welfare Benefit Termination
                              Chapter 3
                              After Losing AFDC, Families Had Various
                              Sources of Support




                              Although AFDC represented a significant source of income for most families
Families Lost Income,         before they lost their benefits, after AFDC benefits were terminated, at least
but Many Had Some             75 percent of families studied in Iowa, Massachusetts, and Wisconsin
Sources of Support            reported having some source of income or benefits.39 In many cases,
                              families’ sources of support were a continuation of income or benefits
                              received before AFDC termination, though the amount of reported income
                              increased after termination. The number of families receiving food stamps
                              and Medicaid significantly decreased after termination, however, despite
                              waiver provisions that eligibility was to be unaffected. Although some of
                              these decreases may have been due to increases in household income, at
                              least some decreases may have been due to families’ no longer receiving
                              benefits for which they may still have been eligible.


Families Lost a Significant   The AFDC monthly benefit represented a significant source of income for
Source of Income              families in states terminating benefits under waivers—not only because of
                              the average dollar amount of the AFDC benefit, but also because AFDC was
                              the only reported source of income for some families (see apps. XI and
                              XII). Among the households studied in Iowa, Massachusetts, and
                              Wisconsin whose cases remained closed, average AFDC payments were
                              smaller than other sources of income before termination, but AFDC was the
                              only source of income received by all families (although most also
                              received food stamps). Supplemental Security Income (SSI) and wages
                              were the largest income sources, but relatively few households reported
                              such income.40 (See table 3.1.)




                              39
                                We used household as our unit of analysis, which may include household members not included in
                              the AFDC family unit used for determining AFDC eligibility and calculating AFDC benefits before
                              termination. (See app. X for a summary table of the percentage of households studied receiving
                              reported income and benefits and app. I for more details on the methodology used in conducting the
                              data matches.)
                              40
                               However, the percentage of families losing AFDC benefits who had a household member receiving
                              SSI was significantly higher than the percentage of families in the general AFDC caseload who had a
                              household member receiving SSI (see apps. X and XII).



                              Page 35                                           GAO/HEHS-97-74 Welfare Benefit Termination
                                         Chapter 3
                                         After Losing AFDC, Families Had Various
                                         Sources of Support




Table 3.1: Sources of Income Before Termination for Households Studied
                           AFDC                   Food stamps                              SSI                       Reported wages
                    Average    Percent of         Average       Percent of        Average       Percent of          Average      Percent of
                    monthly   households          monthly      households         monthly      households           monthly     households
State               amounta     receiving         amount         receiving        amount         receiving          amount        receiving
Iowa                   $277         100.0             $279             83.6           $490               9.8            $692              17.4
Massachusetts           390         100.0               215            95.9              482            12.7             394              14.3
Wisconsin               369         100.0               246b           76.2              554            12.6             551c             35.9
                                         a
                                          Average monthly AFDC benefits lost were lower than the statewide averages (see app. XI)
                                         mainly because many families had been sanctioned and were receiving reduced benefits before
                                         termination. In addition, under benefit determination standards, families with earned income often
                                         received a reduced AFDC benefit.
                                         b
                                             Does not include those households under food stamp sanction receiving $10 per month.
                                         c
                                            May include other income such as pensions.



                                         During winter months, fuel assistance provided through the federal
                                         Low-Income Home Energy Assistance Program was also a significant
                                         source of income. Families on AFDC were generally also enrolled in this
                                         program, but the amount of assistance varied by state as determined by
                                         the state allocation plan. In 1995, households received fuel assistance
                                         averaging $197 a month in Iowa, $348 in Massachusetts, and $300 in
                                         Wisconsin.41 In addition, about 25 percent of the households studied in
                                         Iowa, Massachusetts, and Wisconsin lived in subsidized housing.42

                                         In households in which the amount of the AFDC benefit was low compared
                                         with the amount of other available benefits, states had less leverage for
                                         encouraging compliance through threats of terminating AFDC benefits.
                                         Among cases closed for noncompliance in our case study states,
                                         25 percent or more of the households were receiving benefits from two or
                                         more other programs before termination, so that the combined amount
                                         perhaps minimized the loss of the AFDC benefit.43


                                         41
                                          No data were gathered for the amount of fuel assistance benefits received by the individual
                                         households in our study because these benefits were mainly provided only during winter months, and
                                         we conducted our analysis before implementation of the 1997 winter benefit allocation.
                                         42
                                           At the time of our review, some families also received $50 per month from a child support
                                         pass-through; however, no data were available from Iowa and Wisconsin indicating which families
                                         received such payments. The new welfare reform law has eliminated the $50 child support
                                         pass-through requirement.
                                         43
                                           Analysis of benefits received included food stamps, SSI, and housing assistance. The percentage of
                                         cases receiving benefits from two or more of these programs before termination were 27.9 percent in
                                         Iowa, 33.2 percent in Massachusetts, and 24.6 percent in Wisconsin.



                                         Page 36                                           GAO/HEHS-97-74 Welfare Benefit Termination
                             Chapter 3
                             After Losing AFDC, Families Had Various
                             Sources of Support




Many Families Reported       Between 43 and 48 percent of the households whose AFDC cases remained
Having Wages, Pensions, or   closed in Iowa,44 Massachusetts, and Wisconsin reported having some
Child Support                income from wages, pensions,45 or child support after losing AFDC.
                             Between 23 and 32 percent of households had reported wages (see fig.
                             3.2). Because not all households had to report such income, these
                             percentages are likely to be understated. Households not applying for or
                             receiving AFDC or other benefits did not have to report such income (about
                             25 percent of cases studied). In addition, neither Iowa nor Wisconsin had
                             data on pensions,46 and all three states had only partial data on child
                             support.47 As a result, households in our study were likely to have
                             additional unreported income, according to state officials we spoke with.48




                             44
                              At the time of our analysis, 6 months had not yet elapsed and all the Iowa cases included in our study
                             were still closed.
                             45
                               Pension income includes Social Security, Veterans’ Benefits, and employment-related pensions.
                             46
                               Wisconsin’s wage data may include some pension data.
                             47
                               Once no longer receiving AFDC, some families may receive child support payments privately, which
                             they do not have to report to the state and local offices of Child Support Enforcement, where we
                             obtained the child support data.
                             48
                               Even when reporting is required, households sometimes fail to report wages and other income. See
                             Christopher Jencks and Kathryn Edin, “The Real Welfare Problem,” The American Prospect, No. 1
                             (1990), pp. 31-50; and Kathryn Edin, Single Mothers and Absent Fathers: The Possibilities and Limits of
                             Child Support Policy, Center for Urban Policy Research, Rutgers University (New Brunswick, N.J.:
                             1994).



                             Page 37                                            GAO/HEHS-97-74 Welfare Benefit Termination
                                       Chapter 3
                                       After Losing AFDC, Families Had Various
                                       Sources of Support




Figure 3.2: Percentage of Households
Reporting Income After Benefit
Termination




                                       Although in many cases households had reported these sources of income
                                       both before and after termination, some reported changes in income
                                       sources after termination. For example, of those households with reported
                                       wages after termination, about half had reported no wages before
                                       termination, suggesting that household members found new jobs or that
                                       household composition changed.49 Of those reporting wages both before




                                       49
                                         In Iowa, the percentage of households that reported wages after termination but none before
                                       termination was 52.6 percent; in Massachusetts, 61.5 percent; and in Wisconsin, 39.5 percent.
                                       (Wisconsin data may include other income, such as pensions, which was a likely income source before
                                       termination.)



                                       Page 38                                          GAO/HEHS-97-74 Welfare Benefit Termination
                                       Chapter 3
                                       After Losing AFDC, Families Had Various
                                       Sources of Support




                                       and after termination, the amount of monthly wages increased
                                       significantly.50 (See table 3.2.)

Table 3.2: Reported Wages Before and
After Termination                                               Of cases with
                                                             reported wages after         Of cases with reported wages both before
                                                                 termination                        and after termination
                                                                  Average monthly             Average monthly              Average monthly
                                                                            wage                  wage before                    wage after
                                       Iowa                                       $667                        $648                        $741
                                       Massachusetts                               594                          373                         540
                                       Wisconsin                                   754                          607                         870
                                       Note: Includes wages of all household members, including those who may not have been part of
                                       the AFDC family unit before termination.



                                       Despite the increases for some families, the amount of reported average
                                       monthly wages among families losing AFDC still placed them below the
                                       poverty level, even for the smallest family unit of one adult and one child.
                                       This level is $875 a month, according to the Census Bureau’s 1995 poverty
                                       thresholds. Wisconsin state officials pointed out, however, that a low-wage
                                       job, combined with the earned income tax credit, would result in a
                                       significantly higher income than the average AFDC grant—which was $465 a
                                       month for a three-person family in Wisconsin in 1995. Massachusetts state
                                       officials agreed with this observation and noted further that income would
                                       be even greater for families using child care services, Medicaid benefits,
                                       and food stamps (for which earned income is treated more generously
                                       than AFDC income). In addition, officials noted that families with earned
                                       income also realize self-esteem benefits from working and being
                                       productive members of society.

                                       Of those with reported child support income after termination, average
                                       monthly payments received were $274 in Iowa, $249 in Massachusetts, and
                                       $217 in Wisconsin. In accordance with prior federal law, any child support
                                       payments received before termination would have been signed over to the
                                       state, and the families would have only received a pass-through of up to
                                       $50 a month. The new welfare reform law has eliminated the $50 pass-


                                       50
                                         Although some households had members who were working before the family’s benefits were
                                       terminated, these families’ benefits were, nevertheless, terminated for noncompliance and are not
                                       included in the statistics on those leaving welfare to go to work. Many of these families’ benefits were
                                       terminated for failure to enroll in JOBS. In other cases, either (1) the household members who were
                                       working were not part of the AFDC assistance unit, (2) those who were working were part of the
                                       assistance unit but were not working consistently enough to meet states’ work requirements or had
                                       not reported their wages to their caseworkers, or (3) the family’s benefits were terminated for failure
                                       to comply with some other requirement such as failure to attend school.



                                       Page 39                                             GAO/HEHS-97-74 Welfare Benefit Termination
                         Chapter 3
                         After Losing AFDC, Families Had Various
                         Sources of Support




                         through requirement, and states are allowed to keep the full amount of
                         payments received for families on welfare.

                         Consistently in all three states, a lower percentage of households in the
                         urban areas studied had reported income from wages, pensions, and child
                         support than households in the rest of the state. The percentage of cases
                         reporting child support revealed the most significant variations: 10 to
                         14 percent in Des Moines, Boston, and Milwaukee, compared with 18 to
                         29 percent in cases outside these urban areas. (See app. X for complete
                         data on reported income and benefits received by cases in urban areas
                         compared with cases studied in other areas.)


Many Receive Benefits    As under the waivers, under the new federal welfare reform law, families
From Other Federal and   whose AFDC benefits are terminated for noncompliance generally continue
State Programs           to be eligible for benefits from other federal and state programs.51 In the
                         case of fuel assistance and housing, the benefit amount may even increase
                         when income falls from loss of AFDC. At the time of our review, families
                         continuing to receive food stamps after their AFDC benefits were
                         terminated also often had an increase in their monthly food stamp
                         allotment due to losing AFDC.52 However, federal law now prohibits any
                         increase in food stamps to families losing AFDC (or TANF) benefits due to
                         sanctions.53

                         After losing AFDC, about 75 percent of households studied in Iowa,
                         Massachusetts, and Wisconsin received benefits from one or more other
                         federal programs—including food stamps, SSI, housing assistance, and
                         Medicaid. Analyzing benefits received separately for each program
                         revealed variations among states (see fig. 3.3). The ranges of percentages
                         were fairly consistent for housing, SSI, and Medicaid but varied
                         significantly for food stamps, partly reflecting the states’ different food
                         stamp policies.




                         51
                          The new law, however, provides that states may terminate Medicaid eligibility for adults who fail to
                         comply with work requirements under TANF and that states may terminate food stamps to an entire
                         household if adults fail to comply with work requirements under TANF, with some restrictions.
                         52
                          On average, the increase ranged from $21 to $51 per month for households studied in Iowa,
                         Massachusetts, and Wisconsin. Households with other sources of income had lowered the average
                         amount of increases.
                         53
                          Federal regulations (7 C.F.R., Parts 272 and 273) were effective May 31, 1996; however, states had
                         until Nov. 27, 1996, to implement the provisions.



                         Page 40                                            GAO/HEHS-97-74 Welfare Benefit Termination
                                        Chapter 3
                                        After Losing AFDC, Families Had Various
                                        Sources of Support




Figure 3.3: Percentage of Households
Receiving Benefits After Termination,   100      Percentage
by Program
                                         90

                                         80

                                         70

                                         60

                                         50

                                         40

                                         30

                                         20

                                         10

                                             0

                                                  Food Stamps             SSI            Housing             Medicaid



                                                              Iowa

                                                              Massachusetts

                                                              Wisconsin



Percentage of Families                  In general, according to program policies, termination of AFDC benefits due
Receiving Food Stamps and               to noncompliance was not to affect a family’s eligibility for SSI,54 housing
Medicaid Decreased                      assistance, and Medicaid—and, in most states, food stamps—unless the
Significantly                           family’s circumstances changed. Consistent with these policies, the
                                        percentages of households studied in Iowa, Massachusetts, and Wisconsin
                                        receiving SSI and housing assistance did not change before and after
                                        termination in all three states; however, the statewide percentages of
                                        cases receiving food stamps and Medicaid decreased significantly, with
                                        even greater reductions in the urban areas. Michigan’s study of terminated
                                        cases found similar decreases.55 While some of the decreases in each state
                                        may legitimately be due to families’ finding employment and no longer
                                        meeting income eligibility standards, at least some of the decreases reflect
                                        families’ no longer receiving benefits for which they were still eligible.


                                        54
                                          Aged, blind, and disabled individuals are eligible for SSI benefits if they meet specified criteria and
                                        federal income standards. Individuals receiving SSI may not receive AFDC and were excluded from the
                                        benefit calculation for an AFDC family unit; SSI recipients were included in our analysis of income and
                                        benefits of household members (see footnote 39).
                                        55
                                          Of those families whose benefits were terminated as of Apr. 1996 in Michigan, after 3 months, food
                                        stamp receipt had dropped to 57 percent and active Medicaid status had dropped to 59 percent.



                                        Page 41                                             GAO/HEHS-97-74 Welfare Benefit Termination
Chapter 3
After Losing AFDC, Families Had Various
Sources of Support




To maintain eligibility for food stamps and Medicaid after losing AFDC
benefits, families must continue to meet monthly reporting requirements
and appear for periodic eligibility reviews. To maintain eligibility for food
stamps in Massachusetts, families must also appear for recertification.
When families lose their AFDC grant, some recipients fail to take the steps
necessary to maintain eligibility even though they would be eligible for
continued food stamp and Medicaid benefits, explained officials in our
case study states. On the basis of an internal review of cases closed for
failure to comply with work requirements over a 2-month period,
Massachusetts state officials concluded that most of such families might
have believed it not worth the effort to seek benefits or, in fact, might not
have been eligible for continued benefits due to changes in their
circumstances following case closure.56 Nevertheless, officials in all three
states expressed surprise at the amount of the decline in receipt of food
stamps and Medicaid among households losing AFDC benefits (see fig. 3.4).




56
 For a more detailed description of this case review and its findings, see “Other Indicators of Family
Well-Being” in this chapter.



Page 42                                             GAO/HEHS-97-74 Welfare Benefit Termination
                                       Chapter 3
                                       After Losing AFDC, Families Had Various
                                       Sources of Support




Figure 3.4: Percentage of Households
Receiving Food Stamps and Medicaid
Before and After Termination




                                       Before losing AFDC, virtually all families were covered by Medicaid, as
                                       required under prior federal law. In addition, due to comparable income
                                       eligibility criteria, a high percentage of families receiving AFDC also
                                       received food stamps: the national average was 90 percent in 1995. After
                                       AFDC benefit termination, under most states’ waivers (including Iowa’s and
                                       Massachusetts’s) eligibility for food stamps was to continue unaffected. In
                                       Iowa, state officials viewed continued receipt of food stamps as part of a
                                       safety net for families during the 6-month period they must wait to reapply
                                       for AFDC benefits.




                                       Page 43                                   GAO/HEHS-97-74 Welfare Benefit Termination
                                 Chapter 3
                                 After Losing AFDC, Families Had Various
                                 Sources of Support




                                 In contrast, other states’ waivers required food stamps to be sanctioned
                                 along with AFDC for failure to meet work requirements.57 In Wisconsin,
                                 waiver provisions linked the two programs so that cases closed due to
                                 failure to comply with JOBS enrollment and work requirements would have
                                 their food stamp allotment reduced to $10 per month indefinitely (that is,
                                 no 2-month limit) if they were not exempt from the food stamp
                                 employment and training program.58 As shown in fig. 3.4, this food stamp
                                 sanction affected 8.1 percent of the AFDC cases studied in Wisconsin before
                                 closure and 16.3 percent after closure. Under the new federal welfare
                                 reform law, states may still choose to link the work requirements of the
                                 food stamps and TANF programs.59

Availability of Other Services   In addition to the programs discussed above—food stamps, SSI, housing,
and Benefits Varied              fuel assistance, and Medicaid—states offered other benefits and services
                                 to terminated families; such services varied somewhat by state. For
                                 example, states generally offered mental health and substance abuse
                                 counseling and treatment programs, often within the same departments
                                 administering the AFDC program and with priority given to AFDC recipients.
                                 Massachusetts administered such programs by a separate department with
                                 no direct eligibility links to AFDC. Of the households whose cases remain
                                 closed in Massachusetts, 33.6 percent had used such counseling and
                                 treatment services either before or after termination, with 12.7 percent
                                 using services after termination (including 3.9 percent who began
                                 receiving services only after termination).

                                 In addition, the availability of child care or transportation assistance for
                                 those losing AFDC benefits varied by state. States generally provided child
                                 care and transportation subsidies linked to the AFDC program, including
                                 transitional help for those leaving AFDC due to employment in all three of
                                 our case study states; however, for those families losing AFDC benefits due
                                 to noncompliance, state-provided subsidies varied. In Iowa, non-AFDC
                                 recipients could receive state-assisted child care if they met the income

                                 57
                                   Similar to AFDC, the food stamp program also provided for work requirements, but the requirements
                                 were generally more lenient than those included in states’ AFDC waivers. For example, families with
                                 children under age 6 were exempted from the food stamp work requirements, and the sanction for
                                 failure to meet the requirement was limited to 2 months.
                                 58
                                  Wisconsin cases sanctioned but not closed for noncompliance with AFDC work requirements would
                                 have their food stamp benefits reduced on the basis of hours not worked, similar to the sanctions
                                 under AFDC (see app. VI).
                                 59
                                   In addition, if states had submitted waiver requests to lower the age-of-youngest-child exemption,
                                 and such requests had been denied as of Aug. 1, 1996, states were allowed to lower the age of youngest
                                 child to 1 year for the food stamps work requirement, providing for greater comparability in the two
                                 programs’ requirements as an experiment for up to 3 years. Furthermore, the law stipulated that the
                                 food stamp sanction may last up to 6 months but not longer.



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                          Chapter 3
                          After Losing AFDC, Families Had Various
                          Sources of Support




                          criteria (less than 110 percent of the federal poverty level), according to a
                          state official. Wisconsin also provided child care assistance on a sliding
                          scale. Although Massachusetts offered a similar child care assistance
                          program for non-AFDC recipients, funding was limited and waiting lists
                          were long. Non-AFDC families could expect to wait several months, or even
                          years, for a subsidized child care slot depending on the location and type
                          of care needed.

                          Although many states have general assistance programs (state- and
                          county-funded assistance programs, generally for adults), families losing
                          AFDC benefits do not always qualify for such assistance.60 In
                          Massachusetts, less than 1 percent of the families studied were receiving
                          general assistance after losing AFDC. Iowa had no statewide data on its
                          county-funded general assistance program, and Wisconsin had
                          discontinued its statewide general assistance program in January 1996.


