June 25, 2010

Mr. Clarence Carter

Director, Department of Human Services
District of Columbia Department of Human Services
64 New York Avenue NE, 6th Floor
Washington, DC 20002

Dear Mr. Carter,

Thank you very much for sponsoring a series of roundtables with advocates and other
stakeholders to discuss a redesign of the Temporary Assistance for Needy Families (TANF)
Employment Program. We appreciate your willingness to improve the services provided to TANF
families and to involve a variety of groups in this process. As you begin to plan the redesign, we, the
undersigned groups, would like to share our recommendations for ensuring that more TANF
families receive individualized services tailored to their unique needs. Our vision for an improved
TANF program includes the following basic principles.

 The foundation of a successful TANF program is an individualized assessment of the

strengths and needs of each TANF recipient. Currently, most TANF recipients do not
receive a thorough assessment that would identify the services that would be most appropriate
for them. In order to begin the process of addressing the needs of TANF recipients, the
District needs to perform a comprehensive assessment. This process should be completed by
someone with the skills and knowledge to identify barriers that may not be readily apparent.
Additionally, TANF recipients who encounter barriers as they participate in TANF should be
able to be reassessed.

 Once assessments are completed, the District must ensure that there are a range of
services that recipients can access. Moving forward, it is crucial for the Income
Maintenance Administration (IMA) to identify education, training, and other services that will
help both employable and non-employable recipients engage in productive activities.
Furthermore, the agency must ensure that recipients and staff of the agency and vendors know
how to help recipients access these services. It also will be important that the next round of
contracts provide the vendors with incentives to spend the time to match clients with the
services they need, rather than placing recipients in jobs that are not necessarily appropriate.

 Recipients should be motivated to participate in the TANF program because it meets

their needs and shows a path to financial security, not because of the threat of
termination of benefits. Through the process of individualizing the program and ensuring
access to quality services, we believe that the TANF program can start to improve credibility
among recipients. By improving assessments and placements for recipients according to their
need for services, programs can focus their resources on serving individuals who are able to
participate with assistance. Additionally, by providing comprehensive case management to
recipients from the time of their assessment through their leaving welfare for work, the District
can also help families stay connected to the program. Finally, by ensuring that there are
linkages with quality programs in TANF recipients’ neighborhoods, these communities will
become more invested in the success of the program.

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  Terminating benefits to families who do not, or cannot, comply with TANF
requirements is not an effective way to motivate families to participate in work
activities. Studies have shown that sanctioned families are likely to suffer from multiple,
severe barriers to work that keep them from being able to comply with work requirements.
Additionally, studies show that full family sanctions harm children and their parents by
increasing stress and financial hardship.

 The District should design a program that will improve outcomes for recipients and
allow more of them to achieve self-sufficiency despite the limited flexibility of federal
law and budgetary pressures. We believe that if the District designs its TANF program to
advance the principles discussed above, more families will be able to overcome barriers and
either work or participate in federally-approved work activities. However, it is undeniable that
the District must contend with current federal work requirements adopted in 2006 that are
overly stringent or even unrealistic. It is also true that the District’s current budget shortfalls
would make proposals for vast new spending similarly unrealistic.

However, instead of scaling back its vision for long-term success, we would encourage the
District to create a program that would provide the individualized assessment and quality
services needed through linkages with current programs that are working, modifications to
policies, and pursuit of existing funding opportunities. There are ways of modifying the
District’s program and policies to increase work rates in ways that invest in recipients’ long-
term potential. For example, the District can count participation in vocational education as a
countable work activity. There are also ways that the District could take better advantage of
available funding to invest in hiring additional and better trained staff. Also, the money that is
currently being used for the vendor contracts could be reallocated to support this more
individualized approach.

Assessing and Referring TANF Recipients to Appropriate Activities

Many DC TANF recipients face multiple barriers to work including a lack of work experience,
low literacy levels, domestic violence, and physical and mental health challenges. However,
currently, too many DC residents are not getting the help they need to address their barriers to
work. For example, while an estimated 20 percent of TANF recipients struggle with mental health
issues, in FY 2008 only about 2 percent of TANF recipients were referred to the POWER program,
which is designed to help TANF recipients with physical and mental health and substance abuse
issues.