                          Reported income and benefits receipt only partially describe the
Other Indicators of       well-being of families after losing AFDC. Some families may not report
Family Well-Being         income, and no data were available for some families. Also, despite
                          receiving some income and benefits, total household income may still fall
                          short of the poverty threshold, and children’s well-being may be at risk. In
                          response to concerns about the well-being of families losing AFDC for
                          noncompliance under waivers, states have tried to locate such families
                          and determine their status.

                          In Iowa, the state public health workers have routinely tried to visit
                          families 1 month after benefit termination to check on their well-being and
                          make referrals for other services as needed. Of the 5,333 families they tried
                          to visit in the year ending in June 1996, they contacted less than half
                          (2,270). Of those contacted, caseworkers found no cases of severe
                          deprivation. Results of their contacts were as follows:

                      •   37 percent no longer need assistance,
                      •   18 percent planned to go back on AFDC when eligible,
                      •   29 percent received information or referral for other services, and
                      •   16 percent refused to cooperate.



                          60
                            Of the 42 states with general assistance programs, 12 states provide assistance to all financially needy
                          people who qualify; 30 states provide assistance only to certain categories of people. Of these 30, 19
                          states provide assistance to low-income children or families with children. (See State General
                          Assistance Programs 1996, The Urban Institute (Washington, D.C.: 1996.))



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    After Losing AFDC, Families Had Various
    Sources of Support




    In addition, Iowa’s contracted evaluators, Mathematica Policy Research,
    Inc., and the Institute for Social and Economic Development, conducted a
    survey of recipients whose cases had been terminated between November
    1995 and January 1996 to determine what happened after termination.
    Tentative findings from this study indicate that the effects of losing cash
    assistance varied widely. Forty percent of families’ incomes increased
    after benefit termination, but nearly half the families’ incomes decreased.
    Despite such decreases, the study did not find evidence of extreme
    economic distress among the survey’s 137 respondents.

    Massachusetts made a special effort to locate minor teens whose benefits
    had been terminated. As of February 1997, state officials reported that 192
    of the 314 teens referred for follow-up (about 61 percent) had returned to
    welfare or had been located by the two contractors hired to find and
    interview these teens. As of our review, however, data on the status of
    those not returning to welfare had not yet been compiled.

    In addition, in December 1996, Massachusetts released the results of a
    state study to determine the status of families who had left welfare during
    September and October 1996. Data on those families whose benefits had
    been terminated for noncompliance with work requirements and who had
    not returned to welfare showed the following:

•   51 percent had new jobs,
•   16 percent had new living arrangements,
•   14 percent had new unearned income,
•   6 percent had moved out of state, and
•   13 percent were in an “other” category.

    Michigan gathered data on the 168 families whose AFDC benefits had been
    terminated as of April 1996, surveying the 126 families whose cases had
    not been reopened after 3 months. Interviewers did not complete surveys
    with 59 (or about 47 percent) of these families mainly because they could
    not be located or refused to cooperate. Of the 67 families interviewed,
    when asked about their problems and how they were managing without
    cash assistance, 22 percent responded that they were having no problems.
    A few commented that closing their case was the best thing that ever
    happened, that it was the push they needed, and that it gave them the
    opportunity to better their lives. The study concluded that of those
    interviewed, however, many faced serious problems, with 27 percent
    indicating a problem providing enough food for their family and 29 percent




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After Losing AFDC, Families Had Various
Sources of Support




with insufficient money to provide for personal needs. One family had
been evicted, and seven had received eviction notices. Families said they
were getting by financially by finding jobs and relying on help from family,
friends, or community resources, and some were receiving child support
or SSI; 3 percent said they were “not getting by.”

A wide variety of family histories and characteristics may affect a family’s
prospects after benefit termination. On the one hand, according to
caseworkers, families with previous work experience or unreported
income are most likely to be doing well. On the other hand, caseworkers
were less optimistic about other families’ prospects. In some cases,
because the caseworkers believed the families’ situations were tenuous,
they tried repeatedly but to no avail to contact the families and encourage
compliance.




Page 47                                   GAO/HEHS-97-74 Welfare Benefit Termination
Chapter 4

Termination Provisions Were Effective but
Posed Challenges

                         Benefit termination provisions have improved the effectiveness of welfare
                         programs in Iowa, Massachusetts, and Wisconsin by increasing work
                         activity and job placements and decreasing the number of families on the
                         welfare rolls, state officials believed. In addition, the percentage of the
                         caseload terminated for noncompliance was small compared with the total
                         number of cases—generally about 1 percent or less per month.
                         Nevertheless, implementing benefit termination provisions has posed
                         significant challenges. First, states had to develop systems to accurately
                         track hours worked to monitor compliance and to correctly and
                         adequately notify recipients of pending termination actions. Second, states
                         had to provide certain activities and services or they could not terminate a
                         family’s benefits.


                         Benefit termination provisions in all three states encouraged those with
Provisions Resulted in   other sources of income to move off welfare more quickly and those who
Increased Compliance     truly needed assistance to cooperate more fully with program
and Declining            requirements, according to state officials. With an improving economy,
                         welfare caseloads nationwide have generally declined over the past 3
Caseloads                years; however, the declines in Iowa, Massachusetts, and Wisconsin have
                         exceeded the average decline for the country’s 54 states and territories
                         (see fig. 4.1). Wisconsin’s decline for the period was 38 percent, nearly
                         three times the national average of 13 percent. While crediting the
                         economy as the major factor, officials in all three states believed at least
                         some of the declines were due to their waiver provisions. Iowa’s program
                         has succeeded, in part, because the prospect of benefit termination is a
                         much more effective motivator than the previous adult sanction, which
                         was a relatively minor grant reduction, according to the state program
                         administrator. Massachusetts’s caseload fell after the provisions of the
                         new program were publicized in the press and in mailings to and
                         discussions with recipients. In Wisconsin, when staff explained the benefit
                         termination policy for noncompliance with work requirements to new
                         applicants, many chose to accept jobs rather than go on welfare in the first
                         place, explained state officials. According to data compiled in one county,
                         46 percent of 880 applicants deemed likely to have gone on welfare
                         between March and July of 1996 were diverted from welfare through this
                         process.




                         Page 48                               GAO/HEHS-97-74 Welfare Benefit Termination
                                        Chapter 4
                                        Termination Provisions Were Effective but
                                        Posed Challenges




Figure 4.1: AFDC Caseload Declines in
Case Study States Exceeded National     AFDC Caseloads (in Thousands)
Average, 1993-96                        120



                                        100



                                            80



                                            60



                                            40



                                            20



                                             0
                                                 93




                                                                   94




                                                                                           95




                                                                                                                  96




                                                                                                                                            96
                                             19




                                                                   19




                                                                                         19




                                                                                                                 19




                                                                                                                                            19
                                                                                                                                       pt.
                                                                                                                                       Se
                                                       Nationwide Averagea
                                                       Iowab
                                                       Massachusetts
                                                       Wisconsin


                                        a
                                         Total caseload nationwide divided by 54 states and territories (District of Columbia, Guam,
                                        Puerto Rico, and the Virgin Islands).
                                        b
                                         The increase in Iowa’s caseload in 1994 was due to the increase in the amount of income
                                        disregarded, which allowed more people to be eligible for assistance, and the expansion of the
                                        program for two-parent families, according to the program coordinator.

                                        Sources: 1993 to 1996, HHS data on states’ total caseloads representing the average of monthly
                                        caseloads during the fiscal year; Sept. 1996 HHS and state monthly caseload data.


                                        The threat of benefit termination significantly affected program
                                        participation, stated officials in Wisconsin and Massachusetts. In
                                        Wisconsin, in the first 3 months after implementation, participation in JOBS
                                        sessions increased by 36 percent compared with the previous 3 months,
                                        according to staff at a Milwaukee job center we visited. In addition, job
                                        placements at the center more than doubled between 1995 and 1996, from
                                        about 1,000 to about 2,500. Statewide, Wisconsin reported 24,000 job




                                        Page 49                                           GAO/HEHS-97-74 Welfare Benefit Termination
                        Chapter 4
                        Termination Provisions Were Effective but
                        Posed Challenges




                        placements in 1996. In Massachusetts, in less than a year after
                        implementing the waiver provisions, cases with earned income had
                        increased from 8 to 13 percent, and about 12,000 recipients left the rolls by
                        finding work, according to state officials. In addition, among recipients
                        required to work, the number participating in work activities increased
                        28 percent between June and October 1996. In Iowa, where
                        noncompliance did not result in immediate termination of benefits, the
                        percentage of recipients participating in JOBS sessions had not increased
                        significantly, and state officials said they were considering program
                        changes to impose sanctions more quickly. Nevertheless, after 2 years of
                        implementation, state officials reported that 35,000 recipients had been
                        placed in jobs.


                        The states faced challenges in establishing systems to track recipients’
Establishing Tracking   work activity to accurately determine when benefits should be terminated
and Notification        for noncompliance and in adequately notifying recipients of these actions.
Systems Challenged      This was particularly true for Wisconsin’s Pay for Performance project,
                        which determined the amount of each month’s benefits and imposed
States                  sanctions on the basis of the number of hours worked in a previous
                        month. Wisconsin implemented the project statewide without first pilot
                        testing its provisions and encountered many start-up difficulties. While
                        Iowa and Massachusetts phased in implementation over 7 to 10 months,
                        these states also faced challenges in accurately tracking cases and
                        adequately notifying recipients of pending sanctions.

                        In Wisconsin and Massachusetts, recipients and employers sometimes
                        failed to submit time stubs or verify hours on a timely basis, and often pay
                        periods did not correspond with calendar months. In addition, work hours
                        for recipients in low paying jobs often fluctuated from week to week and
                        month to month, making it difficult for states to determine how many
                        hours a recipient was required to work and, if the hours dropped below
                        that amount, what if any additional requirements the recipient must fulfill
                        to avoid a sanction.

                        In Wisconsin, JOBS and AFDC workers, who often worked for different
                        organizations and were located at different sites, split responsibility for
                        handling cases. The JOBS workers determined the number of hours each
                        recipient must work and tracked the hours of JOBS activities for their
                        caseloads of up to 200 or more. The AFDC workers received pay stubs from
                        employers and entered hours worked for their caseloads of up to 400. Both
                        had difficulty gathering and entering data in the short time frames



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required, and communication between the two was often lacking. The
computer system in Wisconsin was fairly new, and the eligibility workers
and case managers entered information differently. As a result, sometimes
the data they entered conflicted and they often had a hard time
determining the status of individual cases.61

Massachusetts, also initially split responsibilities between JOBS and AFDC
workers, but generally these workers were collocated at the sites we
visited. JOBS workers monitored hours worked, and AFDC workers
determined if recipients met requirements. Sometimes difficulties arose
because JOBS and AFDC workers did not know of each others’ actions, but
workers we spoke with generally liked this arrangement. To streamline
operations, however, in September 1996 the state began integrating these
two roles—expanding the AFDC workers’ job duties to include employment
functions. Because of this, Massachusetts’s most significant
implementation issues involved training AFDC workers to assume these
functions. Several AFDC workers noted a dramatic increase in their
workload due to the need to constantly monitor recipients’ participation in
work activities on a biweekly basis in addition to assessing compliance
with other eligibility requirements.

Due to the difficulties of accurately tracking recipients’ hours worked, as
well as training workers to understand and apply all the new program
rules correctly, all three states had problems notifying recipients of
sanctions during initial program implementation. Milwaukee County,
Wisconsin, issued 5,182 sanctions through August 20, 1996. Of these,
44 percent were later reversed because recipients had met program
requirements or inaccurate data had been corrected. During the 2 months
when the system converted to automatically issuing sanction notices, the
error rate was as high as 70 percent. In addition, staff had reopened cases
on the computer with no evidence that the recipient had begun to comply
with program requirements, according to our case file review. Because so
many incorrect sanction notices had been sent out, recipients were
confused by what was required of them and overwhelmed workers with
calls. Even when accurate, the notices confused recipients because of the
system’s prospective aspect: hours worked in any given month determined
the amount of benefits 2 months in the future. Thus, when recipients


61
  As part of its 1997 implementation plan, Wisconsin planned to have one case manager handle both
JOBS and AFDC functions. State officials believed this would lead to reduced caseloads and eliminate
the work and confusion between the two staffs. In Dane County (Madison) and in a few instances in
Milwaukee County, where the AFDC and JOBS workers have been collocated at one JOBS center,
administering cases has become easier, and program managers believe that fully integrating the two
roles would further facilitate case management.



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Posed Challenges




received a sanction notice and then began to participate, they did not
understand why they did not get any benefits the following month.

In Massachusetts, program staff and welfare advocates also reported
initial difficulties in tracking recipients’ work hours, applying new
program rules correctly in individual cases, and adequately notifying
recipients of termination actions. Initially, if multiple actions took place,
Massachusetts’s computer system combined these into a single notice to
the recipient. This sometimes resulted in notices that did not make sense.
For example, we found one notice that informed the recipient, “The
Department will raise your [AFDC] benefits from $55 to $343 . . . because
you or a household member failed to comply with the requirements of the
work program without good cause.” State officials eventually resolved
these problems by issuing separate notices for each action. In addition,
welfare advocates raised concerns that termination notices did not
provide enough information on good cause reasons for failure to
participate, requirements for recipients to have benefits reinstated, and on
the continuation of food stamps and Medicaid eligibility. The notices did
state, however, that Medicaid benefits would continue (subsequently
revised to include food stamps), that recipients could call their
caseworker with questions, and that free legal services were available.
When the state learned of instances of its failure to accurately track work
hours or apply program rules correctly in individual cases, those cases
were reopened and recipients given another opportunity to comply. As of
December 1996, recipients appealed 978 actions, and records show that
47 percent of actions resolved had been decided, at least in part, in the
recipients’ favor.

Iowa officials also reevaluated their notification procedures because of
concerns about recipients being overloaded with information and
instructions and the effectiveness of procedures in giving recipients
informed choice. Of the 2,073 cases entering the Limited Benefit Plan
between November 1995 and January 1996, about 28 percent subsequently
enrolled in the Family Investment Program before termination due to
either (1) recipients signing a Family Investment Agreement or (2) the
state determining that recipients had been enrolled in the Limited Benefit
Plan in error.




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                       Chapter 4
                       Termination Provisions Were Effective but
                       Posed Challenges




                       Another challenge facing the states was providing sufficient services to
Providing Sufficient   afford recipients a reasonable opportunity to comply with requirements
Case Management        and avoid termination. States had to provide certain activities and services
Services Also          to recipients consistent with JOBS requirements. If states failed to meet this
                       obligation, they could not terminate a family’s benefits. To meet increased
Challenged States      demand for activities and services under their new programs, all three
                       states opened or expanded job centers to help in job search activities,
                       created new partnerships with employers to provide placements, and
                       increased funds for child care. Despite such efforts, however, both welfare
                       advocates and state officials raised concerns that workers were not
                       adequately trained in case management and that large caseloads and
                       complex new program rules prevented workers from paying enough
                       attention to individual cases to ensure that recipients, many with barriers
                       to employability, were assigned appropriate work requirements and
                       provided sufficient support services.

                       In Iowa, for example, JOBS workers were to develop an individualized
                       Family Investment Agreement with each recipient. In most terminated
                       cases, however, recipients failed to come in and sign the agreement, and
                       workers had minimal contact with these recipients. For recipients who did
                       sign agreements, the prescribed activity in many cases was “individual job
                       search,” according to our case file review. Recipients had to make four
                       face-to-face job contacts per day and were recommended for sanction if
                       they did not do so. State reviewers concluded that not enough casework
                       had been done in 50 percent of these cases to determine whether the
                       recipient knew about the proposed action and its consequences and
                       whether the barriers to the recipient’s participation had been adequately
                       addressed. As a result, the program required caseworkers to provide more
                       case management services before relegating cases to the Limited Benefit
                       Plan leading to benefit termination. In addition, Iowa had established a
                       special program to provide intensive case management services to families
                       identified with many or severe barriers to employment. However, funding
                       allowed less than 3 percent of the state’s caseload to participate in this
                       program, and insufficient contact with recipients hindered caseworkers’
                       ability to identify candidates for referral.

                       Massachusetts tried to implement a subsidized job program in which the
                       value of a recipient’s AFDC and food stamp grants was paid as subsidized
                       wages from a private employer rather than provided directly to the
                       recipient as benefits. The state, however, found it difficult to effectively fill
                       job placements created through such partnerships. Up to 2,000 slots had




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Chapter 4
Termination Provisions Were Effective but
Posed Challenges




been authorized, but the state had placed fewer than 200 recipients in
positions at the time of our review.

Finding a good match between employers and recipients presented
problems, according to state officials. About 40 to 50 percent of recipients
had no high school diploma or equivalent, and placing recipients in jobs
required them to have job development and training. What a welfare
caseworker was expected to do had its limits, according to officials.
Welfare advocates criticized the state program, however, for terminating
benefits to families for noncompliance with work requirements without
providing recipients specific, available placements. As in Iowa, many
Employment Development Plans simply called for “60 days of job search”
or “20 hours per week of work or community service.” In some cases, the
state terminated benefits after recipients had received referrals for
community service assignments where no positions were actually
available. After the state decided an appeal in a recipient’s favor in
August 1996 and the action to terminate voided for failure to offer a
specific job placement, the state provided guidance to workers
emphasizing the importance of securing a placement before sanctioning
recipients for noncompliance. As of December 1996, 121 appeals regarding
work requirements and Employment Development Plans had been decided
or withdrawn in the recipients’ favor.

In addition, some raised concerns about caseworkers’ ability to identify
needs and inform families of available services. Welfare advocates cited
examples of families being allowed child care assistance only when other
family members were not available to provide free care, contrary to
program policy. Records show that 25 appeals regarding denials of child
care services were later decided or withdrawn in the recipients’ favor.

Wisconsin’s biggest implementation challenges occurred in Milwaukee,
where workers’ caseloads were the largest and, according to state
officials, the number of recipients with multiple barriers to employment
was disproportionately large.62 In 1996, Milwaukee County had 58 percent
of the state’s AFDC caseload but accounted for 44 percent of the 24,500 job
placements. Large caseloads made it difficult for caseworkers to pay
personal attention to each case to help recipients meet program
requirements and move toward self-sufficiency rather than terminate

62
  One reason Milwaukee’s caseworkers’ caseloads were the largest is because the county had a hiring
freeze due to uncertainty over its role in future program administration. As part of its 1997
implementation plan, other public and private agencies would be allowed to submit bids to administer
the program. Some of the JOBS programs had already been contracted to private organizations such as
Goodwill and the Young Men’s Christian Association.



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Termination Provisions Were Effective but
Posed Challenges




benefits for noncompliance. In addition to handling as many as 200 to 400
cases, caseworkers had to spend time learning new roles and
responsibilities and performing such tasks as tracking hours of
participation. Caseworkers had little time left to understand the particular
circumstances of each case and identify services recipients might need to
comply with program requirements and avoid termination.

In all three states, officials acknowledged the challenges inherent in the
culture shift required of their caseworkers—from determining eligibility to
emphasizing work,63 the difficulty of learning and accurately applying
complex new program rules, and of handling a large number of cases.
Nevertheless, state officials maintained that the guiding principle of their
waiver programs—consistent with the new federal reform law—was that it
is ultimately the recipient’s responsibility to either comply with program
requirements, inform their caseworkers of any barrier to employment or
service need, provide good cause reason for noncompliance, or have their
benefits terminated.




63
 For more discussion of these changes, see Welfare Waivers Implementation: States Work to Change
Welfare Culture, Community Involvement, and Service Delivery (GAO/HEHS-96-105, July 2, 1996).



Page 55                                         GAO/HEHS-97-74 Welfare Benefit Termination
Chapter 5

Conclusions and Comments From the States


              States’ early experiences with benefit termination provisions reveal that
Conclusions   such provisions have seldom been used. Nevertheless, state officials we
              spoke with consider these provisions successful in discouraging those
              with other adequate means of support from receiving benefits and
              encouraging those on welfare to comply with requirements so that they
              might move toward self-sufficiency. Although our analysis yielded little
              information on implementing time-limit provisions, it provided several
              insights for states implementing full-family sanction provisions under the
              new federal welfare reform law.

              First, states will probably experience relatively low percentages of cases
              terminated for noncompliance with program requirements as compared
              with their total caseloads. Although the states we studied in detail were
              chosen for their relatively large numbers of terminations, these states still
              terminated on average about 1 percent or less of their monthly caseloads.

              Second, depending on program structure, states will probably have a
              relatively higher proportion of terminations due to noncompliance with
              enrollment and other nonwork requirements when initially converting
              their existing caseloads to their new programs. Once programs are fully
              implemented, the proportion of such terminations will most likely
              decrease, while the proportion of terminations due to failure to comply
              with work requirements and, eventually, that due to reaching a time limit,
              will most likely increase.

              Third, states will probably see a significant percentage of families whose
              benefits are terminated for failure to comply with requirements return to
              welfare. In the three states we studied, about one-third did so. In most
              cases, families returning to welfare demonstrated compliance with
              program requirements or provided a basis for exemption. Although the
              federal 5-year lifetime limit on benefit receipt will probably affect
              decisions to return to welfare, its impact is not yet known.

              Fourth, states will probably see significant reductions in the number of
              families continuing to receive food stamps and Medicaid after AFDC
              benefits are terminated. Many families do not take the steps necessary to
              maintain food stamp and Medicaid benefits after losing AFDC, even though
              they may continue to be eligible. Many families not returning to welfare,
              however, do have some sources of support according to data from federal
              and state programs—and most likely, additional families have support they
              have not reported.




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                    Chapter 5
                    Conclusions and Comments From the States




                    Fifth, states will probably face challenges in establishing reliable tracking
                    and notification systems and ensuring that families get adequate case
                    management and support services to meet program requirements and
                    avoid having benefits terminated.

                    Our analysis yielded little information on implementing time-limit
                    provisions. Only one state, Florida, had terminated benefits due to
                    reaching a time limit through December 1996. Of the 74 Florida families
                    losing benefits, those who complied with program requirements and were
                    not already employed upon reaching their time limit received job offers
                    from the state (which all declined); those who failed to comply were not
                    offered jobs. Once a family reaches the new federal 5-year lifetime time
                    limit, compliance with program requirements neither secures more time
                    on welfare nor a job guarantee. To protect those experiencing genuine and
                    intractable hardship, the law allows up to 20 percent of a states’ caseload
                    to be exempt from the time limit. Under waivers, however, states generally
                    excluded more than 20 percent of their caseloads from coverage. The
                    number of families who will ultimately reach the new federal 5-year
                    lifetime time limit under TANF is unclear. Also unclear is whether states
                    will devise other programs for addressing the needs of these hard-to-serve
                    families.


                    We obtained comments on a draft of this report from our three case study
Comments From the   states: Iowa, Massachusetts, and Wisconsin. The states generally agreed
States              with the report’s findings and provided technical clarifications about their
                    programs and data interpretation. We incorporated their comments in the
                    report as appropriate. We requested but did not receive comments from
                    HHS.




                    Page 57                                    GAO/HEHS-97-74 Welfare Benefit Termination
Appendix I

Scope and Methodology


             This appendix details our methodology, including information about our
             AFDC case selection process and databases used in determining (1) the
             number and characteristics of families with benefits terminated in Iowa,
             Massachusetts, and Wisconsin; (2) the number of cases later reopened;
             and (3) the number of cases with other reported income and benefits.

             We obtained data on all cases terminated in Iowa through the Limited
             Benefit Plan from April through June 1996, a total of 408 cases. The data
             included cases assigned to the Limited Benefit Plan for failure to sign a
             Family Investment Agreement and for failure to fulfill such agreements. To
             determine benefits and reported income after termination, we obtained
             data for the month of August 1996. At the time of our analysis, none of the
             terminated cases had been reopened. (Under Iowa’s waiver, states could
             not reopen terminated cases for 6 months, and 4 months or less had
             elapsed when we obtained post-termination data.)

             We obtained data on all cases terminated and in closed status in
             Massachusetts for failure to meet work, school attendance, or teen living
             arrangement requirements as of the end of June 1996, a total of 1,292
             cases. We included in our analysis all cases closed for failure of parents
             (including teen parents) and caretakers to comply with these
             requirements, a total of 936 cases.64 We obtained data for these cases as of
             the end of September 1996 to determine the number of cases reopened as
             well as benefits and reported income for the 636 cases remaining closed.

             We obtained data on all cases terminated in Wisconsin in May 1996 for
             failure to enroll in the JOBS program and all cases closed in July and August
             for failure to meet work requirements under the program for 3 consecutive
             previous months (March through May or April through June), a total of 759
             cases. We obtained October 1996 data to determine the number cases
             reopened as well as benefits and reported income for the 651 cases
             remaining closed.

             For cases chosen, we analyzed and matched data from electronic
             databases provided to us by the states, as well as from the following
             federal databases: HUD’s Multifamily Tenant Characteristics System and
             Tenant Rental Assistance Certification System and the Social Security
             Administration’s SSI database. State databases matched included AFDC,
             food stamps, Medicaid, child support enforcement, and child protective



             64
               We did not include in our analysis the 356 cases closed for failure of dependent children aged 16 to 18
             to comply with work or school attendance requirements.



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Appendix I
Scope and Methodology




services.65 To determine what benefits families had received before
termination, we obtained data for the month preceding termination.
Although we did not independently evaluate the overall validity of the
databases received from other federal and state programs, we consulted
with state database and program staff to correct discrepancies in the data,
and we reviewed case files for a sample of cases from Des Moines, Boston,
and Milwaukee.

For benefits and income matches, we obtained data not only for AFDC
recipients, but also for household members not in the AFDC assistance unit
who might have been receiving housing, SSI, or food stamp benefits or who
might have reported income from wages, pensions, or child support. For
most matches, we used heads’ of household and individual household
members’ Social Security numbers. For state database matches, we also
used state identification or case numbers.

We did our review between April 1996 and April 1997 in accordance with
generally accepted government auditing standards.




65
  We determined that data obtained from child protective services on substantiated reports of abuse or
neglect and foster care placements for terminated cases were too limited and inconclusive to include
in the report.



Page 59                                            GAO/HEHS-97-74 Welfare Benefit Termination
Appendix II

Overview of States Terminating Benefits
Under Waivers as of December 31, 1996


                                                                   AFDC caseload in
                                                                              covered
                                 Date waiver                       jurisdictions as of
               State            implemented     Coveragea               June 30, 1996
               Arizona                 11/95    Statewide                      61,538




               Connecticut              1/96    Statewide                      56,017
               Delaware                10/95    Statewide                      10,253
               Florida                  2/94    Two countiesi                   9,083j
               Illinois                 1/96    Statewide                    221,632
               Iowa                    10/93    Statewide                      28,581
               Massachusetts           11/95    Statewide                      82,237

               Michigan                 4/95    Statewide                    174,176

               Mississippi             10/95    Six countiesk                  11,697
               Missouri                 6/95    Statewide                      80,426

               Nebraska                10/95    Five countiesl                  2,423
               North Carolina           7/96    Statewide                    110,451



               Ohio                     7/96    Statewide                    203,442




               Oregon                   7/96    Statewide                      31,851
               South Dakota             5/94    Statewide                       5,891
                                                          p
               Utah                    11/95    Pilot sites                    14,320
                                        7/96    statewide
               Vermont                  7/94    Statewide                       8,965
               Virginia                 7/95    Statewide                      63,399




               Wisconsin                3/96    Statewide                      52,765

               Total



               Page 60                     GAO/HEHS-97-74 Welfare Benefit Termination
                                      Appendix II
                                      Overview of States Terminating Benefits
                                      Under Waivers as of December 31, 1996




                                                                                     Number of cases terminatedc
Cities covered with                                                          As of June 30,   As of June 30,
populations over      Population in   Basis for              Month first              1996,   1996, in urban As of Dec. 31,
150,000b                     1994b    termination      terminated cases         statewided            areasd 1996, statewide
Glendale                   168,000    Sanction                     11/95                66e                f
                                                                                                                         50e
Mesa                       314,000
Phoenix                  1,049,000
Scottsdale                 152,000
Tucson                     435,000
                                  g
None                                  Sanction                       6/96               11h                g
                                                                                                                        477h
                                  g                                                                        g
None                                  Sanction                     10/96                 0                               68
     i                            g                                                                        g
None                                  Time limit                     4/96               19                               74
                                                                                                           g
Chicago                  2,732,000    Sanction                       7/96                0                                8
                                                                                                           f
Des Moines                 194,000    Sanction                     10/94             4,174                            5,288
Boston                     548,000    Sanction                     11/95             1,292              258           1,969
Worcester                  165,000                                                                       50
Detroit                    992,000    Sanction                       4/96              307               56             765
Grand Rapids               190,000                                                                       58
Jackson                    193,000    Sanction                     11/95               279              118             699
                                                                                                           f
Kansas City                444,000    Sanction                       6/95               73                              279
St. Louis                  368,000
Lincoln                    203,000    Sanction                       3/96                8                5              59
                                                                                                           g               m
Charlotte                  438,000    Sanction                       7/96                0
Greensboro                 196,000
Raleigh                    237,000
Winston-Salem              155,000
Akron                      222,000    Sanction                     10/96n                0                 g               m

Cincinnati                 358,000
Cleveland                  493,000
Columbus                   636,000
Dayton                     179,000
Toledo                     323,000
Portland                   451,000    Sanction                       9/96n               0                 g
                                                                                                                         60o
                                  g                                                                        g
None                                  Sanction                       5/94              289                              413
Part of Salt Lake          172,000    Sanction                     12/95                62               26             180
Cityp
                                  g                                                                        g
None                                  Sanction                       1/96                3                                3
Arlington                  175,000    Sanction                       7/95              985               20            1955
Chesapeake                 181,000                                                                       13
Newport News               179,000                                                                       27
Norfolk                    241,000                                                                       43
Richmond                   201,000                                                                       19
Virginia Beach             430,000                                                                       11
Madison                    195,000    Sanction                       4/96            2,208               84           5,700
Milwaukee                  617,000                                                                    1,020
                                                                                     9,776                           18,047



                                      Page 61                                     GAO/HEHS-97-74 Welfare Benefit Termination
Appendix II
Overview of States Terminating Benefits
Under Waivers as of December 31, 1996




a
 States implementing programs statewide generally phased in implementation over periods
lasting up to a year.
b
 Based on 1994 data from the U.S. Bureau of the Census, as published in table no. 46 in
Statistical Abstract of the United States - 1996.
c
 Includes cases terminated in states implementing benefit termination waiver provisions before
passage of the new federal welfare reform law in August 1996. In some states, such as
Massachusetts and Wisconsin, data represent cases in terminated status as of the date shown. In
other states, such as Iowa and Connecticut, data represent cumulative totals that may include
cases that have subsequently been reopened and may double count some cases.
d
    Data requested as of June 30, 1996, but data provided were from June 15, 1996, to July 2, 1996.
e
 According to the official surveyed, the most significant reason for the drop in terminations over
time is that many teen parents become old enough to no longer have to meet living arrangement
requirements.
f
    Breakdown for urban area(s) not available.
g
    Not applicable.
h
 Data do not include those cases terminated for failure to comply with teen living arrangement
requirements (not tracked).
i
 The two Florida counties covered were Alachua and Escambia. As of June 1996, seven
additional counties were participating, but no families in these counties could reach their time
limits as of Dec. 31, 1996.
j
Cohort entering program through June 1994 that could possibly reach a time limit as of
June 1996 comprised 353 cases. Cohort entering program through Dec. 1994 that could possibly
reach a time limit as of Dec. 1996 comprised 1,442 cases.
k
The six Mississippi counties covered included Adams, Harrison, Jones, Lee, Hinds, and
Washington.
l
    The five Nebraska counties included Adams, Clay, Lancaster, Nuckolls, and Webster.
m
 Entire families’ benefits had been terminated, but data system did not track and no estimate
could be provided, according to officials surveyed.
n
    The first month a family’s benefits could be terminated after waiver was implemented.
o
    Terminations as of Nov. 15, 1996. Data as of Dec. 31, 1996, were not available.
p
 The pilot sites in Utah included Kearns office (covering part of Salt Lake City), St. George,
Roosevelt, Kanab (Kane County), Cedar City, Beaver, Panguitch, American Fork, and Brigham
City.




Page 62                                              GAO/HEHS-97-74 Welfare Benefit Termination
Appendix III

Full-Family Sanction Provisions in State
Welfare Waivers Approved Between January
1987 and August 1996

Waiver program           Basis for full-family sanction (for cases without
(approval date)          good cause for noncompliance)                          Sanction provisions
ARIZONA
Employing and Moving     Teen living arrangement: Failure of minor parents to Termination of family’s eligibility for AFDC.
People Off Welfare and   live in an adult-supervised setting.
Encouraging
Responsibility (5/95)
CONNECTICUT
A Fair Chance (9/94)     Work: After 24 cumulative months of AFDC receipt,      Assistance unit is ineligible for an AFDC payment.
                         failure to comply with activities required by          Case can be reinstated through compliance.
                         employability plans.
                         Work: Voluntarily quitting a job after 24 months of    Assistance unit is ineligible for AFDC cash
                         AFDC receipt under Pathways.                           assistance for 3 months.
Reach for Jobs First     1. Work: Not cooperating with JOBS requirements;       First sanction: AFDC benefit reduced 20 percent for
(12/95)                  quitting a job.                                        3 months. Second sanction: AFDC benefit reduced
                         2. Child support: Not cooperating with child support   35 percent for 6 months. Third and subsequent
                         enforcement requirements.                              sanctions: No AFDC benefit paid for 3 months.
                         3. Other: Not cooperating with quality control
                         programs.
                         Teen living arrangement: Failure of minor parents to Termination of family’s eligibility for AFDC.
                         live in a supervised setting.
                         Enrollment: Failure to complete redetermination of     AFDC benefit terminated for failure to complete
                         eligibility.                                           6-month redetermination. AFDC, food stamp, and
                                                                                Medicaid benefits terminated for failure to complete
                                                                                other redeterminations. Families may reapply for
                                                                                benefits at any time.
DELAWARE
A Better Chance (5/95)   1. Enrollment: Not cooperating in developing of        First sanction: One-third reduction in AFDC benefit
                         Contract of Mutual Responsibility.                     until compliance. Second sanction: Two-thirds
                         2. Work: Not cooperating with employment-related       reduction in AFDC benefit until compliance. Third
                         provisions of contract.                                sanction: Termination of AFDC benefit for duration
                                                                                of demonstration.
                         Other: Failure to comply with                          AFDC benefit initially reduced by $50. Reduction
                         nonemployment-related requirements of Contract of      increases by $50 every month until compliance with
                         Mutual Responsibility, such as immunizing children     requirements if the state finds that adult has not
                         and attending parenting classes.                       taken reasonable steps to fulfill the requirement.
                         Child support: Failure to comply with child support    AFDC benefit terminated until compliance.
                         enforcement requirements.
                         Teen living arrangement: Failure of minor parents to Termination of family’s eligibility for AFDC.
                         live in adult-supervised setting.
Amendments to A Better   1. Enrollment: Not cooperating in developing           AFDC benefit initially reduced by $50. Reduction
Chance (12/95)           Contract of Mutual Responsibility.                     increases by $50 every month until compliance with
                         2. Other: Failure to comply with                       requirements.
                         nonemployment-related requirements of contract,
                         such as immunizing children and attending
                         parenting classes.
                                                                                                                              (continued)




                                           Page 63                                       GAO/HEHS-97-74 Welfare Benefit Termination
                                             Appendix III
                                             Full-Family Sanction Provisions in State
                                             Welfare Waivers Approved Between January
                                             1987 and August 1996




Waiver program             Basis for full-family sanction (for cases without
(approval date)            good cause for noncompliance)                          Sanction provisions
                           1. Work: Not cooperating with employment-related       First sanction: One-third reduction in AFDC benefit
                           provisions of Contract of Mutual Responsibility.       for 3 months or until compliance, whichever is
                           2. Other: Failure of dependent children under age      sooner. Second sanction: Two-thirds reduction in
                           16 to comply with school attendance requirements.      AFDC benefit for 3 months or until compliance,
                                                                                  whichever is sooner. Third sanction: Termination of
                                                                                  AFDC benefit for duration of demonstration.
                                                                                  Sanctions for failure to meet school attendance
                                                                                  requirements will not be imposed if parent or
                                                                                  caretaker is working with school officials or other
                                                                                  agencies to remedy situation.
                           Child support: Failure to comply with child support    AFDC benefit terminated until compliance.
                           enforcement requirements.
                           Teen living arrangement: Failure of minor parents to Termination of family’s eligibility for AFDC.
                           live in adult-supervised setting.
DISTRICT OF COLUMBIA
Project on Work,           Teen living arrangement: Failure of unmarried minor Termination of family’s eligibility for AFDC.
Employment, and            parents or pregnant minors to live in
Responsibility (8/96)a     adult-supervised setting.
IDAHO
Temporary Assistance for   Work: Being fired from a job, quitting a job, or       Family is ineligible for AFDC benefits for 90 days or
Families in Idaho (8/96)   turning down a job offer that would provide income     until compliance. Eligibility for the family may be
                           equal to or greater than the AFDC benefit.             reestablished during the sanction period if the adult
                                                                                  secures new employment comparable in gross
                                                                                  wages to the job he or she quit, becomes exempt
                                                                                  from the work requirements, or the adult who
                                                                                  caused the sanction leaves the family.
                           Work: Failure to participate in work or JOBS           First sanction: Entire family’s needs removed in
                           activities.                                            determining the amount of AFDC benefits for 1
                                                                                  month or until compliance, whichever is longer.
                                                                                  Second sanction: Entire family’s needs removed in
                                                                                  determining the amount of AFDC benefits for 3
                                                                                  months or until compliance, whichever is longer.
                                                                                  Third sanction: Entire family’s needs removed in
                                                                                  determining the amount of AFDC benefits until the
                                                                                  end of the demonstration.
                           Teen living arrangement: Failure of minor,             Termination of family’s eligibility for AFDC.
                           unmarried parents or minors who are pregnant to
                           live in adult-supervised setting.
ILLINOIS
Work and Responsibility    Work: Not cooperating with Targeted Work Initiative    Sanctions for first three instances of noncooperation
(9/95)                     requirements, such as participation in job search      are in accord with JOBS policy for noncooperation.
                           and subsidized work positions; not cooperating with    Sanction for fourth and subsequent instances of
                           Get a Job Initiative requirements, such as             noncooperation is loss of entire AFDC benefit for 6
                           participation in job search, community work            months or until individual complies, whichever is
                           experience, and short-term training.                   longer.
                           Work: Failure to accept a full-time or part-time job   Termination of family’s AFDC benefit for 3 months or
                           offer.                                                 until individual complies, whichever is sooner.
                                                                                                                                  (continued)




                                             Page 64                                       GAO/HEHS-97-74 Welfare Benefit Termination
                                               Appendix III
                                               Full-Family Sanction Provisions in State
                                               Welfare Waivers Approved Between January
                                               1987 and August 1996