Part of the challenge is the way that assessments currently are conducted. TANF recipients are
supposed to be assessed twice – once when they apply for TANF and again when they are referred
to an employment vendor. In both cases, specialized staff members usually are not performing the
assessments. At the service centers, the same workers who determine eligibility for benefits also are
required to screen participants. At the employment vendors, organizations are not required to use a
uniform assessment or employ specialized staff with experience in assessing recipients’ barriers to
work. As a result, many recipients are not being assessed at all or are assessed but not connected to
the services they need.

Another challenge is the lack of pathways that exist for TANF recipients to receive education and
job training services. Currently, nearly all TANF applicants who apply for benefits are referred

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randomly to an employment vendor – all of which are required to provide only the most basic job
readiness and job placement assistance. In the focus groups DCFPI and SOME, Inc. conducted
with TANF recipients last year, most recipients said that they were unaware of the other programs
offered by TANF and were unaware that they could go to job training and educational services
outside of the employment vendors.

For the TANF program to work, we must acknowledge that there are at least three broad groups
of TANF recipients and that individual recipients may move back and forth among these groups:

 Otherwise employable individuals who need some limited assistance and supports (such as
transportation, child care subsidies, and job placement assistance) to find and keep a job;

 Individuals who are not yet employable who need more intensive assistance and supports (such
as basic education, job skills training, subsidized work opportunities, internships, life skills
training, and accommodations for disability, domestic violence, or other challenges) in order to
become employable; and

 Individuals who will not be employable in the short term due to one or more significant barriers
to work including the need to care for a sick child or a child with a disability, domestic violence,
or illiteracy.

Different strategies and services are needed to respond to the needs of each group. In order to help
more TANF recipients transition successfully from welfare to work, it is important to know their
barriers to work, strengths, and employment goals. As IMA works to improve its assessment and
referral process, it should:

 Consolidate the upfront assessment process and employ specialized staff to conduct
assessments. IMA should hire specialized staff or contract with an outside organization to
provide an assessment for TANF recipients before they are referred to a vendor, social service
provider, or other training organization. IMA also should ensure that the assessment is
accessible to TANF recipients who speak languages other than English.

 Provide more job training, education, and supportive services pathways for TANF
recipients beyond the one-size-fits-all vendor approach. Developing more pathways will
allow the assessment to be used to direct TANF recipients to the appropriate mix of services.
Recommendations for specific pathways and services are included in the following section.

 Provide an effective orientation so that TANF recipients know their options and the
services available to them. The orientation should include oral and written information
about the job training, education, and supportive services pathways available to TANF
recipients as well as information about exemptions and programs, like POWER, that are
available to help recipients with barriers to work.

 Provide ways for TANF recipients to be both formally and informally assessed and
referred to additional services as needs arise. This should include developing a mechanism
to flag and follow-up with recipients who are at vendors or training for long periods of time or
who repeatedly cycle onto the TANF program. This mechanism should allow TANF recipients
to be reassessed and referred to more appropriate services.

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Providing More Pathways to Job Training, Education, and Supportive Services

In order to meet the goals of a person-centric approach, a broad array of job training, job
placement, and education services is essential. With a comprehensive, high-quality assessment, staff
will be able to make referrals to a mix of services appropriate to individuals’ needs. But improved
assessments alone will not improve outcomes for recipients. Quality services are needed. These
services should include:

 Work First: For TANF recipients who are employable and are interested in immediate
employment, a pathway similar to the current vendor model would be helpful. In the new
contract, IMA should ensure that organizations have the capacity and the relationships with
employers to place recipients in jobs with career ladders and sustainable wages and support
them during their initial months of employment.

 Training: This pathway should be targeted to TANF recipients who are employable and have
an interest and reasonable chance of success in a sector-based, hard skills training program that
will improve their employment and earnings prospects. IMA could contract with specific
organizations with a proven record of success in training and placing TANF recipients and
provide a voucher program to allow recipients to choose among a variety of certified hard skills
training programs based on their skills, needs, and goals.