Waiver program              Basis for full-family sanction (for cases without
(approval date)             good cause for noncompliance)                          Sanction provisions
                            Enrollment: Failure to cooperate in developing and     Termination or denial of AFDC cash benefits for the
                            signing a self-sufficiency plan within 30 days of      entire family until compliance.
                            application or redetermination.
INDIANA
Amendments to Indiana  Work: Failure to register for work with local               Termination of family’s AFDC benefits until
Manpower Placement and employment and training office.                             compliance.
Comprehensive Training
Program (8/96)
                            Teen living arrangement: Failure of minor parents      Termination of family’s eligibility for AFDC.
                            and their children to live in an adult-supervised
                            setting.
IOWA
Family Investment           1. Enrollment: Failure to enter into a Family          Family is placed in the Limited Benefit Plan: For 3
Program (8/93)              Investment Agreement.                                  months, the family is eligible for full benefits,
                                                                                   followed by a 3-month benefit period reflecting the
                                                                                   needs of the children only. At the end of this period,
                                                                                   the AFDC grant is terminated and the family is not
                                                                                   eligible to apply for assistance for 6 months. During
                                                                                   the Limited Benefit Plan, the state will review the
                                                                                   well-being of the children. Before termination,
                                                                                   participants are allowed to develop a Family
                                                                                   Investment Agreement and leave the Limited
                                                                                   Benefit Plan.
                            1. Work: Failure to comply with terms of the Family    Family is placed in the Limited Benefit Plan: For 3
                            Investment Agreement.                                  months, the family is eligible for full benefits,
                            2. Teen school attendance: Failure to comply with      followed by a 3-month benefit period reflecting the
                            terms of the Family Investment Agreement.              needs of the children only. At the end of this period,
                                                                                   the AFDC grant is terminated and the family is not
                                                                                   eligible to apply for assistance for 6 months. During
                                                                                   the Limited Benefit Plan, the state will review the
                                                                                   well-being of the children. Participants have no
                                                                                   reconsideration rights, that is, they are not allowed
                                                                                   to redevelop a Family Investment Agreement and
                                                                                   leave the Limited Benefit Plan.
Amendments to Family      Enrollment: Failure to enter into a Family Investment Family is placed in the Limited Benefit Plan: For 3
Investment Program (2/95) Agreement.                                            months, adults’ needs are removed in calculating
                                                                                AFDC benefit, followed by 6 months of AFDC
                                                                                ineligibility for the family. During the Limited Benefit
                                                                                Plan, the state will review the well-being of the
                                                                                children. At any time in the first 3 months of the
                                                                                Limited Benefit Plan, participants are allowed to
                                                                                develop a Family Investment Agreement and leave
                                                                                the Limited Benefit Plan. If a participant enters the
                                                                                Limited Benefit Plan for a second or subsequent
                                                                                time, the family will be immediately ineligible for
                                                                                AFDC for 6 months with no 3-month period of
                                                                                reduced benefits.
                                                                                                                                   (continued)




                                               Page 65                                      GAO/HEHS-97-74 Welfare Benefit Termination
                                               Appendix III
                                               Full-Family Sanction Provisions in State
                                               Welfare Waivers Approved Between January
                                               1987 and August 1996




Waiver program              Basis for full-family sanction (for cases without
(approval date)             good cause for noncompliance)                          Sanction provisions
                            1. Work: Failure to comply with the terms of the       Family is placed in the Limited Benefit Plan: For 3
                            Family Investment Agreement.                           months, adults’ needs are removed in calculating
                            2. Teen school attendance: Failure to comply with      AFDC benefit, followed by 6 months of AFDC
                            terms of the Family Investment Agreement.              ineligibility for the family. During the Limited Benefit
                                                                                   Plan, the state will review the well-being of the
                                                                                   children. Participants have no reconsideration
                                                                                   rights, that is, they are not allowed to redevelop a
                                                                                   Family Investment Agreement and leave the Limited
                                                                                   Benefit Plan. If a participant enters the Limited
                                                                                   Benefit Plan for a second or subsequent time, the
                                                                                   family will be immediately ineligible for AFDC for 6
                                                                                   months with no 3-month period of reduced benefits.
                            Teen living arrangement: Failure of minor parents to Termination of family’s eligibility for AFDC.
                            live in adult-supervised setting.
KANSAS
Kansas Actively Creating    Work: Failure to attend a job interview if referred,   If the noncomplying individual is a parent or
Tomorrow for Families       failure to accept a bona fide offer of suitable        spouse, the family will not receive AFDC cash
(8/96)                      employment, or termination of employment.              benefits for 3 months for each occurrence or until
                                                                                   compliance.
                            Work: Failure to comply with JOBS requirements,        The needs of a noncomplying parent or spouse are
                            including participation in substance abuse             not taken into account in determining the amount of
                            screening and treatment when deemed necessary.         AFDC cash benefits for up to 2 months. If individual
                                                                                   is not cooperating after 2 months, family’s AFDC
                                                                                   cash benefits are eliminated for 2 months with no
                                                                                   cure. If individual is not cooperating after this
                                                                                   additional 2-month period, family’s AFDC cash
                                                                                   benefits continue to be eliminated until individual
                                                                                   cooperates.
                            Child support: Failure to cooperate with child         The needs of the caretaker are not taken into
                            support enforcement requirements.                      account in determining the amount of AFDC cash
                                                                                   benefits for 2 months. If the individual is still not
                                                                                   cooperating after 2 months, the family’s AFDC cash
                                                                                   benefits are eliminated until compliance.
LOUISIANA
Individual Responsibility   Work: Failure to accept a full-time job offer.         The family’s eligibility for AFDC benefits is
Project (2/96)                                                                     terminated for a mandatory 3-month period, after
                                                                                   which the sanction ends.
MAINE
Welfare to Work (6/96)      Teen living arrangement: Failure of unmarried minor Termination of family’s eligibility for AFDC.
                            parents or married minor parents not living with their
                            spouses to live in an adult-supervised setting.
MARYLAND
Family Investment           1. Work: Failure to participate in job search.         Termination of family’s eligibility for AFDC.
Program (8/95)              2. Teen living arrangement: Failure of unmarried
                            minor parents to live in adult-supervised setting.
                                                                                                                                   (continued)




                                               Page 66                                      GAO/HEHS-97-74 Welfare Benefit Termination
                                              Appendix III
                                              Full-Family Sanction Provisions in State
                                              Welfare Waivers Approved Between January
                                              1987 and August 1996




Waiver program              Basis for full-family sanction (for cases without
(approval date)             good cause for noncompliance)                          Sanction provisions
                            Work: Failure to comply with requirements of JOBS      Removal of the noncooperating individual from the
                            program.                                               grant. This sanction remains as long as the
                                                                                   cumulative months of sanction for noncooperation
                                                                                   do not exceed 6 months. The sanction for
                                                                                   noncooperation after the sanctions have been
                                                                                   imposed for 6 cumulative months is case closure.
                                                                                   Once the case has been closed, the family may
                                                                                   reapply for AFDC and will be reinstated after
                                                                                   cooperation with JOBS requirements for 30 days.
                                                                                   Families whose cases have been closed may
                                                                                   receive up to 3 months of transitional noncash
                                                                                   assistance.
Amendments to Family      Work: Failure to participate in job search.              Case is closed.
Investment Program (8/96)
                            Work: Failure to comply with requirements of the       Case is closed. The family may reapply for AFDC
                            JOBS program.                                          and be reinstated immediately upon compliance
                                                                                   with JOBS requirements in the first instance of
                                                                                   noncompliance, after 10 days of compliance in the
                                                                                   second instance, and after 30 days of compliance
                                                                                   in the third and subsequent instances. Families
                                                                                   whose cases have been closed may receive up to 3
                                                                                   months of transitional noncash assistance.
                            Child support: Failure to cooperate with child         Case is closed. Once the case has been closed,
                            support enforcement requirements.                      the family may reapply for AFDC and will be
                                                                                   reinstated immediately upon compliance.
                            Other: Commission of fraud by a member of the          The entire family is ineligible for cash assistance.
                            assistance unit.                                       The sanction period for the first conviction is 6
                                                                                   months or until full restitution is made, whichever is
                                                                                   less; for the second conviction, 12 months or until
                                                                                   full restitution is made, whichever is less; and for the
                                                                                   third conviction, the sanction is permanent.
MASSACHUSETTS
Welfare Reform ’95 (10/95) Work: Failure to comply with requirements of            Initial instance of noncompliance results in a
                           Employment Development Program, including               warning. If noncompliance continues, participant is
                           participation in specified JOBS components.             required to participate in community service.
                                                                                   Sanction for failure to participate in community
                                                                                   service is reduction of AFDC benefit by portion of
                                                                                   benefit attributable to participant. Sanction for
                                                                                   subsequent instances of noncompliance is
                                                                                   termination of AFDC benefit until participant
                                                                                   complies.
                            Work: Failure of participants in the Full Employment   Participants may be required to participate in
                            Program to maintain a job after at least three         community service. Sanction for failure to
                            attempts.                                              participate in community service is reduction of
                                                                                   AFDC benefit by portion of benefit attributable to
                                                                                   participant. Sanction for subsequent instances of
                                                                                   noncompliance is termination of AFDC benefit until
                                                                                   participant complies.
                                                                                                                                (continued)




                                              Page 67                                       GAO/HEHS-97-74 Welfare Benefit Termination
                                                Appendix III
                                                Full-Family Sanction Provisions in State
                                                Welfare Waivers Approved Between January
                                                1987 and August 1996




Waiver program               Basis for full-family sanction (for cases without
(approval date)              good cause for noncompliance)                            Sanction provisions
                             Work: Failure to participate in community service        First sanction: Reduction of AFDC benefit by portion
                             when required in the work program.                       of benefit attributable to participant. Second and
                                                                                      subsequent sanctions: Termination of AFDC benefit
                                                                                      until participant complies.
                             Teen school attendance: Failure of teen parents to       First sanction: AFDC benefit reduced by teen
                             attend at least 75 percent of assigned educational       parent’s portion of benefit. If noncompliance
                             activities in any month.                                 continues for more than 30 days, and for any
                                                                                      subsequent instances of noncompliance, family
                                                                                      becomes ineligible for AFDC. Sanctions will be
                                                                                      removed if participant demonstrates compliance for
                                                                                      at least 2 consecutive weeks.
                             Teen living arrangement: Failure of teen parents to      Termination of family’s eligibility for AFDC.
                             live in adult-supervised setting.
MICHIGAN
Amendments to                Work: Failure to participate in job search; failure to   First sanction: AFDC benefit reduced by 25
Strengthen Michigan          meet JOBS program requirements.                          percent, and if no child in case is younger than age
Families (10/94)                                                                      6, food stamp benefit is also reduced by 25 percent
                                                                                      for 12 months or until individual complies,
                                                                                      whichever is sooner. Subsequent sanction: If
                                                                                      participant does not comply during the 12-month
                                                                                      period, the AFDC case is closed until the individual
                                                                                      complies and the food stamp sanction discontinued.
Amendments to                Teen living arrangement: Failure of minor parents       Termination of family’s eligibility for AFDC.
Strengthen Michigan          and their children to live in adult-supervised setting.
Families (6/96)
                             Teen school attendance: Failure of minor parents         Case is closed for at least 1 month.
                             who have not completed high school to attend
                             school.
                             Work: Failure to participate in job search; failure to   First sanction: AFDC benefit reduced by 25
                             meet JOBS program requirements.                          percent, and if no child in case is younger than age
                                                                                      6, food stamp benefit is also reduced by 25 percent
                                                                                      for 12 months or until individual complies,
                                                                                      whichever is sooner. Subsequent sanction: If
                                                                                      participant does not comply during the 12-month
                                                                                      period, the AFDC case is closed until the individual
                                                                                      complies and the food stamp sanction discontinued.
MINNESOTA
Work First (8/96)            Work: Failure to comply with community work              The entire family’s needs are removed in
                             experience program requirements.                         determining the amount of AFDC benefits for at
                                                                                      least 6 months.
MISSISSIPPI
Mississippi New Direction    Work: Refusal of a Work First job placement,             AFDC grant terminated until participant complies.
Demonstration Project        termination of a placement within a 2-week trial
(12/94)                      period or a pattern of accepting placement but
                             requesting early termination.
MISSOURI
Missouri Families Mutual     Teen living arrangement: Failure of minor parents to Termination of family’s eligibility for AFDC.
Responsibility Plan (4/95)   reside in an adult-supervised setting.
                                                                                                                                      (continued)


                                                Page 68                                        GAO/HEHS-97-74 Welfare Benefit Termination
                                              Appendix III
                                              Full-Family Sanction Provisions in State
                                              Welfare Waivers Approved Between January
                                              1987 and August 1996




Waiver program              Basis for full-family sanction (for cases without
(approval date)             good cause for noncompliance)                          Sanction provisions
NEBRASKA
Welfare Reform              Work: Continued failure to comply with terms of the    First sanction: AFDC cash benefit terminated for 1
Demonstration Project       self-sufficiency contract.                             month or until participant complies, whichever is
(2/95)                                                                             longer. Second sanction: AFDC cash benefit
                                                                                   terminated for 3 months or until participant
                                                                                   complies, whichever is longer. Third sanction:
                                                                                   AFDC cash benefit terminated for remainder of
                                                                                   demonstration or until 48-month time-limit benefit
                                                                                   period expires, whichever is sooner.
NEW HAMPSHIRE
Employment Program          Work: Failure to comply with JOBS requirements or      For the first occurrence of noncompliance, or for
(6/96)b                     work requirements or, within 60 days of application,   occurrences more than 6 months after the end of
                            being fired from a job, quitting a job, voluntarily    the most recent sanction period, the needs of the
                            reducing hours, or turning down a bona fide offer of   noncomplying participant are not taken into account
                            an unsubsidized job.                                   in calculating the AFDC benefit amount for one
                                                                                   payment period or until the failure to comply
                                                                                   ceases, whichever is longer. After 3 months of
                                                                                   continued noncompliance, the adjusted payment
                                                                                   standard (the payment standard with the needs of
                                                                                   the noncomplying participant removed) is reduced
                                                                                   by one-third for one payment period or until the
                                                                                   failure to comply ceases, whichever is longer. After
                                                                                   an additional 3 months of continued
                                                                                   noncompliance, the adjusted payment standard is
                                                                                   reduced by two-thirds for one payment period or
                                                                                   until the failure to comply ceases, whichever is
                                                                                   longer. After an additional 3 months of continued
                                                                                   noncompliance, the AFDC case is closed.
                            Enrollment: Failure to attend the employability        Termination of AFDC benefits.
                            assessment meeting.
NORTH CAROLINA
Work First Program (2/96)   Enrollment: Failure to sign the personal               Case is closed.
                            responsibility contract.
                                                                                                                             (continued)




                                              Page 69                                      GAO/HEHS-97-74 Welfare Benefit Termination
                                             Appendix III
                                             Full-Family Sanction Provisions in State
                                             Welfare Waivers Approved Between January
                                             1987 and August 1996




Waiver program             Basis for full-family sanction (for cases without
(approval date)            good cause for noncompliance)                       Sanction provisions
NORTH DAKOTA
Training, Education,      Enrollment: Failure to sign or cooperate in          Termination of the family’s Training, Education,
Employment, and           developing the social contract within 2 months of    Employment, and Management (TEEM) benefit—a
Management Project (9/95) eligibility.                                         cash payment constituting the family’s AFDC, food
                                                                               stamps, and Low-Income Home Energy Assistance
                                                                               Program (LIHEAP) benefit. Households may apply
                                                                               for food stamps and LIHEAP benefits under the
                                                                               regular programs. If a family whose TEEM benefit is
                                                                               terminated reapplies for assistance under TEEM
                                                                               within 10 months of the month of closure, the family
                                                                               would not be eligible for TEEM benefits until the
                                                                               social contract is signed. If a family whose case
                                                                               had been closed for failure to complete the social
                                                                               contract within the 2-month period reapplies for
                                                                               assistance under TEEM more than 10 months after
                                                                               the month of closure, the household, if found
                                                                               eligible under TEEM, will be allowed another
                                                                               2-month period to develop and sign the social
                                                                               contract.
                           1. Work: Failure to comply with self-sufficiency    The AFDC portion of the TEEM benefit has the
                           requirements of the social contract.                following sanctions: First sanction: The needs of the
                           2. Child support: Failure to comply with child      noncomplying individual are removed for a
                           support enforcement requirements.                   minimum of 1 month; if the individual fails to comply
                                                                               for 6 consecutive months, the entire AFDC portion
                                                                               of the TEEM benefit is terminated. Second sanction:
                                                                               The needs of the noncomplying individual are
                                                                               removed for at least 2 months; if the individual fails
                                                                               to comply for 3 consecutive months, the entire
                                                                               AFDC portion of the TEEM benefit is terminated.
                                                                               Third and subsequent sanctions: The needs of the
                                                                               noncomplying individual are removed for at least 3
                                                                               months; if the individual fails to comply for 3
                                                                               consecutive months, the entire AFDC portion of the
                                                                               TEEM benefit is terminated. AFDC eligibility can be
                                                                               reestablished when the individual complies with the
                                                                               original program requirement or an alternative
                                                                               approved activity.
OHIO
Ohio First (3/96)          Work: Failure to comply with JOBS requirements.     First sanction: The needs of the noncomplying
                                                                               individual are removed in calculating the AFDC
                                                                               benefit for the assistance unit for 1 month or until
                                                                               compliance, whichever is longer. Second sanction:
                                                                               No AFDC cash benefit is issued for the assistance
                                                                               unit for 1 month or until compliance, whichever is
                                                                               longer. Third sanction: No AFDC cash benefit is
                                                                               issued for the assistance unit for 2 months or until
                                                                               compliance, whichever is longer. Fourth and
                                                                               subsequent sanctions: No AFDC cash benefit is
                                                                               issued for the assistance unit for 6 months or until
                                                                               compliance, whichever is longer.
                                                                                                                           (continued)



                                             Page 70                                    GAO/HEHS-97-74 Welfare Benefit Termination
                                         Appendix III
                                         Full-Family Sanction Provisions in State
                                         Welfare Waivers Approved Between January
                                         1987 and August 1996




Waiver program         Basis for full-family sanction (for cases without
(approval date)        good cause for noncompliance)                         Sanction provisions
                       Work: Voluntary termination of employment.            AFDC ineligibility for the assistance unit for 6
                                                                             months.
                       Child support: Failure to cooperate with child        Caretaker relative’s needs are removed in
                       support enforcement requirements.                     calculating the AFDC benefit for the assistance unit.
                                                                             If the caretaker does not request to be added back
                                                                             to the assistance unit and does not cooperate with
                                                                             the requirements within 2 years of the date of being
                                                                             penalized for noncooperation, the AFDC cash
                                                                             benefit for the remaining assistance unit members
                                                                             is terminated. The caretaker relative may reapply for
                                                                             AFDC at any time. However, the assistance unit
                                                                             members will not be eligible to receive AFDC cash
                                                                             benefits until the caretaker relative cooperates with
                                                                             child support enforcement requirements.
                       Other: Refusal of pregnant recipients to cooperate    First sanction: Recipient is ineligible for AFDC cash
                       with substance abuse assessment or treatment.         benefits for 1 month or until compliance, whichever
                                                                             is longer. Second sanction: The entire assistance
                                                                             unit is ineligible for AFDC cash benefits for 1 month
                                                                             or until compliance, whichever is longer. Third
                                                                             sanction: The entire assistance unit is ineligible for
                                                                             AFDC cash benefits for 2 months or until
                                                                             compliance, whichever is longer. Fourth and
                                                                             subsequent sanctions: The entire assistance unit is
                                                                             ineligible for AFDC cash benefits for the longest of
                                                                             the following: 36 months, for the remainder of the
                                                                             recipient’s 60-month time period, or until
                                                                             compliance.
OREGON
Oregon Option (3/96)   1. Work: Failure to meet JOBS participation           For individuals who have not been previously
                       requirements.                                         sanctioned or have been sanctioned in only 1
                       2. Other: Failure to comply with mental health and    previous month, the first 2 months of
                       substance abuse diagnosis, counseling, and            noncompliance result in a $50 decrease in the
                       treatment requirements.                               grant. Individuals who have been sanctioned in 2 or
                                                                             3 previous months will be removed from the grant,
                                                                             except that cases including a work-eligible
                                                                             alien parent continue to be subject to a $50
                                                                             decrease in the grant for this sanction period. For
                                                                             individuals who have been sanctioned in 4 or more
                                                                             previous months, the sanction is the closure of the
                                                                             AFDC grant. All sanctions are removed, at any point
                                                                             in the sanction process, when an individual
                                                                             complies.
                       Teen living arrangement: Failure of minor parents to Termination of family’s eligibility for AFDC.
                       live with their parents or in another safe living
                       environment.
                                                                                                                            (continued)




                                         Page 71                                       GAO/HEHS-97-74 Welfare Benefit Termination
                                               Appendix III
                                               Full-Family Sanction Provisions in State
                                               Welfare Waivers Approved Between January
                                               1987 and August 1996