 Alternative Paths to Work: This pathway is designed for TANF recipients who are able to
work, but may need an alternative path to get there. A mixture of supportive services, training,
and modified work requirements should be provided to allow recipients to participate in
contextual basic education, part-time work, sessions with a ―life coach,‖ and/or case
management.

 Supportive Services: All TANF recipients with significant barriers to work (e.g. mental and
physical health issues, domestic violence, substance abuse, and learning disabilities) would
benefit from quality supportive services. For some, who cannot currently find and keep a job
because of a barrier, an exemption from the work requirements is also appropriate. However,
when provided with these services, other recipients may be able to work. Services could be
provided by referrals to community organizations and/or to DC government agencies, such as
APRA, DMH, and RSA.

The new contracts should provide appropriate incentives to ensure that the vendors will refer
recipients to appropriate services instead of, or in addition to, providing job placement assistance.

Engaging More TANF Recipients in Work Activities

Currently, only a small portion of DC’s TANF recipients are participating in countable work
activities. This problem is not unique to the District and partly reflects the narrow set of countable
activities set in the federal TANF law. Nevertheless, efforts to encourage more DC TANF
recipients to engage in work activities is important, both to meet the federal rules and to ensure that
recipients are making progress toward improved self-sufficiency.

Connecting recipients to high-quality services that are appropriate to their individual needs is a
promising first step. Programs that assist people who are job ready can focus more of their

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resources on job development, outreach to employers and facilitation of training opportunities if
more people who are not job ready have been referred to more intensive and appropriate services.

Another way to promote engagement is to provide comprehensive case management

throughout the entire time of a family’s receipt of TANF benefits. Through this case management,
recipients with a mix of challenges that make it difficult to involve them in work activities can be
better identified and referred to appropriate services and activities. Case management will also help
recipients who can participate have a place to go when they encounter difficulties or just need extra
support for participation.

Finally, engaging neighborhood-based organizations in the TEP redesign also could help DHS
reach TANF recipients who receive assistance from these organizations but are no longer
participating in the TANF program’s services. DHS could work with community-based
organizations to develop an outreach plan to reassess and reengage more TANF recipients in the
program.

Full Family Sanctions Are Not an Effective Motivator

The undersigned believe strongly that the District can motivate and support families who are able
to participate in work activities by redesigning its program and using the sanction authority that the
District already possesses. Strong programs, helpful services, and community investment can help
engage more TANF recipients without simultaneously hurting their families.

We believe that the District should not adopt full-family sanctions for families that do not meet
work requirements. Full-family sanctions have not been shown to help families move toward self-
sufficiency. Instead, they have been shown to push vulnerable families deeper into poverty.
Research shows that sanctioned families typically are families that face significant barriers to
participation. Several analyses of sanctioned welfare recipients show that sanctioned families have
lower levels of education than non-sanctioned participants, higher incidents of health related barriers
to work — including mental health problems and domestic violence — and had less work
experience than non-sanctioned families.1 Other studies show that the more barriers a family faces,
the greater the likelihood that they will be sanctioned.2

Instead of motivating families who are choosing not to participate, full family sanctions cause
hardship for already struggling families. The authors of a survey of research on sanctioned families
concluded, ―[s]anctioned recipients are more likely to experience material hardships than their non-
sanctioned counterparts. Material hardships TANF recipients face include borrowing money to pay
bills or falling behind on payments, not having enough food, problems paying for medical care, and
experiencing a utility shut-off.‖3

The burden of full family sanctions are felt particularly by children. One study found that infants
and toddlers in sanctioned families had a 30 percent greater risk of having been hospitalized since

1
Marcia Meyers, et al., Review of Research on TANF Sanctions. (University of Washington, West Coast Poverty
Center, June 2006); Heidi Goldberg and Liz Schott, A Compliance-Oriented Approach to Sanctions in State and
County TANF Programs. (Center on Budget and Policy Priorities, Oct. 1, 2000).
2
Meyers, et al. (2006).
3
LaDonna Pavetti, Review of Sanction Policies and Research Studies (Mathematica Policy Research 2003).