Waiver program               Basis for full-family sanction (for cases without
(approval date)              good cause for noncompliance)                          Sanction provisions
SOUTH CAROLINA
South Carolina               1. Enrollment: Failure to sign an Individual           First instance of noncompliance: The caretaker’s
Self-Sufficiency and         Self-Sufficiency Plan.                                 needs are removed from the calculation of the
Parental Responsibility      2. Work: Failure to comply with the work               AFDC benefit for a maximum of 30 days, curable at
Programc (1/95)              requirements of the plan.                              any time by compliance. If at the end of 30 days the
                                                                                    caretaker has not complied, he or she is notified
                                                                                    that at the end of the next 30 days, the whole family
                                                                                    will be removed from AFDC. During the second 30
                                                                                    days, the sanction can be removed at any time by
                                                                                    compliance. Second instance of noncompliance:
                                                                                    The family’s AFDC grant is terminated for at least 30
                                                                                    days. After 30 days, the sanction can be removed
                                                                                    at any time by compliance. Third instance of
                                                                                    noncompliance: The family’s AFDC grant is
                                                                                    terminated for at least 90 days, after which the
                                                                                    caretaker would be given the opportunity to comply.
                                                                                    At the end of 90 days, the sanction continues until
                                                                                    the caretaker complies. Fourth and subsequent
                                                                                    instances of noncompliance: The family’s AFDC
                                                                                    grant is terminated for at least 180 days, after which
                                                                                    the caretaker would be given the opportunity to
                                                                                    comply. At the end of 180 days, the sanction
                                                                                    continues until the caretaker complies.
Family Independence Act      1. Enrollment: Failure to comply with developing an    First instance of noncompliance: The caretaker’s
(5/96)                       Individual Self-Sufficiency Plan.                      needs are removed from calculation of the AFDC
                             2. Work: Failure to comply with the terms of the       benefit for 30 days, curable at any time by
                             plan; refusing an offer of employment.                 compliance. If at the end of 30 days the caretaker
                                                                                    has not complied, he or she is notified that at the
                                                                                    end of the next 30 days, the family’s AFDC grant will
                                                                                    be terminated, curable when the adult
                                                                                    demonstrates compliance for 30 days. Second and
                                                                                    successive instances of noncompliance: The
                                                                                    family’s AFDC grant is terminated, curable when the
                                                                                    adult demonstrates compliance for 30 days.
SOUTH DAKOTA
Strengthening South          Work: Voluntarily quitting a job of 20 hours or more   The family’s AFDC benefit is terminated for 3
Dakota Families Initiative   per week.                                              months or until the participant complies with the
(3/94)                                                                              requirement to find a job comparable to the one
                                                                                    quit, whichever is sooner.
                                                                                                                               (continued)




                                               Page 72                                       GAO/HEHS-97-74 Welfare Benefit Termination
                                           Appendix III
                                           Full-Family Sanction Provisions in State
                                           Welfare Waivers Approved Between January
                                           1987 and August 1996




Waiver program          Basis for full-family sanction (for cases without
(approval date)         good cause for noncompliance)                          Sanction provisions
TENNESSEE
Families First (7/96)   Work: Refusal or failure to participate in             First sanction: The assistance unit is ineligible for an
                        employment, training, or other work preparation        AFDC payment until compliance. Second and
                        activities.                                            subsequent sanctions: The assistance unit is
                                                                               ineligible for AFDC for 3 months or until compliance,
                                                                               whichever is longer. The state will take action to
                                                                               monitor and protect the safety and well-being of the
                                                                               children in families whose benefits are terminated. If
                                                                               the state certifies that AFDC assistance is needed
                                                                               to prevent a child’s loss of housing, heat, light, or
                                                                               water or to prevent removal of the child from the
                                                                               custody of a parent, a cash or vendor payment will
                                                                               be issued to meet the child’s needs.
                        Work: Voluntarily quitting a job.                      The assistance unit is ineligible for AFDC for 3
                                                                               months. AFDC eligibility may be reestablished
                                                                               during the disqualification period if the caretaker
                                                                               secures new comparable employment, becomes
                                                                               exempt from work requirements, or leaves the
                                                                               assistance unit. The state will take action to monitor
                                                                               and protect the safety and well-being of the
                                                                               children in families whose benefits are terminated. If
                                                                               the state certifies that AFDC assistance is needed
                                                                               to prevent a child’s loss of housing, heat, light, or
                                                                               water or to prevent removal of the child from the
                                                                               custody of a parent, a cash or vendor payment will
                                                                               be issued to meet the child’s needs.
                        1. Child support: Failure to comply with child         Ineligibility for the entire assistance unit until
                        support enforcement requirements.                      compliance.
                        2. Enrollment: Failure to sign a Personal
                        Responsibility Plan.
UTAH
Amendment to Single     1. Work: Failure to participate in JOBS or other       AFDC benefit is reduced by $100 per month until
Parent Employment       Single Parent Employment Demonstration activities.     individual complies. However, if individual is a child
Demonstration Project   2. Child support: Failure to cooperate with child      aged 16 to 18 who is not in school or working full
(8/95)                  support enforcement requirements.                      time, the needs of the child will instead be removed
                                                                               from the grant calculation until the individual
                                                                               complies. In instances where the $100 sanction has
                                                                               been applied for 2 months and nonparticipation
                                                                               continues, the case may be closed. The case will
                                                                               be reopened immediately upon compliance.
VERMONT
Welfare Restructuring   1. Work: Failure to participate in community service   AFDC benefits are issued in the form of vendor
Project (8/94)          jobs program; quitting, failing to accept, or being    payments for the assistance unit’s expenses for
                        fired from an unsubsidized job; or failure to          housing, food, fuel, and other utilities, and any
                        participate in required job search.                    undisbursed balance is issued to the assistance
                        2. Teen school attendance: Failure of pregnant or      unit. Failure to comply with any of the requirements
                        parenting minors to attend school or participate in    under the penalty, such as monthly reporting on the
                        an alternative education or training activity.         individual’s circumstances, results in termination of
                                                                               all AFDC benefits until the individual complies with
                                                                               work requirements for 2 weeks.
                                                                                                                               (continued)


                                           Page 73                                       GAO/HEHS-97-74 Welfare Benefit Termination
                                               Appendix III
                                               Full-Family Sanction Provisions in State
                                               Welfare Waivers Approved Between January
                                               1987 and August 1996




Waiver program              Basis for full-family sanction (for cases without
(approval date)             good cause for noncompliance)                         Sanction provisions
                            Teen living arrangement: Failure of pregnant or     Termination of family’s eligibility for AFDC.
                            parenting minors who are not living in a supervised
                            setting to attend meetings with caseworkers on 3
                            separate days each month, at least 1 of which must
                            take place at teen’s place of residence.
VIRGINIA
Virginia Independence       Enrollment: Refusing to sign an agreement of          AFDC cash benefit terminated for entire case until
Program (11/93)             personal responsibility.                              case head of household complies.
                            Teen living arrangement: Failure of minor parents to Termination of family’s eligibility for AFDC.
                            live in adult-supervised setting.
                            Work: Failure to participate in required work         First sanction: AFDC cash benefit terminated for 1
                            program activities.                                   month, or until compliance, whichever is longer.
                                                                                  Second sanction: AFDC cash benefit terminated for
                                                                                  3 months, or until compliance, whichever is longer.
                                                                                  Third and subsequent sanctions: AFDC cash
                                                                                  benefit terminated for 6 months, or until compliance,
                                                                                  whichever is longer.
                            Child support: Failure to cooperate with efforts to   AFDC cash benefit terminated for at least 1 month
                            establish paternity.                                  and until caretaker relative cooperates with
                                                                                  paternity establishment.
WEST VIRGINIA
Joint Opportunities for     Work: Failure of a nonexempt adult in             First sanction: Adult’s needs are removed in
Independence (8/95)         AFDC-Unemployed Parent case to participate in the determining the amount of the AFDC cash benefit
                            alternate work experience program.                for 3 months or until the failure to comply ceases,
                                                                              whichever is longer. Second sanction: The AFDC
                                                                              cash benefit is terminated for 6 months or until the
                                                                              failure to comply ceases, whichever is longer. The
                                                                              AFDC cash benefit is reinstated upon successful
                                                                              participation in the alternate work experience
                                                                              program for 10 consecutive days.
WISCONSIN
Pay for Performance (8/95) Enrollment: Failure of active cases to enroll in the   Termination of a family’s eligibility for AFDC.
                           JOBS program as assigned.
                            Work: Failure to complete assigned hours of JOBS      The AFDC grant is reduced by the hourly federal
                            activities.                                           minimum wage for each hour of assigned activity a
                                                                                  recipient fails to complete without good cause. The
                                                                                  food stamp allotment is reduced by the minimum
                                                                                  wage for each uncompleted hour of assigned JOBS
                                                                                  activity that has not been taken into account in
                                                                                  reducing the AFDC grant. If a recipient fails to
                                                                                  complete at least 25 percent of hours assigned to
                                                                                  JOBS activities, he or she receives no AFDC
                                                                                  payment and the food stamp payment is $10.
                                                                                  Parents responsible for the care of a child under 6
                                                                                  years of age do not have their food stamp allotment
                                                                                  reduced due to failure to complete their assigned
                                                                                  hours of JOBS activity.

                                                                                                                 (Table notes on next page)




                                               Page 74                                      GAO/HEHS-97-74 Welfare Benefit Termination
Appendix III
Full-Family Sanction Provisions in State
Welfare Waivers Approved Between January
1987 and August 1996




a
 In September 1996, HHS withdrew approval for the work requirement and time limit components
of the District of Columbia’s Project on Work, Employment, and Responsibility but let stand the
teen parent component.
b
 The waiver terms and conditions stipulate that New Hampshire may choose not to implement this
provision or choose to discontinue it once implemented.
c
South Carolina chose not to implement program.

Source: GAO analysis of the terms and conditions of approved state waivers supplemented by
information obtained from the states and HHS.




Page 75                                          GAO/HEHS-97-74 Welfare Benefit Termination
Appendix IV

Time-Limit Provisions in State Welfare
Waivers Approved Between January 1987
and August 1996

                         Type of time limit
Waiver program           (amount of time before
(approval date)          limit is reached)             Time-limit provisions                        Provisions for extending time limit
ARIZONA
Employing and Moving     Benefit reduction             Nonexempt adults are limited to 24           Extensions for 6-month periods can
People Off Welfare and   (24 months)                   months of AFDC receipt during a              be granted to those who
Encouraging                                            consecutive 60-month period. After time      demonstrate good cause for not
Responsibility (5/95)                                  limit is reached, family’s benefits are      being able to find and accept work
                                                       reduced by adult’s portion of grant.         with a specified level of earnings. Up
                                                                                                    to two 4-month extensions may be
                                                                                                    granted to allow for completion of an
                                                                                                    education or training program.
CALIFORNIA
California Work Pays     Work trigger with             Mandatory JOBS participants are              None
Demonstration Project    sanctions (22 months)         required to participate 100 hours per
Amendment (9/95)                                       month in the Community Work
                                                       Experience Program (CWEP)(or if less,
                                                       the number of hours equal to the AFDC
                                                       grant divided by the federal minimum
                                                       wage) if they have received AFDC for 22
                                                       of the last 24 months, are unemployed or
                                                       employed fewer than 15 hours per week,
                                                       have received the services to meet their
                                                       employment goals, and have completed
                                                       CWEP or are participating in CWEP for
                                                       less than 100 hours per month.
CONNECTICUT
A Fair Chance (9/94)     Work trigger with             After receiving benefits for the first 24 None
                         full-family sanction          cumulative months under Pathways,
                         (24 months)                   assistance units may continue to receive
                                                       benefits only if nonexempt participants
                                                       comply with the activities required by
                                                       their employability plans. Noncompliance
                                                       results in the assistance unit being
                                                       ineligible for AFDC.
Reach for Jobs First     Benefit termination           AFDC receipt for all assistance units with   Extensions for 6-month periods can
(12/95)                  (21 months)                   a mandatory JOBS participant is limited      be granted to those who have been
                                                       to 21 months, except for units where         unable to obtain or retain
                                                       minor parents are heads of household.        employment despite a good faith
                                                       After time limit is reached, assistance      effort to substantially comply with all
                                                       units’ benefits are terminated.              JOBS requirements.
                                                                                                                               (continued)




                                             Page 76                                       GAO/HEHS-97-74 Welfare Benefit Termination
                                               Appendix IV
                                               Time-Limit Provisions in State Welfare
                                               Waivers Approved Between January 1987
                                               and August 1996




                            Type of time limit
Waiver program              (amount of time before
(approval date)             limit is reached)            Time-limit provisions                         Provisions for extending time limit
DELAWARE
A Better Chance (5/95)      Work trigger with            After receiving benefits for 24 months,       Extensions to the 4-year time limit
                            sanctions up to              nonexempt households headed by                may be granted if the state has failed
                            full-family sanction         employable adults age 19 and older may        to provide services specified in
                            (24 months)                  continue to receive AFDC only if adults       recipients’ contracts; no suitable
                                                         participate in a work experience program      unsubsidized employment is
                            Benefit termination          and job search or are working and the         available in the local economy,
                            (48 months)                  household’s income is below 75 percent        despite recipients’ good faith efforts
                                                         of the federal poverty level. Sanctions for   to obtain employment; or other
                                                         noncompliance without good cause are          unique circumstances prevent
                                                         increasing reductions in grant, followed      recipients from obtaining
                                                         by termination of families’ benefits. After   employment.
                                                         receiving AFDC for 4 years, household
                                                         benefits are terminated if the adult is
                                                         determined to be employable.
FLORIDA
Family Transition Program   Benefit termination          AFDC receipt is limited to 36 months in       Extensions for up to two 4-month
(1/94)                      (24 or 36 months)            any 72-month period for nonexempt             periods can be granted if the state
                                                         families that have a caretaker relative or    has substantially failed to provide
                                                         adult under age 24 who does not have a        services, the recipient would benefit
                                                         high school diploma or equivalent, is not     from additional education or training
                                                         in high school and has little work history    regarding immediate employment
                                                         in the past year, or has received AFDC        prospects, or the recipient has
                                                         for 36 of 60 months before entering the       encountered extraordinary difficulties
                                                         program. AFDC benefit receipt for other       in obtaining employment or
                                                         nonexempt families is limited to 24           completing his or her plan.
                                                         months in any 60-month period. If the
                                                         state determines that benefit termination
                                                         would most likely result in children being
                                                         placed in emergency shelter or foster
                                                         care, only the parent’s or caretaker’s
                                                         needs will be removed from grant.
                                                         Transitional employment program
                                                         provides private-sector employment
                                                         possibilities for recipients who have
                                                         diligently completed their employment
                                                         plans but have been unable to obtain
                                                         employment.
GEORGIA
Work for Welfare (10/95)    Work trigger with            After receiving AFDC for 24 of the last 36 None
                            sanctions (24 months)        months, nonexempt adult recipients and
                                                         noncustodial parents under court order
                                                         are required to participate in up to 20
                                                         hours of work per month at an assigned
                                                         agency. Sanction for failure to participate
                                                         without good cause is withholding of
                                                         individual’s portion of grant for increasing
                                                         lengths of time.
                                                                                                                                 (continued)




                                               Page 77                                        GAO/HEHS-97-74 Welfare Benefit Termination
                                              Appendix IV
                                              Time-Limit Provisions in State Welfare
                                              Waivers Approved Between January 1987
                                              and August 1996




                          Type of time limit
Waiver program            (amount of time before
(approval date)           limit is reached)             Time-limit provisions                         Provisions for extending time limit
HAWAII
Pursuit of New            Benefit termination           AFDC receipt limited to 60 months for all     Extensions for 3-month periods may
Opportunities (8/96)      (60 months)                   nonexempt families.                           be granted if recipients who have not
                                                                                                      found employment have made a
                                                                                                      good faith effort to find a job and
                                                                                                      satisfactorily fulfilled approved
                                                                                                      employment training activity
                                                                                                      requirements.
ILLINOIS
Work and Responsibility   Work trigger with             After 12 months in the Targeted Work          Extensions to the 24-month time limit
(9/95)                    sanctions (12 months)         Initiative program, participants who are      can be granted if recipients cannot
                                                        unemployed and have completed                 find or maintain full- or part-time
                          Benefit termination           approved JOBS activities are required to      employment at least equal to the
                          (24 months)                   participate in subsidized work positions.     maximum AFDC benefit for a family
                                                        Sanction for failure to participate without   of that size, plus the appropriate
                                                        good cause is nonpayment of wages by          work expense deductions.
                                                        employer. Nonexempt cases that receive
                                                        a total of 24 months of AFDC are
                                                        ineligible to reapply for assistance for 24
                                                        months.
INDIANA
Indiana Manpower          Benefit reduction             For any family that includes an adult in      Extensions can be granted to
Placement and             (24 months)                   the placement track, the amount of AFDC       individuals who have cooperated
Comprehensive Training                                  cash benefits taking into account the         with the JOBS program and
Program (12/94)                                         needs of the adult is limited to 24 months    substantially complied with the
                                                        from the time of entry to this track,         requirements of their self-sufficiency
                                                        followed by a 36-month period of the          plans if (1) a temporary physical or
                                                        adult not receiving AFDC.                     mental condition prevents the
                                                                                                      individual from attaining and
                                                                                                      maintaining employment that would
                                                                                                      provide the family at least a
                                                                                                      specified level of income; (2) the
                                                                                                      state has substantially failed to
                                                                                                      provide services specified in
                                                                                                      self-sufficiency plans; (3) despite all
                                                                                                      appropriate efforts, the person has
                                                                                                      been unable to find, or has lost
                                                                                                      without cause, employment that
                                                                                                      would provide at least a specified
                                                                                                      level of income; or (4) other unique
                                                                                                      circumstances prevent obtaining or
                                                                                                      retaining employment.
                                                                                                                                 (continued)




                                              Page 78                                        GAO/HEHS-97-74 Welfare Benefit Termination
                                               Appendix IV
                                               Time-Limit Provisions in State Welfare
                                               Waivers Approved Between January 1987
                                               and August 1996




                            Type of time limit
Waiver program              (amount of time before
(approval date)             limit is reached)            Time-limit provisions                         Provisions for extending time limit
Amendments to Indiana  Benefit reduction                 AFDC receipt for adults who are not           An individual’s assistance unit may
Manpower Placement and (24 months)                       exempt from JOBS is limited to 24             earn 1 month of AFDC benefits
Comprehensive Training                                   months in the demonstration period.           beyond the time limit for each period
Program (8/96)                                                                                         of 6 consecutive months during
                                                                                                       which an individual was employed
                                                                                                       full time. Renewable extensions of up
                                                                                                       to 1 year can be granted to
                                                                                                       individuals who have cooperated
                                                                                                       with the JOBS program and
                                                                                                       substantially complied with the
                                                                                                       requirements of their self-sufficiency
                                                                                                       plans if (1) the state has substantially
                                                                                                       failed to provide services specified
                                                                                                       in self-sufficiency plans; (2) despite
                                                                                                       all appropriate efforts, the person
                                                                                                       has been unable to find, or has lost
                                                                                                       without cause, employment that
                                                                                                       would provide at least a specified
                                                                                                       level of income; or (3) other unique
                                                                                                       circumstances prevent obtaining or
                                                                                                       retaining employment.
LOUISIANA
Individual Responsibility   Benefit termination          Nonexempt families are limited to 24          Extension can be granted for up to 1
Project (2/96)              (24 months)                  months of AFDC cash benefits in a             year to enable adults to complete
                                                         60-month period. After time limit is          employment-related education or
                                                         reached, families’ benefits are terminated.   training.
MARYLAND
Family Investment           Work trigger with            Nonexempt recipients may not receive          Extensions can be granted if a
Program (8/95)a             sanctions up to              more than 3 months of AFDC benefits           recipient cannot find necessary and
                            full-family sanction         unless they meet a work requirement:          adequate child care, has a verified
                            (3 months)                   full-time unsubsidized employment, 30         illness, or is attending an educational
                                                         hours of subsidized employment, a             or training program that will
                                                         minimum of 20 hours of community              substantially improve his or her
                                                         service, or a minimum of 20 hours of          prospects of obtaining a job.
                                                         community service combined with
                                                         employment. Sanctions for
                                                         noncompliance are removal of
                                                         noncooperating person from grant,
                                                         followed by case closure after 6
                                                         cumulative months.
                                                                                                                                  (continued)




                                               Page 79                                       GAO/HEHS-97-74 Welfare Benefit Termination
                                               Appendix IV
                                               Time-Limit Provisions in State Welfare
                                               Waivers Approved Between January 1987
                                               and August 1996