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birth and a 90 percent greater risk of being admitted to the hospital after visiting the emergency
room.4 Another study found that preschoolers and adolescents in sanctioned families were at a
greater risk for behavioral problems and lower test scores than children in families that hadn’t been
sanctioned.5

Working Within Existing Federal Law

Changes to the federal TANF law in 2006 made it increasingly hard for states to meet the
requirement to have a specified share of TANF recipients engaged in work activities. Moreover, the
focus of federal rules on a ―work first‖ approach made it nearly impossible to find ways to provide
appropriate services to families with multiple barriers while also meeting the work rates.

As the District modifies its TANF services, it should focus primarily on designing services that
will help families move ahead, even if they will not be countable activities for the federal work
requirements. There are some steps the city can take to move families into countable activities, but
it is likely the city will need to rely on locally funded programs outside of TANF or MOE funds – as
most states have done – to provide useful services while also meeting the federal work rates.

Federal Changes Adopted in 2006 Make it Harder to Meet Work Rates

In early 2006, Congress enacted changes to TANF in the Deficit Reduction Act (DRA) that
effectively increase the proportion of assistance recipients that states must have participating in work
activities for a specified number of hours each week. HHS has since issued TANF rules that make it
more difficult for states to meet these increased work participation requirements. Prior to 2006, for
example, some states used programs funded with local funds – the so-called TANF ―maintenance-
of-effort‖ or MOE funds – to fund education programs that would last more than a year, because
federal rules allow education as a countable work activity for only a year. Since 2006, using MOE-
funded programs is no longer an option to provide such services, because the federal work rules
apply to MOE-funded programs.

As a result, the District and many states face a tension between initiating or continuing programs
that are effective in addressing the range of employability needs of TANF families and creating
programs that focus more narrowly on those activities that can count toward federal work rates,
even when these ―countable‖ activities are not a good match for some families.

Some Ways to Meet Families Needs within Countable Work Activities

The final regulations for the 2006 TANF changes give the District some opportunities to provide
services that meet the needs of families with barriers.

 Using “Excess MOE” to reduce the District’s required work rate. Federal TANF rules
allow states to reduce the work participation rate they are expected to meet – that is, the share
of TANF recipients in countable work activities – if they have local MOE expenditures that

4
Meyers, et al. (2006) (citing Children’s Sentinel Nutrition Assessment Program, Pediatricians Find TANF
Sanctions Put Young Children at Risk (2005)).
5
Meyers, et al. (2006) (citing P. Lindsey Chase-Lansdale, et al., Welfare Reform: What About the Children.
Policy Brief 02-1. (Welfare Children, and Families: A Three State Study, Johns Hopkins University, 2002)).

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 exceed the required level. Only certain excess MOE expenditures count for this purpose –
those spent on families receiving TANF cash assistance or similar kinds of TANF assistance.
The District should identify all programs and services that may qualify as excess MOE.

 Reclassify Financial Education as a Countable Activity. Other states looking to prepare

TANF recipients to transition successfully to work have classified basic financial literacy and
budgeting classes as a countable work activity, as provided for under federal law. Budgeting for
expenses like transportation, child care, and taxes is immediately applicable to entering the
workforce and increases the likelihood of job retention. Additionally, poor credit can be a
barrier to work for recipients, so credit counseling could also be considered a work readiness
activity. DHS should refer to TANF system reforms implemented in Indiana and Illinois to
connect welfare recipients with financial education and savings incentives.

 Making Use of Opportunities in Federal Law to Provide Vocational Education and

Other Educational Services as Countable Work Activities. Federal law allows TANF
recipients to participate vocational education as a countable work activity for 12 months. This
can include basic education, ESL programs, certificate programs, two-year community college
degrees, or bachelor’s degrees. Time spent on homework for these activities also counts. This
flexibility would allow the District to provide a variety of educational activities and count
recipients who participate in them towards the work participation rate for 12 months.
Additionally, other educational activities could also be counted towards federal work
participation rates as long as the individual was also participating in a work or work-like activity.
While this approach might not work for all families, there could be some who would benefit
from combining education and work activities.