                            Type of time limit
Waiver program              (amount of time before
(approval date)             limit is reached)            Time-limit provisions                       Provisions for extending time limit
MASSACHUSETTS
Welfare Reform ’95 (10/95) Work trigger with             Nonexempt adults whose child is of            None
                           sanctions up to               mandatory full-time school age are
                           full-family sanction          required to work at least 20 hours per
                           (60 days)                     week after receiving AFDC for 60 days.
                                                         Requirement may be met through
                                                         working 20 hours per week in
                                                         unsubsidized employment, working full
                                                         time in a subsidized employment
                                                         program, participating 20 hours per week
                                                         in the community service program, or
                                                         combining work and participation in the
                                                         community service program for 20 hours
                                                         per week. Sanction for noncompliance
                                                         without good cause is reduction in
                                                         benefit payment equal to adult’s portion
                                                         of benefit. For recipients required to
                                                         participate in the community service
                                                         program, the sanction for repeated failure
                                                         to participate is termination of the family’s
                                                         AFDC benefit.
MINNESOTA
Work First (8/96)           Work trigger with            If, at the end of the required 60 days of   None
                            full-family sanction         job search, a participant assigned to the
                            (60 days)                    immediate employment track has not
                                                         been hired for at least 32 hours per week
                                                         or does not earn a net income from
                                                         self-employment equal to his or her
                                                         AFDC grant, the individual is required to
                                                         participate in CWEP and continue job
                                                         search. If participants do not comply with
                                                         CWEP requirements within the time
                                                         specified in their conciliation conference,
                                                         the entire family’s needs are removed in
                                                         determining the amount of AFDC benefits
                                                         for at least 6 months.
                                                                                                                             (continued)




                                               Page 80                                       GAO/HEHS-97-74 Welfare Benefit Termination
                                               Appendix IV
                                               Time-Limit Provisions in State Welfare
                                               Waivers Approved Between January 1987
                                               and August 1996




                             Type of time limit
Waiver program               (amount of time before
(approval date)              limit is reached)           Time-limit provisions                         Provisions for extending time limit
MISSOURI
Missouri Families Mutual     Work trigger with           After reaching the 24-month time limit        The 24-month time limit can be
Responsibility Plan (4/95)   sanctions (24 months)       specified in their self-sufficiency           extended an additional 24 months
                                                         agreements, JOBS-mandatory individuals        when necessary to allow individuals
                             Benefit reduction (36       may be required to participate in a job       to complete their self-sufficiency
                             months)                     search or CWEP. Noncompliance without         agreements.
                                                         good cause is subject to sanctions in
                                                         accord with federal regulations.
                                                         Individuals who reapply for benefits after
                                                         completing a self-sufficiency agreement
                                                         entered into after July 1, 1997, will be
                                                         denied AFDC if they received benefits for
                                                         at least 36 months; however, other
                                                         eligible family members may receive
                                                         AFDC.
MONTANA
Families Achieving      Work trigger with                Nonexempt single-parent families have a       None
Independence in Montana sanctions (18 or 24              24-month time limit and nonexempt
(4/95)                  months)                          two-parent families have an 18-month
                                                         time limit after which adult recipients are
                                                         required to participate an average of 20
                                                         hours a week in community services
                                                         program activities if such activities are
                                                         available. The sanction for
                                                         noncompliance is removal of the adult’s
                                                         needs from the grant for increasing
                                                         periods of time.
NEBRASKA
Welfare Reform               Benefit termination         AFDC receipt for families assigned to the     Benefits will not be terminated if (1)
Demonstration Project        (24 months)                 time-limited program is limited to 24         no job that provides at least a
(2/95)                                                   months in a 48-month period. After the        specified level of income is available
                                                         time limit is reached, benefits are           to a recipient, (2) termination would
                                                         terminated.                                   result in the family’s experiencing
                                                                                                       extreme hardship, (3) adult family
                                                                                                       members can no longer meet the
                                                                                                       conditions of their self-sufficiency
                                                                                                       contracts, or (4) the state has failed
                                                                                                       to meet the terms of a recipient’s
                                                                                                       self-sufficiency contract.
                                                                                                                                 (continued)




                                               Page 81                                        GAO/HEHS-97-74 Welfare Benefit Termination
                                               Appendix IV
                                               Time-Limit Provisions in State Welfare
                                               Waivers Approved Between January 1987
                                               and August 1996




                            Type of time limit
Waiver program              (amount of time before
(approval date)             limit is reached)            Time-limit provisions                           Provisions for extending time limit
NEW HAMPSHIRE
Employment Program          Work trigger with            After 26 weeks of job search, adults      None
(6/96)                      sanctions up to              nonexempt from JOBS who are able to
                            full-family sanction         work are required to work for 26 weeks,
                            (26 weeks)                   provided that work is available. The work
                                                         requirement may be fulfilled by
                                                         unsubsidized work, subsidized work,
                                                         on-the-job training, community service,
                                                         alternative work experience programs,
                                                         work supplementation, or other approved
                                                         employment-related activities. Sanctions
                                                         for noncompliance without good cause
                                                         are increasing reductions in AFDC grant,
                                                         culminating in case closure.
NORTH CAROLINA
Work First Program (2/96)   Benefit termination          AFDC receipt for families in the Work First     Extensions may be granted if
                            (24 months)                  employment and training program is              recipients have substantially
                                                         limited to 24 months. After the time limit is   complied with their personal
                                                         reached, families are ineligible for            responsibility contracts (or have
                                                         benefits for 36 months.                         good cause reasons for not doing
                                                                                                         so) and through no fault of their own
                                                                                                         have been unable to obtain or
                                                                                                         maintain employment to provide a
                                                                                                         specified level of subsistence.
NORTH DAKOTA
Training, Education,      Work trigger with              Nonexempt families are required to sign Not specified
Employment, and           sanctions (24 months, 42       a social contract that sets an expected
Management Project (9/95) months, or 43 months or        time limit for self-sufficiency based on
                          longer)                        factors related to employability: 24
                                                         months, 42 months, or 43 months or
                                                         longer. Individuals not employed full time
                                                         in unsubsidized employment by end of
                                                         time limit are placed in a work experience
                                                         position or granted an extension.
OHIO
Ohio First (3/96)           Benefit termination          AFDC receipt for nonexempt assistance None cited
                            (36 months)                  units headed by adults is limited to 36
                                                         months out of any 60-month period. After
                                                         the time limit is reached, assistance unit’s
                                                         benefits are terminated.
                                                                                                                                   (continued)




                                               Page 82                                         GAO/HEHS-97-74 Welfare Benefit Termination
                                            Appendix IV
                                            Time-Limit Provisions in State Welfare
                                            Waivers Approved Between January 1987
                                            and August 1996




                          Type of time limit
Waiver program            (amount of time before
(approval date)           limit is reached)           Time-limit provisions                     Provisions for extending time limit
OKLAHOMA
Mutual Agreement—A        Work trigger with           After 36 cumulative months of AFDC        Extensions may be provided to
Plan for Success (3/95)   sanctions (36 months)       receipt out of 60 months for recipients   individuals who are making
                                                      nonexempt from JOBS, participation in     satisfactory progress in the program
                                                      workfare (or other JOBS components        and are within either one semester of
                                                      leading to employment if workfare         completing an educational program
                                                      positions are unavailable) becomes        or 4 months of completing a training
                                                      mandatory. JOBS sanctions may be          program expected to lead directly to
                                                      imposed on individuals who fail to meet   employment.
                                                      the minimum hourly requirement.
OREGON
Oregon Option (3/96)      Benefit termination         Nonexempt families are limited to 24      Extensions can be granted to the
                          (24 months)                 cumulative months of AFDC receipt in      following recipients: (1) a dependent
                                                      any period of 84 consecutive months.      child in a two-parent household in
                                                                                                which the primary wage earner has
                                                                                                died; (2) a dependent child living
                                                                                                with a person other than the
                                                                                                parent(s) with whom the child lived
                                                                                                at the time the child was receiving
                                                                                                AFDC; or (3) a parent of a
                                                                                                dependent child receiving AFDC,
                                                                                                and his or her dependent children, if
                                                                                                the state determines that the parent
                                                                                                is making good faith efforts to obtain
                                                                                                permanent employment.
SOUTH CAROLINA
Family Independence Act   Benefit termination         Nonexempt families are limited to 24      An extension of up to 6 months may
(5/96)                    (24 months)                 months of AFDC receipt.                   be granted if an individual is
                                                                                                involved in a training program that
                                                                                                will not be completed by the 24th
                                                                                                month. An extension of up to 12
                                                                                                months can be granted if an
                                                                                                individual has completed training
                                                                                                and has diligently complied with the
                                                                                                self-sufficiency plan but cannot
                                                                                                obtain or maintain employment that
                                                                                                provides at least a specified level of
                                                                                                subsistence. When the 6- or
                                                                                                12-month extensions expire,
                                                                                                month-by-month extensions may be
                                                                                                granted if an individual has complied
                                                                                                with the self-sufficiency plan and the
                                                                                                county determines either that benefit
                                                                                                termination will have detrimental
                                                                                                effect on the welfare of the children
                                                                                                or that the family has no other source
                                                                                                of financial support sufficient to
                                                                                                provide at least a specified level of
                                                                                                subsistence.
                                                                                                                          (continued)



                                            Page 83                                      GAO/HEHS-97-74 Welfare Benefit Termination
                                              Appendix IV
                                              Time-Limit Provisions in State Welfare
                                              Waivers Approved Between January 1987
                                              and August 1996




                             Type of time limit
Waiver program               (amount of time before
(approval date)              limit is reached)          Time-limit provisions                           Provisions for extending time limit
SOUTH DAKOTA
Strengthening South          Work trigger with          Nonexempt adults assigned to the                An extension can be granted if the
Dakota Families Initiative   sanctions (24 or 60        employment track are limited to 24              state fails to make available services
(3/94)                       months)                    months of AFDC receipt. Nonexempt               it agreed to provide as part of an
                                                        adults assigned to the education track          individual’s self-sufficiency plan and
                                                        are limited to 60 months of AFDC receipt.       determines that an individual needs
                                                        When the time limits are reached, adults        additional time to complete his or her
                                                        who are not working 30 hours per week           plan.
                                                        are required to perform 30 hours per
                                                        week of approved volunteer service.
                                                        Noncompliance is subject to either a
                                                        JOBS sanction or the grant being
                                                        reduced in any month of noncompliance
                                                        to an amount equal to what the family
                                                        would receive if the adult’s needs were
                                                        not taken into account.
TENNESSEE
Families First (7/96)        Benefit termination (18    Receipt of AFDC cash benefits by an             The 18-month eligibility period may
                             months and 60 months)      assistance unit is limited to 60 months,        be extended for an additional 6
                                                        and periods of eligibility within the 60        months for families in which the
                                                        months are limited to 18 months. An             caretaker is living in an economic
                                                        assistance unit whose benefit is                hardship county and is in substantial
                                                        terminated after receiving AFDC cash            compliance with the Personal
                                                        assistance for 18 months within an              Responsibility Plan. The 18-month
                                                        18-month period of eligibility is eligible to   and 60-month periods can also be
                                                        reapply for AFDC no sooner than 3               extended on a case-by-case basis if
                                                        months from the last month of receipt of        good cause exists or the state has
                                                        AFDC, with the following exception. The         failed to provide timely services.
                                                        assistance unit will not be subject to the      Good cause exists when all of the
                                                        3-month waiting period if the caretaker         following criteria are met: (1) the
                                                        was employed when the case was                  participant is in compliance with the
                                                        terminated, loses the job through no fault      plan, (2) the participant has been in
                                                        of his or her own, and the assistance unit      substantial compliance with the plan
                                                        meets all other AFDC eligibility                during the entire current period of
                                                        requirements. The state will act to monitor     eligibility, (3) the assistance unit’s
                                                        and protect the safety and well-being of        income is less than the payment
                                                        the children in families whose benefits         standard plus $90 (or a higher
                                                        are terminated. If the state certifies that     amount), and (4) the participant is
                                                        AFDC assistance is needed to prevent a          not currently refusing employment or
                                                        child’s loss of housing, heat, light, or        voluntarily quitting employment
                                                        water or to prevent removal of the child        without good cause.
                                                        from the custody of his or her parent, a
                                                        cash or vendor payment will be issued to
                                                        meet the child’s needs.
                                                                                                                                  (continued)




                                              Page 84                                         GAO/HEHS-97-74 Welfare Benefit Termination
                                           Appendix IV
                                           Time-Limit Provisions in State Welfare
                                           Waivers Approved Between January 1987
                                           and August 1996




                        Type of time limit
Waiver program          (amount of time before
(approval date)         limit is reached)            Time-limit provisions                       Provisions for extending time limit
TEXAS
Achieving Change for    Benefit reduction (12, 24, On the basis of availability of JOBS          Extensions of no longer than 6
Texans (3/96)           or 36 months)              positions, AFDC receipt is time limited for   months at a time can be granted
                                                   caretakers, second parents in                 upon request if the individual lives in
                                                   AFDC-Unemployed Parent cases, and             an area of economic hardship or
                                                   teen parents certified as caretakers. The     experiences severe personal
                                                   length of the time limit—12, 24, or 36        hardship and has complied with all
                                                   months—depends on the extent of the           work-related requirements.
                                                   individual’s education and work
                                                   experience. After the time limit is
                                                   reached, a family’s benefits are reduced
                                                   by the individual’s portion for 5 years.
VERMONT
Family Independence     Work trigger with            Nonexempt parents who have not              None
Project (4/93)          sanctions (15 or 30          accepted an unsubsidized job will be
                        months)                      required to participate in community
                                                     service jobs after 30 months
                                                     (single-parent families and two-parent
                                                     families with incapacitated adults) or 15
                                                     months (other two-parent families). The
                                                     sanction for failure to participate is a
                                                     reduction of the AFDC benefit based on
                                                     the number of hours the parent was
                                                     required to work under the community
                                                     service jobs component.
Welfare Restructuring   Work trigger with            Nonexempt parents who have not             None
Project (7/94)          sanctions up to              accepted an unsubsidized job or who are
                        full-family sanction         working in an unsubsidized job for fewer
                        (15 or 30 months)            than the required hours will be required
                                                     to participate in community service jobs
                                                     after 30 months (single-parent families
                                                     and two-parent families with
                                                     incapacitated adults) or 15 months (other
                                                     two-parent families). The sanction for
                                                     failure to participate is issuance of the
                                                     AFDC benefit in the form of vendor
                                                     payments for housing, food, fuel, and
                                                     utilities (with any remaining balance paid
                                                     in cash). Failure to comply with any
                                                     requirements while under the sanction
                                                     will result in termination of a family’s
                                                     AFDC benefit.
                                                                                                                            (continued)




                                           Page 85                                       GAO/HEHS-97-74 Welfare Benefit Termination
                                              Appendix IV
                                              Time-Limit Provisions in State Welfare
                                              Waivers Approved Between January 1987
                                              and August 1996




                           Type of time limit
Waiver program             (amount of time before
(approval date)            limit is reached)            Time-limit provisions                        Provisions for extending time limit
VIRGINIA
Virginia Independence      Work trigger with            Within 90 days of signing personal           Hardship exceptions to the 24-month
Program (7/95)             sanctions up to              responsibility agreements, nonexempt         time limit can be granted for up to 1
                           full-family sanction         recipients are required to participate in    year if factors relating to job
                           (90 days)                    work activities such as unsubsidized         availability are unfavorable or an
                                                        employment, subsidized employment, or        exception would enable a caretaker
                           Benefit termination          CWEP. The sanction for noncompliance         to complete employment-related
                           (24 months)                  is termination of families’ benefits for     education or training. Hardship
                                                        increasing periods of time. In addition,     exceptions can also be granted for
                                                        cases headed by nonexempt caretakers         up to 90 days if an individual has
                                                        are limited to 24 cumulative months of       been actively seeking unsubsidized
                                                        AFDC cash benefits.                          employment and cannot find a job
                                                                                                     that pays at least a specified amount
                                                                                                     or the individual demonstrates
                                                                                                     extreme hardship because of a job
                                                                                                     loss resulting from factors unrelated
                                                                                                     to job performance. Extensions to
                                                                                                     hardship exceptions may be granted
                                                                                                     in very limited circumstances.
WASHINGTON
Success Through            Benefit reduction (48        Assistance units in which adults have        None
Employment Program         months)                      received AFDC for 48 months in any
(10/95)                                                 60-month period will have benefits
                                                        reduced by 10 percent. Until an
                                                        assistance unit has been off assistance
                                                        for 1 month or more, benefits will be
                                                        reduced by an additional 10 percent for
                                                        each additional 12 months of AFDC
                                                        receipt.
WISCONSIN
Work Not Welfare (11/93)   Work trigger with            After the first month, nonexempt             Extensions to the 24-month time limit
                           sanctions up to              recipients are required to earn their        can be granted to those who (1)
                           full-family sanction (1      benefits through education, training, or     cannot work for reasons such as
                           month and 12 months)         work activities; after 12 months of AFDC     personal disability or incapacity, (2)
                                                        receipt, they must engage in work            need to care for a disabled
                           Benefit termination (24      activities. The sanction for                 dependent, or (3) have made all
                           months)                      noncompliance without good cause is a        appropriate efforts to find work but
                                                        reduction of the combined AFDC/food          cannot find work because local labor
                                                        stamp grant based on the number of           market conditions preclude a
                                                        hours of assigned activity not completed.    reasonable job opportunity.
                                                        Nonexempt cases are limited to 24
                                                        months of AFDC receipt within a
                                                        48-month period. After this time limit is
                                                        reached, families’ benefits are terminated
                                                        for 36 months.
                                                                                                                               (continued)




                                              Page 86                                       GAO/HEHS-97-74 Welfare Benefit Termination
                                              Appendix IV
                                              Time-Limit Provisions in State Welfare
                                              Waivers Approved Between January 1987
                                              and August 1996




                            Type of time limit
Waiver program              (amount of time before
(approval date)             limit is reached)           Time-limit provisions                            Provisions for extending time limit
WYOMING
New Opportunities and       Benefit reduction (varies) Nonexempt individuals who complete an             One 6-month extension may be
New Responsibilities (9/93)                            associate’s or bachelor’s program while           granted to individuals to update an
                                                       receiving AFDC will be eligible for no            expired certification, take a licensing
                                                       more than 6 additional months of                  or certification examination, or obtain
                                                       benefits. In addition, nonexempt                  a license or certificate to practice the
                                                       individuals will be ineligible for AFDC if        trade or profession for which they
                                                       they are pursuing a bachelor’s degree             have been trained.
                                                       beyond a sixth year; a vocational or
                                                       associate’s degree beyond a fourth year;
                                                       or a second associate’s or bachelor’s
                                                       degree or any kind of graduate degree.

                                              Note: The District of Columbia’s Project on Work, Employment, and Responsibility, approved
                                              Aug. 19, 1996, contained a time-limit provision. HHS withdrew approval for this provision in Sept.
                                              1996.
                                              a
                                               The time-limit provision was eliminated when Maryland’s Family Investment Program was
                                              amended in Aug. 1996.

                                              Source: GAO analysis of the terms and conditions of approved state waivers, supplemented by
                                              information obtained from the states and HHS.




                                              Page 87                                            GAO/HEHS-97-74 Welfare Benefit Termination
Appendix V

Reasons for Excluding Cases From
Coverage in Selected States


                              AFDC caseload in jurisdictions covered as of June 30,
                                                      1996
              State                             Number                      Percent
              Arizona                            61,538                       100.0
              Connecticut                        56,017                       100.0
              Delaware                           10,253                       100.0
                         e
              Florida                             9,083                       100.0
              Illinois                          221,632                       100.0
              Iowa                               28,581                       100.0
              Massachusetts                      82,237                       100.0
              Michigan                          174,176                       100.0
              Mississippi                        11,697                       100.0
              Nebraska                            2,423                       100.0
              Utah                               14,320                       100.0
              Vermont                             8,965                       100.0
              Virginia                           63,399                       100.0
              Wisconsin                          52,765                       100.0




              Page 88                     GAO/HEHS-97-74 Welfare Benefit Termination
                                        Appendix V
                                        Reasons for Excluding Cases From
                                        Coverage in Selected States




          Cases exempta
                          Age-of-
                          youngest-          Cases assigned to a             Cases excluded for other           Cases subject to benefit
                          child                control groupb                       reasons                          termination
Number         Percent    exemption            Number            Percent         Number            Percent          Number            Percent
      0              0    (none)                   1,100              1.8                 0                0          60,438              98.2
       c                                                                                     d
  7,595           13.6    1 year                   1,900              3.4          24,110              43.0           22,412              40.0
  1,161           11.3    3 months                 1,676             16.3            5,353d            52.2            2,063              20.1
                                                                                             f
  1,499           16.5    6 months                 3,732             41.1              826               9.1           3,026              33.3
   575g            0.3    13 yearsh                5,694              2.6                 0                0        215,363i              97.2
  6,777           23.7    6 months                  918               3.2                 0                0          20,886              73.1
 57,109c          69.4    6 years                  1,692              2.1            7,976d              9.7          15,460              18.8
 46,806           26.9    4 months                12,888              7.4                 0                0        114,482               65.7
  5,248           44.9    3 years                  1,297             11.1                 0                0           5,152              44.0
                                    j
   319            13.2    6 months                  878              36.2                 0                0           1,226              50.6
      0k             0    none                     5,230             36.5               32l              0.2           9,058              63.3
     61            0.7    18 months                3,545             39.5                 0                0           5,359              59.8
  5,600            8.8    18 months                3,000              4.7                 0                0          54,800              86.4
                                                                                           m
  9,424           17.9    1 year                    675               1.3            3,306               6.3          39,360              74.6

                                        a
                                          Typical categories of exemptions to work requirements under states’ waiver programs were
                                        similar to those provided under the JOBS program: having a disability, caring for a young child or
                                        a disabled household member, or household headed by caretaker relatives (also referred to as
                                        “ineligible grantees”) with no legal obligation of support. Some states provided exemptions for
                                        seniors (aged 62 or older), for those in their last 3 or 4 months of pregnancy, or for those lacking
                                        transportation or child care. Categories of exemptions for other types of requirements leading to
                                        full-family sanctions varied by the requirements. For example, exemptions relating to the teen
                                        living arrangement requirement generally dealt with conditions in the teens’ parents’ homes, and
                                        exemptions relating to child enforcement requirements generally dealt with the unavailability, or
                                        risk to the child of providing, information on the absent parent.
                                        b
                                         As a standard condition of obtaining HHS approval for a waiver, states were required to provide
                                        for an evaluation based on a comparison of those subject to the waiver provisions (treatment
                                        group) versus those subject to previous program provisions (control group). Cases were to be
                                        randomly assigned to the control groups in each state, generally to be spread incrementally
                                        through the first few years of implementation. As a result, the number of cases excluded as
                                        control cases in each state depended on the number of waivers being implemented and how
                                        long the state had been implementing each of its waiver programs. Under the new federal welfare
                                        reform law, states are no longer required to evaluate their waiver programs, and they may
                                        discontinue maintaining their control groups for study. As of April 1997, 16 states had requested
                                        HHS funding to continue evaluations of their waivers, including maintenance of control groups. Of
                                        these, 10 were states that had implemented benefit termination waiver provisions.
                                        c
                                         The exemption data included here represent those who were not subject to a nonmandatory
                                        work requirement; exemption data are different for other requirements in which noncompliance
                                        can result in full-family sanction, such as the teen living arrangement and teen school attendance
                                        requirements.
                                        d
                                        Pending review for conversion to new program.




                                        Page 89                                            GAO/HEHS-97-74 Welfare Benefit Termination
Appendix V
Reasons for Excluding Cases From
Coverage in Selected States




e
 Data included here are for Alachua and Escambia counties only, the two pilot counties where all
terminations as of Dec. 31, 1996, had taken place.
f
    Nonvolunteers in Alachua County where participation was voluntary.
g
 Represents the number exempt among the 15,000 cases otherwise subject to work requirements
under the Targeted Work Initiative and Get a Job components of Illinois’s Work and Responsibility
waiver.
h
 Age-of-youngest-child exemption among those subject to work requirements. No exemptions
provided for requirement to sign self-sufficiency plan.
i
 Of the total caseload, about 14,425 cases were subject to provisions potentially leading to benefit
termination on the basis of noncooperation with work requirements; and the entire caseload
(except control cases) was subject to provisions potentially leading to benefit termination on the
basis of noncooperation with signing a self-sufficiency plan.
j
However, cases with the youngest child age 12 weeks to 6 months must participate part time in
activities such as family nurturing or pre-employment skills.
k
 According to the waiver, no one over age 15 was exempt. However, according to a May 1996
report prepared by the Utah Department of Human Services, approximately 4 to 5 percent of
families are at any one time temporarily excused from active participation because of a recent
birth, personal illness, or unforeseen circumstance.
l
    Seasonal fluctuation.
m
 Represents cases in other waiver demonstration projects, such as Work Not Welfare, Parental
and Family Responsibility, and Learnfare.




Page 90                                             GAO/HEHS-97-74 Welfare Benefit Termination
Appendix VI

Overview of Waiver Programs in Iowa,
Massachusetts, and Wisconsin

                     Iowa was the first of the three case study states to implement benefit
Iowa’s Family        termination provisions statewide under its waiver, called the Family
Investment Program   Investment Program. The goal of the program, as stated in Iowa’s waiver
                     application, was to transform its welfare system from one of income
                     maintenance to one of self-sufficiency. The program was designed to make
                     welfare a transition to work by requiring participants’ involvement in some
                     work or training activity and providing consequences for those not
                     participating. Iowa began implementing some provisions under this waiver
                     in October 1993 but did not begin implementing its benefit termination
                     provisions statewide until April 1994.

                     At the core of Iowa’s program was the Family Investment Agreement, an
                     individualized plan designed to help each family achieve self-sufficiency.
                     This plan generally called for entry into the workforce as soon as possible,
                     with state assistance in job search activities and child care provision. In
                     some cases, however, a recipient’s plan may have called for a period of
                     education, training, rehabilitation, or work experience to prepare the
                     recipient for the job market. As circumstances changed, the plan,
                     including a time table for achieving self-sufficiency, could be altered on
                     the basis of client and caseworker consultations. Recipients who failed to
                     sign the agreement, or who signed it but failed to subsequently fulfill the
                     terms of the agreement, had their benefits phased out under a Limited
                     Benefit Plan. Initially, the Limited Benefit Plan consisted of 3 months of
                     full benefits, followed by 3 months of reduced benefits (eliminating the
                     adult portion of the grant), then benefit termination. In February 1996, the
                     state shortened the phase-out period by eliminating the 3 months of full
                     benefits. Before termination, recipients in the Limited Benefit Plan who
                     had not previously signed a Family Investment Agreement could request
                     having their full benefits reinstated by signing an agreement. Once a case
                     had been terminated, however, families were required to wait 6 months
                     before reapplying for benefits.

                     Iowa contracted with Mathematica Policy Research, Inc., and the Institute
                     for Social and Economic Development to evaluate its program as required
                     under the waiver. At the time of our review, the evaluators were
                     conducting a study including (1) a flow analysis to obtain data on the
                     number of and reasons why recipients entered and exited the Limited
                     Benefit Plan program and (2) a survey of recipients whose benefits have
                     been terminated to determine what happened to them after termination.
                     For the survey, the evaluators contacted 137 of the 172 recipients whose
                     benefits had been terminated between November 1995 and January 1996.
                     The state received the draft report summarizing the results of this study in



                     Page 91                               GAO/HEHS-97-74 Welfare Benefit Termination
                     Appendix VI
                     Overview of Waiver Programs in Iowa,
                     Massachusetts, and Wisconsin




                     October 1996, but the final report had not yet been released as this report
                     went to press. In addition, a request for funding from HHS to continue the
                     evaluation of Iowa’s waiver program was pending at the time of our
                     review.


                     As stated in Massachusetts’s waiver application, the underlying goal of its
Massachusetts’s      program, called Welfare Reform ’95, was to replace traditional cash
Welfare Reform ’95   assistance with work or community service requirements for all able-
Program              bodied AFDC recipients with school-aged children. At the core of this
                     program was the expectation that recipients would assume responsibility
                     for moving toward self-sufficiency. Ongoing recipients as well as new
                     applicants had to appear for an eligibility assessment under the new
                     program requirements. Similar to Iowa’s Family Investment Agreement,
                     Massachusetts required caseworkers to develop an Employment
                     Development Plan for each recipient subject to the work requirement and
                     for each teen parent.

                     Recipients subject to the work requirement had 60 days for job search
                     activities before the requirement was imposed. If recipients did not find
                     employment after 60 days, or if they subsequently lost their job, their plans
                     required participation in community service to meet the 20 hours per week
                     mandatory work requirement, and caseworkers provided a list of
                     community service work sites. Teen parents’ plans required enrollment in
                     high school (or an equivalent program) and at least 75-percent attendance;
                     caseworkers provided referrals to programs as needed. For both adults
                     and teens, the plans also allowed recipients to request support services
                     such as transportation or child care. If recipients failed to comply with
                     their plans, their benefits were reduced (removal of the adult portion of
                     the grant); continued noncompliance meant benefit termination for the
                     entire family. The state could reopen cases and restore full benefits
                     retroactively if recipients demonstrated compliance with plan
                     requirements for 2 consecutive weeks. The waiver explicitly eliminated
                     any formal reconciliation process before notifying recipients of or
                     implementing sanctions.

                     Although required under the waiver, the state had not yet contracted with
                     evaluators to study its program before the new federal welfare reform law
                     was enacted. At the time of our review, the state was developing plans to
                     evaluate the program under the new law; however, the state did not intend
                     to continue to maintain its control groups for study.




                     Page 92                                GAO/HEHS-97-74 Welfare Benefit Termination
                      Appendix VI
                      Overview of Waiver Programs in Iowa,
                      Massachusetts, and Wisconsin




                      Wisconsin implemented its benefit termination provisions statewide in
Wisconsin’s Pay for   March 1996 as part of the waiver demonstration project called Pay for
Performance Project   Performance. This project had two major components: provisions for
                      diverting AFDC applicants from ever receiving benefits and provisions for
                      requiring AFDC recipients to work in exchange for benefits.

                      The diversion component was designed to help applicants become self-
                      sufficient without going on welfare. Applicants met with a financial
                      planning resource specialist who would explain the alternatives to going
                      on welfare and the services available to help them find a job, secure child
                      care, or address other barriers to self-sufficiency. Those seeking further
                      assistance had to enroll in Wisconsin’s JOBS program and begin looking for
                      work. If applicants completed 60 hours of JOBS participation and were still
                      not self-sufficient, they then became eligible to receive welfare benefits.
                      Although statewide data on the effectiveness of these provisions were not
                      yet available, the number of applicants diverted from the welfare rolls due
                      to these provisions was significant, according to state and county officials.
                      Data compiled in one county revealed that 46 percent of 880 applicants
                      deemed likely to have gone on AFDC between March and July of 1996 were
                      diverted from receiving benefits.

                      The work-in-exchange-for-benefits component was designed to replicate
                      working-world situations for those receiving benefits by reducing benefits
                      proportionately to the number of required hours not worked. The program
                      required recipients to work 20 to 40 hours per week. Each month,
                      caseworkers determined hours of participation in assigned JOBS activities
                      and calculated a monetary sanction for any missed hours by multiplying
                      the number of missed hours by the federal minimum wage. If a recipient’s
                      participation fell below 25 percent of the scheduled hours, the entire AFDC
                      grant was reduced to zero, and, because the AFDC and food stamp work
                      requirements were linked, food stamps were reduced to $10 for those who
                      had no basis for exemption under the food stamp employment and training
                      program (such as having a child under 6 years old).66 Because calculating
                      these sanctions is difficult, sanctions were not to be imposed until the
                      second month after the month in question to allow a 30-day period for data
                      processing and for the recipient to request adjustments based on good
                      cause for failure to participate or on reporting and processing errors. The
                      state closed cases if the recipient failed to enroll in the Pay for
                      Performance JOBS program or received a full sanction (for participation
                      below 25 percent) for 3 consecutive months. Once the state closed a case,

                      66
                       Under the new federal welfare reform law, Wisconsin was allowed to lower the age-of-youngest-child
                      exemption for the food stamp sanction from 6 years to 1 year of age for 3 years because the state had
                      previously submitted a waiver request to do so that had been denied.



                      Page 93                                           GAO/HEHS-97-74 Welfare Benefit Termination
Appendix VI
Overview of Waiver Programs in Iowa,
Massachusetts, and Wisconsin




a recipient would generally have to meet the program requirements for
new applicants in the diversion component—60 hours of participation in
JOBS—before becoming eligible to receive benefits again.


Wisconsin had contracted with MAXIMUS to conduct the required
evaluations of the Pay for Performance waiver program. Although the
contract was canceled after passage of federal welfare reform, a request
for funding from HHS to continue the evaluation was pending at the time of
our review. In addition, a broader study group, including the University of
Wisconsin, had been formed to evaluate the state’s comprehensive reform
effort, called Wisconsin Works, of which Pay for Performance is one part.
Phased-in implementation of Wisconsin Works began in October 1996, and
officials expected to have the program fully implemented by
September 1997.




Page 94                                GAO/HEHS-97-74 Welfare Benefit Termination
Appendix VII

Bases for Terminations Nationwide, by State



Table VII.1: Terminations as of June 30, 1996
                                                      Number of families with benefits terminateda
                                                              Due to failure to comply with
                                                            Child Teen parent                       Teen parent
                                                         support       school                             living                          Due to
                            Enrollment         Work enforcement attendance                         arrangement        Other           reaching a
State               Total requirements requirements requirements requirements                     requirements requirements            time limit
Arizona                66                                                                                       66
                         b                                                                                            b
Connecticut            11                                 2                 7                                                   2c
Florida                19                                                                                                                      19d
Iowa                4,174         3,756e               418e
Massachusetts       1,292                            1,036                                217f                  39g
Michigan             307                               307
Mississippi          279                               279
Missouri               73                                                                                       73
Nebraska                8                                 8
South Dakota         289                               289
Utah                   62                                59                 3
Vermont                 3                                 3
Virginia             985             191               390               362                                    42
Wisconsin           2,208          1,634               574
Total               9,776          5,581             3,365               372              217                 220               2              19

                                           a
                                            In some states, such as Massachusetts and Wisconsin, data represent cases in terminated
                                           status as of the date shown. In other states, such as Iowa and Connecticut, data represent
                                           cumulative totals that may include cases that have subsequently been reopened and may double
                                           count recipients in some cases.
                                           b
                                            Data do not include those cases terminated for failure to comply with teen living arrangement
                                           requirements, which are not tracked, according to the state official surveyed.
                                           c
                                               Terminations for failure to comply with fingerprinting requirements.
                                           d
                                            Of the 19 cases terminated upon reaching their time limit, 10 had complied and 9 had failed to
                                           comply with program requirements.
                                           e
                                               Based on state official’s estimates.
                                           f
                                            Does not include the 25 cases in which closure was for failure to comply with living arrangement
                                           requirement as well as failure to attend school.
                                           g
                                            Includes the 25 cases in which closure was for failure to attend school as well as failure to
                                           comply with living arrangement requirement.




                                           Page 95                                               GAO/HEHS-97-74 Welfare Benefit Termination
                                              Appendix VII
                                              Bases for Terminations Nationwide, by State




Table VII.2: Terminations as of December 31, 1996
                                                        Number of families with benefits terminateda
                                                                  Due to failure to comply with
                                                           Child Teen parent                        Teen parent
                                                        support       school                              living                            Due to
                           Enrollment         Work enforcement attendance                          arrangement        Other             reaching a
State              Total requirements requirements requirements requirements                      requirements requirements              time limit
Arizona               50                                                                                        50b
Connecticut          477c                               460                 12                                       c
                                                                                                                                  5d
                                                            e                                                        f
Delaware              68                                 15                 40                                   0               13g
Florida               74                                                                                                                            74h
                                          i                   i
Iowa               5,288          4,691                 597
Illinois               8              0                    8
Massachusetts      1,969                             1,708j                              235k                   26l
Michigan             765                                765
Missouri             279                                                                                      279
Mississippi          699                                699
Nebraska              59                                 59
                        m              n
North Carolina
                        m                                   n                 n
Ohio
Oregon                60o                                60o
South Dakota         413                                413
Utah                 180                                177p                 3q
Vermont                3                                   3
                                       r
Virginia           1,955            704                 390s              810t                                  51
Wisconsin          5,700          2,577              3,123
Total             18,047          7,972              8,477                865            235                  406                18                 74

                                              a
                                               In some states, such as Massachusetts and Wisconsin, data represent cases in terminated
                                              status as of the date shown. In other states, such as Iowa and Connecticut, data represent
                                              cumulative totals that may include cases that have subsequently been reopened and may double
                                              count recipients in some cases.
                                              b
                                               Data do not include those cases terminated for failure to comply with teen living arrangement
                                              requirements, which are not tracked, according to the state official surveyed. The most significant
                                              reason for the drop in terminations over time is because many teen parents become old enough
                                              to no longer have to meet living arrangement requirements.
                                              c
                                               Data do not include those cases terminated for failure to comply with teen living arrangement
                                              requirements (not tracked).
                                              d
                                              Terminations for failure to comply with fingerprinting requirements.
                                              e
                                               Of the 15, 6 cases terminated until the end of the demonstration project; 9 cases could still be
                                              reopened on the basis of compliance with requirement.




                                              Page 96                                             GAO/HEHS-97-74 Welfare Benefit Termination
Appendix VII
Bases for Terminations Nationwide, by State




f
 According to the official surveyed, provisions for terminating cases for failure to comply with teen
living arrangement requirement predated implementation of the waiver. Although the number of
cases terminated for this reason has not been tracked, the official believed it was probably zero.
g
 Other reasons included nine cases for failure to attend parenting classes; three cases for failure
to provide proof that children had been immunized; and one case for failure to attend a family
planning session.
h
 Of the 74 cases terminated upon reaching their time limit, 43 had complied and 31 had failed to
comply with program requirements.
i
    Based on state official’s estimates.
j
Includes a partial estimate for terminations due to noncompliance by dependent children aged
16 to 18.
k
 Does not include the 16 cases in which closure was for failure to comply with living arrangement
requirement as well as failure to attend school.
l
Includes the 16 cases in which closure was for failure to attend school as well as failure to
comply with living arrangement requirements.
m
 According to the official surveyed, families have had benefits terminated under waiver
provisions, but the number of cases terminated has not been tracked. Efforts are under way to
begin collecting such data.
n
 State’s waiver included provisions for terminating benefits on this basis, and, according to the
official surveyed, cases have been terminated. However, the number of cases terminated on this
basis has not been tracked.
o
 Number of cases terminated as of Nov. 15, 1996. According to the official surveyed, data as of
Dec. 31, 1996, were not yet available as this report went to press.
p
 May include some cases terminated for failure to comply with child support enforcement
requirements (see table note q).
q
 Number of cases terminated for failure to comply with child support enforcement requirements
as of June 30, 1996; data not tracked and could not be updated through Dec. 31, 1996,
according to the official surveyed.
r
    Does not include 23 cases that also had failed to comply with work requirements.
s
 State officials could not update the number of terminations based on failure to comply with work
requirements past June 30, 1996.
t
    Does not include three cases that also had failed to comply with work requirements.