 Find Ways to Keep More Working Families within TANF: A number of states have
provided transitional TANF cash assistance to families that find work while on TANF. Not
only does this help these families, it also would help the District meet the federal work rate,
since many of the families receiving this aid would be meeting the federal work requirements.
Even a modest transitional benefit would help families and help the city meet work
participation rates.

Using Solely State Funded Programs to Meet Other Needs

The steps outlined above may help the District meet the federal work rates, but they are unlikely
to be sufficient. For that reason, the city should continue the practice of serving some families
outside of TANF, using a ―solely state funded‖ program supported with state funds that will not be
reported as MOE. More than half of states operate such programs to allow them to provide
services that are helpful but cannot be counted as a federally-approved work activity. It may make
sense for the District to place some families in tracks that are funded entirely with local non-MOE
funds. This would be administratively simple and would acknowledge a choice by the city to relieve
families of participating in the narrow range of countable TANF work activities so that they can be
placed in services that better meet their needs.

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Funding Recommended Changes to DC’s TANF Program

There are several sources of funding that can be used to support the recommended improvements
to the TANF program, including:

 Existing TEP and PATHS program contracts ($15 million): The District already is
spending $15 million in its TANF program for job readiness and job placement. Given that the
TEP vendor contracts expire at the end of this year, at least a portion of these funds can be
redirected to support the development of a variety of job training, education, and supportive
services pathways for TANF recipients.

 TANF Emergency Contingency Fund ($46 million): The American Reinvestment and
Recovery Act of 2009 provided additional funding to states to help them manage rising TANF
caseloads. States can apply for funding of up to 50 percent of their federal block grant to
reimburse increased expenses in the areas of basic assistance, subsidized employment, and
short-term non-recurring benefits.

As of May 2010, the District had received about $23 million from the fund and had applied for
the remaining $23 million it is eligible for under the legislation. A portion of this funding
should be used to fund pilot training, education, home visiting, and other programs to help
identify successful strategies for engaging and connecting TANF recipients with appropriate
services.

Conclusion

As the District works to redesign its TANF program, it should use its available resources to create
a program that better addresses the needs of recipients, from those who need only basic job
readiness and placement assistance to those who need more intensive services to address their
barriers to work. The District can do this by consolidating and improving its assessment process;
creating more pathways for employment, training and supportive services for recipients to take
advantage of once they have been assessed; and improving the engagement of recipients in the
program through community outreach and case management. We believe that these changes can
help both the District and TANF recipients without causing the harm that full family sanctions
would cause. We hope that these recommendations will be helpful as the District moves toward a
more personalized and responsive TANF program.

Submitted by:
1. Academy of Hope
2. Ayuda
3. Bread for the City
4. Capital Area Asset Builders
5. Capital Area Food Bank
6. Center for Law and Social Policy
7. Children’s Law Center
8. Coalition for Housing Justice, Inc.
9. DC Coalition Against Domestic Violence
10. DC Fiscal Policy Institute

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 11. D.C. Hunger Solutions
12. DC Jobs Council
13. D.C. LEARNs
14. The DC Project
15. DC Quality Trust
16. DC Statehood Green Party
17. DC Voice
18. DC Women’s Agenda
19. Fair Budget Coalition
20. Healthy Families/Thriving Communities Collaborative Council
21. Legal Aid Society of DC
22. Mary’s Center for Maternal and Child Care, Inc.
23. Perry School Community Services Center, Inc.
24. Southeast Ministry
25. Washington Legal Clinic for the Homeless
26. Washington Literacy Council
27. We Are Family
28. Wider Opportunities for Women
29. Women Empowered Against Domestic Violence, Inc. (WEAVE)

cc: Ms. Laura Zeilinger, Deputy Director, Department of Human Services

Ms. Deborah Carroll, Administrator, Income Maintenance Administration
Ms. Inessa Lurye, Strategic Planning Officer, Income Maintenance Administration
The Honorable Tommy Wells (Ward-6)
The Honorable Michael Brown (At-Large)