Page 97                                              GAO/HEHS-97-74 Welfare Benefit Termination
Appendix VIII

Demographic Profile of Total Caseload
Compared With Terminated Cases Studied in
Iowa, Massachusetts, and Wisconsin

                                                                Iowa
                                                              Terminated cases studied
                                    Total statewide                                    Statewide -
                                              AFDC                                   no benefits or
                                          caseload                                        reported
                                             (1995)a    Statewide      Des Moines         incomeb
                Number of cases              36,435           408              77               56
                Household characteristics - percentc of cases with
                Number of
                children
                0-1                            48.4           39.7            44.2             46.4
                2                              32.1           34.8            26.0             30.4
                3                              13.5           16.7            18.2              7.1
                4 or more                       6.0            8.8            11.7             16.1
                Youngest child
                under age 1                    12.1            6.6             2.6             10.7
                age 1-2                        24.6           30.2            39.0             32.1
                age 3-5                        24.2           29.7            23.4             26.8
                age 6-11                       25.4           24.5            28.6             19.6
                age 12-15                       9.6            6.6             3.9              8.9
                age 16-18                       3.9            2.4             2.6              1.8
                Length of current
                stay
                0-6 mos.                       25.4            0.7             0.0              0.0
                7-12 mos.                      12.9           21.3            22.1             19.6
                13-24 mos.                     18.5           23.0            22.1             17.9
                25-36 mos.                      9.1           14.9             7.8             16.1
                37-48 mos.                      7.0           15.7            11.7             10.7
                49-60 mos.                      5.9           24.3            36.4             35.7
                over 60 mos.                   21.3            0.0             0.0              0.0
                Head-of-household characteristics - percentc of cases with head of household
                Under age 20                    6.7            6.4             5.2              5.4
                age 20-29                      48.5           51.7            48.0             62.5
                age 30-39                      36.1           33.8            42.9             32.1
                40 and over                     8.8            8.1             3.9              0.0
                Female                         85.7           84.3            89.6             82.1
                Nonwhite                       16.7           12.1            21.1              5.4




                Page 98                                  GAO/HEHS-97-74 Welfare Benefit Termination
                                    Appendix VIII
                                    Demographic Profile of Total Caseload
                                    Compared With Terminated Cases Studied
                                    in Iowa, Massachusetts, and Wisconsin




                   Massachusetts                                                              Wisconsin
                        Terminated cases studied                                               Terminated cases studied
                                                 Statewide - Total statewide                                               Statewide -
Total statewide                                no benefits or          AFDC                                              no benefits or
AFDC caseload                                       reported       caseload                                                   reported
         (1995)a   Statewide       Boston           incomeb           (1995)a           Statewide       Milwaukee             incomeb
        100,852         936             196               138              72,366               759              280                 123




           45.5         53.4            61.7              68.1                40.8             39.1             38.6                 51.2
           31.3         29.0            21.0              19.6                28.9             29.9             28.2                 26.8
           15.7         11.4            12.2               6.5                17.0             19.5             21.4                 15.4
            7.6          6.2             5.1               5.7                13.3             11.5             11.8                  6.5

            9.6          3.6             3.1               5.1                18.4              2.6              2.9                  4.1
           25.3         22.0            19.9              38.4                28.2             32.0             30.4                 22.8
           26.6          7.1            10.7              11.6                21.0             29.8             27.1                 26.0
           24.0         37.0            31.1              26.8                21.1             23.2             24.3                 23.6
           11.8         18.5            20.9               8.7                 7.8              8.8             11.1                 13.0
            2.6         11.8            14.3               9.4                 3.6              3.6              4.3                 10.6


           17.0         45.7            45.9              46.4                24.9             30.7             32.5                 30.9
           11.9         16.9            16.8              13.0                11.6             20.2             16.4                 31.7
           15.1         13.9            12.7              20.3                20.6             19.0             17.1                 18.7
           13.4          5.6             4.6               5.8                12.4             12.1             11.0                  8.9
           10.4          3.2             2.6               2.2                 7.7              6.6              7.9                  5.7
            9.2          3.5             4.1               3.6                 7.0              4.3              5.7                  0.0
           23.0         11.2            13.3               8.7                15.8              7.1              9.3                  4.1


            5.7         18.9            19.9              38.4                 6.2              2.4              1.4                  2.4
           43.8         19.8            16.8              25.4                50.6             50.1             49.6                 43.9
           37.1         39.8            38.8              23.2                32.4             36.2             36.0                 37.4
           13.5         21.5            24.5              13.0                10.7             11.3             12.9                 16.3
           90.5         87.8            85.7              88.4                88.5             92.2             90.4                 83.7
           55.0         57.6            82.7              55.8                56.6             45.6             80.4                 45.6
                                    a
                                     These data are from Characteristics and Financial Circumstances of AFDC Recipients - Fiscal
                                    Year 1995, HHS (Washington, D.C.: June 1996). Number of children data are from table 6. Age of
                                    youngest child data are from table 11. Length of current stay data are from table 12. Age of
                                    head-of-household percentages calculated on the basis of combined figures from table 21.1
                                    (mothers aged 11-17), table 22 (adult female recipients), and table 25 (adult male recipients). Sex
                                    of head-of-household percentages calculated on the basis of combined figures from tables 22
                                    and 25. Race of head-of-household data are from table 10 (race of natural or adoptive parent).
                                    b
                                     Data on demographic characteristics not broken down for “No benefits or reported income”
                                    category for cases studied in selected urban areas due to the small number of cases in the
                                    category: Des Moines, 16; Boston, 37; and Milwaukee, 50.
                                    c
                                     Percentages exclude unknowns, which were generally less than 1 percent, except for race.
                                    Unknown percentages for race ranged from 0 to 8.4 percent.




                                    Page 99                                           GAO/HEHS-97-74 Welfare Benefit Termination
Appendix IX

Massachusetts Data on High School, Work
Experience, and Primary Language


                                                                 Terminated cases studied

                             Total                                                            Statewide - no benefits or
                        statewide           Statewide                      Boston                   reported income
                            AFDC                 Noncompliance               Noncompliance                  Noncompliance
                        caseload                      with work                    with work                     with work
                      (Feb. 1996) All reasons      requirements All reasons     requirements All reasons      requirements
Number of cases           87,945          936             680          196              138          138                 67
Percent of cases with head of household
Not completing
high school or
equivalent                  49.6        65.3              54.1        65.8              52.9         71.0              46.3
Not working in last
10 years                    41.5        47.4              42.4        51.0              43.5         45.7              34.3
Primary language
not English                 18.4        21.9              23.5        23.5              25.4         27.5              31.3




                                           Page 100                               GAO/HEHS-97-74 Welfare Benefit Termination
Page 101   GAO/HEHS-97-74 Welfare Benefit Termination
Appendix X

Reported Income and Benefits Received by
Terminated Cases Studied in Iowa,
Massachusetts, and Wisconsin

                                                                Iowa
                                              Total cases       Des Moines         Rest of state
                                               statewide             cases               cases
              Number of terminated
              cases                                  408                  77                331
              Number of cases
                                                         a                    a                a
              reopened
              Number of cases
              remaining closed                       408                  77                331
              Of cases remaining closed, percent with reported income fromb
                Wages                                30.4               24.7               31.7
                Pensionsd                                e                    e                e

                Child support                        19.1               14.3               20.2
              Of cases remaining
              closed, percent with any
              of the above reported
              income                                 42.9               33.8               45.0
              Of cases remaining closed, percent receiving other non-AFDC benefits from
                Food stamps                          60.8               55.8               61.9
                SSI                                   9.8               18.2                 7.9
                Housing                              27.2               24.7               27.8
                                                         f                    f                f
                General assistance
              Percent receiving any of
              the above non-AFDC
              benefits                               71.8               71.4               71.9
              Of cases remaining
              closed, percent with
              active Medicaid status                 54.4               45.5               56.5
              Percent receiving any of
              the above non-AFDC
              benefits, including
              Medicaid                               74.3               74.0               74.3
              Percent with any of the
              above non-AFDC benefits,
              including Medicaid, or
              reported income                        86.3               83.1               87.0
              Percent with none of the
              above non-AFDC benefits
              or reported income                     13.7               16.9               13.0




              Page 102                                GAO/HEHS-97-74 Welfare Benefit Termination
                                   Appendix X
                                   Reported Income and Benefits Received by
                                   Terminated Cases Studied in Iowa,
                                   Massachusetts, and Wisconsin




                  Massachusetts                                                    Wisconsin
Total statewide           Boston          Rest of state       Total statewide            Milwaukee         Rest of state
          cases            cases                cases                   cases                cases               cases

           936               196                   740                    759                   280                 479

           300                65                   235                    108                     70                 38

           636               131                   505                    651                   210                 441


          23.0              22.9                   23.0                   31.5c                 27.1c              33.6c
                                                                              e                     e                  e
          16.0               6.1                   18.6
          16.4               9.9                   18.0                   24.0                  13.8               28.8



          48.3              38.2                   50.9                   47.2                  38.1               51.5


          25.6              20.6                   26.9                   39.3                  34.8               41.5
          12.7              10.7                   13.3                   12.6                  10.5               13.6
          26.4              33.6                   24.6                   22.1                  16.7               24.7
                                                                              g                     g                  g
            0.3              0.0                    0.4


          47.3              50.4                   46.5                   57.6                  51.9               60.3


          58.5              52.7                   60.0                   53.5                  44.8               57.6



          75.5              73.3                   76.0                   75.4                  69.0               78.5



          78.3              73.3                   79.6                   81.1                  76.2               83.4


          21.7              26.7                   20.4                   18.9                  23.8               16.6




                                   Page 103                                   GAO/HEHS-97-74 Welfare Benefit Termination
Appendix X
Reported Income and Benefits Received by
Terminated Cases Studied in Iowa,
Massachusetts, and Wisconsin




Note: See app. I for details on scope and time frames of cases studied in each state.
a
 Not applicable, as data analysis was conducted before 6 months had elapsed, the minimum
time period required in Iowa before an AFDC case could be reopened.
b
 Families not applying for, or receiving, AFDC or other benefits were not required to report their
wages or other income. In addition, once no longer receiving AFDC, some families may receive
child support payments privately, which they are not required to report to the state and local
offices of Child Support Enforcement, where we obtained our data. For these reasons, the figures
on wage, pension, and child support income are likely to be understated.
c
These figures may include other income, such as from pensions.
d
    Includes Social Security, Veterans’ Benefits, and employment-related pensions.
e
No data available.
f
 In Iowa, the general assistance program was administered at the county level, and statewide
data were not available.
g
 Not applicable. Wisconsin discontinued its statewide general assistance program in Jan. 1996,
though some counties have programs.




Page 104                                            GAO/HEHS-97-74 Welfare Benefit Termination
Appendix XI

Average Benefits, Child Support Payments,
and Unemployment Rates in States
Terminating Benefits Under Waivers

                                                                     Housing                                   Child
                           AFDC Food stamp                        assistance              Fuel               support
                        average    average SSI average               average      assistance                 average
                        monthly    monthly     monthly             maximum average annual                   monthly
                   grant amount     benefit     benefit              monthly      household                 payment Unemployment
State                     (1995)a   (1995)b     (1996)c        benefit (1996)d benefit (1995)e                (1995)f  rate (1995)g
Arizona                   $293           $202          $347                $508                 $163             $235                  5.1
Connecticut                523            141           355                  730                 411              266                  5.5
Delaware                   301            187           328                  549                 194              169                  4.3
Florida                    263            178           342                  518                  92              194                  5.5
Illinois                   317            172           378                  407                 267              235                  5.2
Iowa                       371            154           310                  401                 197              290                  3.5
Massachusetts              551            152           342                  701                 348              334                  5.4
Michigan                   413            165           372                  442                 182              334                  5.3
Mississippi                122            174           308                  363                 150              156                  6.1
Missouri                   273            172           332                  361                 187              288                  4.8
Nebraska                   317            150           318                  377                 173              283                  2.6
North Carolina             243            159           299                  435                  80              199                  4.3
Ohio                       313            155           369                  427                  97              292                  4.8
Oregon                     394            155           342                  493                 215              268                  4.8
South Dakota               331            181           300                  401                 394              207                  2.9
Utah                       371            173           346                  446                 219              246                  3.6
Vermont                    510            146           300                  533                 281              272                  4.2
Virginia                   273            163           319                  493                 174              138                  4.5
Wisconsin                  465            161           334                  424                 300              226                  3.7
                                                                                 h
National average           378            172           339                                      172              238                  5.6

                                     a
                                      Average monthly AFDC payment for a family with two children. (Source: Table 34 in
                                     Characteristics and Financial Circumstances of AFDC Recipients - Fiscal Year 1995, HHS
                                     (Washington, D.C.: June 1996)).
                                     b
                                      Average monthly value of the food stamp benefit in dollars. (Source: Table 6 in Characteristics of
                                     Food Stamp Households: Fiscal Year 1995, (Advance Report) U.S. Department of Agriculture
                                     (Washington, D.C.: Oct. 1996)).
                                     c
                                      Average monthly federal SSI payment, Dec. 1996. (Source: Social Security Administration, Office
                                     of Research and Statistics.)




                                     Page 105                                           GAO/HEHS-97-74 Welfare Benefit Termination
Appendix XI
Average Benefits, Child Support Payments,
and Unemployment Rates in States
Terminating Benefits Under Waivers




d
 The unweighted average of the fair market rent for a two-bedroom unit as of Feb. 22, 1996,
established by Department of Housing and Urban Development (HUD) housing authorities for
each county in the state. HUD will pay up to the fair market rent for a subsidized family, less the
“total tenant payment,” which is based on the family’s gross income, less specified deductions.
(Deductions include $480 for each dependent, $400 for any elderly family or a person with a
disability, and some medical deductions.) The formula used in determining the tenant payment is
the highest of (1) 30 percent of monthly income (including AFDC cash payments) less
deductions; (2) 10 percent of monthly income; (3) welfare rent, if applicable; or (4) a $25 minimum
rent or higher amount (up to $50) set by the housing authority. Therefore, a family losing AFDC
benefits with no other income would fall into this last category and be eligible to receive a housing
subsidy up to the amount of the fair market rent minus the minimum rent payment set by the
housing authority.
e
 Generally includes only heating assistance provided during winter months under the
Low-Income Home Energy Assistance Program (LIHEAP) during fiscal year 1995. The program
also provides cooling assistance, and winter and summer crisis assistance. According to the
program official contacted, income standards for the program are fairly high, and AFDC families
were likely to receive amounts greater than the amounts indicated here. (Source: HHS,
Administration for Children and Families, Fiscal Year 1995 Summer LIHEAP Telephone Survey
Results, Mar. 1996.)
f
 Based on preliminary data reported by the states: total collections divided by total cases with
collections, monthly average. (Source: Child Support Enforcement FY 1995 Preliminary Data
Report, HHS (Washington, D.C.: May 1996)).
g
 Percent unemployed in the civilian labor force in 1995. (Source: Statistical Abstract of the United
States - 1996, U.S. Department of Commerce, Bureau of the Census (Washington, D.C.:
Oct. 1996)).
h
 According to a HUD Issue Brief, HUD Reinvention From Blueprint to Action, HUD (Washington,
D.C.: Mar. 1995), the average cost of serving families through housing certificates nationwide was
$440 per month; and the average cost of a public housing subsidy nationwide was $481 per
month based on fiscal year 1995 appropriations.




Page 106                                           GAO/HEHS-97-74 Welfare Benefit Termination
Appendix XII

AFDC Caseload Participation in Selected
Programs in States Terminating Benefits
Under Waivers

                                                          AFDC caseload
                                                       Percent                           Percent receiving       Percent
                                                receiving food             Percent                housing receiving child
State             Number            Percent            stamps        receiving SSIa           assistanceb       supportc
Arizona            69,609                100                 92.1                 3.1                    15.1                 0.2
Connecticut        60,985                100                 88.7                 3.2                    33.0                10.7
Delaware           10,775                100                 83.6                 3.1                    36.4                11.4
Florida           230,807                100                 93.6                 6.0                    15.4                 2.0
Illinois          236,205                100                 93.7                 8.5                    19.5                 0.5
Iowa               36,435                100                 88.3                 5.1                    26.8                11.8
Massachusetts     100,852                100                 78.6                 4.9                    33.7                 8.7
Michigan          201,696                100                 94.4                10.4                    10.5                 1.6
Mississippi        52,528                100                 93.5                13.4                    22.5                12.3
Missouri           89,289                100                 89.9                 6.8                    25.3                 8.6
Nebraska           14,828                100                 86.4                 6.5                    36.6                 1.2
North Carolina    125,503                100                 77.7                10.9                    23.7                12.0
Ohio              228,171                100                 91.3                 9.2                    25.3                 8.4
Oregon             39,264                100                 91.1                 1.4                    17.5                 9.7
South Dakota        6,286                100                 83.7                 6.9                    27.5                 8.8
Utah               16,648                100                 85.9                 0.7                    25.6                11.9
Vermont             9,648                100                 97.7                 0.7                    21.7                11.2
Virginia           72,147                100                 86.6                 7.7                    28.9                 7.5
Wisconsin          72,366                100                 85.5                 9.8                    15.1                 4.1
U.S. total       4,873,398               100                 89.8                 5.4                    20.1                 4.8
                             a
                             Data for SSI also include workers compensation.
                             b
                              Data include families in public housing or receiving a HUD rent subsidy. Families receiving other
                             rent subsidies were not included.
                             c
                              At the time of our review, states were required to pass through to AFDC recipients up to $50 per
                             month of child support collected by the state from absent parents. This pass-through requirement
                             was eliminated under the new federal welfare reform law.

                             Source: Characteristics and Financial Circumstances of AFDC Recipients - Fiscal Year 1995, HHS
                             (Washington, D.C.: June 1996). Food stamps data are from table 5; housing assistance data are
                             from table 4; and child support data are from table 42; SSI data are from tables 33 and 42.
                             According to the program official contacted, table 42 includes only adults on SSI and must be
                             combined with the number of children on SSI from table 33 for the approximate total number of
                             families with an SSI recipient.




                             Page 107                                          GAO/HEHS-97-74 Welfare Benefit Termination
Appendix XIII

GAO Contacts and Staff Acknowledgments


                  David P. Bixler, Assistant Director, (202) 512-7201
GAO Contacts      Margie K. Shields, Evaluator-in-Charge, (415) 904-2228


                  The following individuals also made important contributions to this report:
Staff             Donald J. Porteous conducted the analysis of automated data, led the
Acknowledgments   fieldwork in Wisconsin, and coauthored the draft; Andrew Sherrill
                  conducted the analysis of waivers; and Christina L. Warren led the
                  fieldwork in Iowa.




                  Page 108                             GAO/HEHS-97-74 Welfare Benefit Termination
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Page 110                              GAO/HEHS-97-74 Welfare Benefit Termination
Bibliography




Page 111       GAO/HEHS-97-74 Welfare Benefit Termination
Related GAO Products


              Welfare Reform: Three States’ Approaches Show Promise of Increasing
              Work Participation Rates (GAO/HEHS-97-80, forthcoming report).

              Welfare Waivers Implementation: States Work to Change Welfare Culture,
              Community Involvement, and Service Delivery (GAO/HEHS-96-105, July 2,
              1996).

              Employment Training: Successful Projects Share Common Strategy
              (GAO/HEHS-96-108, May 7, 1996).

              Welfare to Work: Approaches That Help Teenage Mothers Complete High
              School (GAO/HEHS/PEMD-95-202, Sept. 29, 1995).

              Welfare to Work: Child Care Assistance Limited; Welfare Reform May
              Expand Needs (GAO/HEHS-95-220, Sept. 21, 1995).

              Welfare to Work: State Programs Have Tested Some of the Proposed
              Reforms (GAO/PEMD-95-26, July 14, 1995).

              Welfare to Work: Most AFDC Training Programs Not Emphasizing Job
              Placement (GAO/HEHS-95-113, May 19, 1995).

              Welfare Dependency: Coordinated Community Efforts Can Better Serve
              Young At-Risk Teen Girls (GAO/HEHS/RCED-95-108, May 10, 1995).

              Welfare to Work: Participants’ Characteristics and Services Provided in
              JOBS (GAO/HEHS-95-93, May 2, 1995).


              Welfare to Work: Measuring Outcomes for JOBS Participants (GAO/HEHS-95-86,
              Apr. 17, 1995).

              Child Care: Recipients Face Service Gaps and Supply Shortages
              (GAO/HEHS-95-96, Mar. 1, 1995).

              Community Development: Comprehensive Approaches Address Multiple
              Needs but Are Challenging to Implement (GAO/RCED/HEHS-95-69, Feb. 8, 1995).

              Child Care: Child Care Subsidies Increase Likelihood That Low-Income
              Mothers Will Work (GAO/HEHS-95-20, Dec. 30, 1994).

              Welfare to Work: Current AFDC Program Not Sufficiently Focused on
              Employment (GAO/HEHS-95-28, Dec. 19, 1994).



(106611)      Page 112                             GAO/HEHS-97-74 Welfare Benefit Termination
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